ML092600263
| ML092600263 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/13/2009 |
| From: | Kalyanam N Plant Licensing Branch IV |
| To: | Entergy Operations |
| Kalyanam N, NRR/DORL/LPL4, 415-1480 | |
| References | |
| TAC ME1828 | |
| Download: ML092600263 (9) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 CX:tober 13, 2009 Vice President, Operations Entergy Operations, Inc.
Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093 SUB~IECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - SAFETY EVALUATION ON PROPOSED EMERGENCY ACTION LEVEL CHANGES (TAC NO. ME1828)
Dear Sir or Madam:
By letter dated August 4, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092170758), Entergy Operations Inc. (the licensee), requested prior U.S. Nuclear Regulatory Commission (NRC) approval for proposed changes to emergency action levels (EALs) CU4 and SU9 for the Waterford Steam Electric Station, Unit 3 (Waterford 3). A subsequent letter dated August 11, 2009 (ADAMS Accession No. ML092240610), superseded the August 4, 2009, letter in its entirety. The requested changes to the licensee's EALs are to align these EALs with the latest endorsed EAL guidance provided in Nuclear Energy Institute (NEI) 99-01, Revision 5, "Methodology for Development of Emergency Action Levels" (ADAMS Accession No. ML080450149), and site Technical Specifications.
The NRC staff performed a review of the proposed changes to Waterford 3's EALs in accordance with the regulations in paragraph 50.54(q) of Title 10 of the Code of Federal Regulations (10 CFR). The NRC staff concludes that the proposed changes would not result in a decrease in effectiveness, and as changed, continue to meet the requirements in 10 CFR 50.47(b) and in 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities." No NRC approval is necessary. The NRC safety evaluation is enclosed.
The NRC staff expects that the licensee will implement these EALs as provided in of the licensee's letter dated August 11, 2009, which includes the implementation of the Emergency Action Level Technical Basis Document changes. If the licensee changes the EALs via 10 CFR 50.54(q) prior to implementation, the licensee shall ensure that the changes are provided to the NRC during the next emergency preparedness baseline inspection.
- 2 If you have any questions, please contact me at (301) 415-1480 or by electronic mail at kaly.kalyanam@nrc.gov.
Sincerely, ~
~ -
N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosure:
As stated cc w/encl: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ON PROPOSED REVISIONS TO EMERGENCY ACTION LEVELS WATERFORD STEAM ELECTRIC STATION, UNIT 3 ENTERGY OPERATIONS, INC.
DOCKET NO. 50-382
1.0 INTRODUCTION
By letter dated August 4, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092170758), Entergy Operations Inc. (the licensee), requested prior U.S. Nuclear Regulatory Commission (NRC) approval for proposed changes to emergency action levels (EALs) CU4 and SU9 for the Waterford Steam Electric Station, Unit 3 (Waterford 3). A subsequent letter dated August 11, 2009, (ADAMS Accession No. ML092240610) superseded the August 4, 2009, letter in its entirety. The requested changes to the licensee's EALs are to align these EALs with the latest endorsed EAL guidance provided in Nuclear Energy Institute (NEI) 99-01, Revision 5, "Methodology for Development of Emergency Action Levels," (ADAMS Accession No. ML080450149), and site Technical Specifications.
Specifically, the requested changes to these EALs are as follows:
CU4 - This EAL has been deleted from the latest endorsed EAL scheme as it is bounded by other EALs applicable in cold shutdown operating modes and is more in alignment with site-specific Technical Specifications. The licensee proposes deleting this EAL from its approved EAL scheme.
SU9 - The licensee proposes revising this EAL to align it with the values and time periods stated in the Waterford 3 Technical Specification 3.4.7, "Reactor Coolant System, Specific Activity," which would also prevent erroneous EAL classifications.
2.0 REGULATORY EVALUATION
The NRC staff reviewed the proposed revision against the following regulations and guidance described below.
Enclosure
- 2 2.1 Regulations The regulations in Title 10 of the Code of Federal Regulations (10 CFR), Section 50.47, "Emergency plans," set forth emergency plan requirements for nuclear power plant facilities.
Paragraph 50.47(a)(1 )(i) states, in part, that
... no initial operating license for a nuclear power reactor will be issued unless a finding is made by the NRC that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.
Paragraph 50.47(b) establishes the standards that the onsite and offsite emergency response plans must meet for the NRC staff to make a positive finding that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. One of these standards (10 CFR 50.47(b)(4)) stipulates that emergency plans include a standard emergency classification and action level scheme.
The regulations in 10 CFR 50.54(q) state, in part, that:
...A holder of a nuclear power reactor operating license... shall follow and maintain in effect em~rgency plans which meet the requirements in appendix E to this part.... The nuclear power reactor licensee may make changes to these plans without Commission approval only if the changes do not decrease the effectiveness of the plans and the plans, as changed, continue to meet the standards of § 50.47(b) and the requirements of appendix E to this part....
Proposed changes that decrease the effectiveness of the approved emergency plans may not be implemented without application to and approval by the Commission.
Section IV.B, "Assessment Actions," of Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," to 10 CFR Part 50, states, in part, that:
The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be us-ed for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. These initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC.
Thereafter, emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis. A revision to an emergency action level must be approved by the NRC before implementation if:
- 3 (1)
The licensee is changing from one emergency action level scheme to another emergency action level scheme (e.g., a change from an emergency action level scheme based on NUREG-0654 to a scheme based upon NUMARC/NESP-007 or NEI-99-01);
(2)
The licensee is proposing an alternate method for complying with the regulations; or (3)
The emergency action level revision decreases the effectiveness of the emergency plan.
2.2 Guidance Regulatory Guide (RG) 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors," Revision 2, dated October 1981 (ADAMS Accession No. ML090440294), states, in part, that:
The criteria and recommendations contained in Revision 1 of NUREG 0654/FEMA-REP-1 are considered by the NRC staff to be generally acceptable methods for complying with the standards in § 50.47 of 10 CFR Part 50 that must be met in onsite and offsite emergency response plans.
Revisions 3 and 4 of RG 1.101 endorsed Nuclear Management and Resources Council, Inc.
(NUMARC)/National Environmental Studies Project (NESP)-007, Revision 2, "Methodology for Development of Emergency Action Levels," dated January 1992 (ADAMS Accession No. ML041120174), and NEI 99-01, Revision 4, "Methodology for Development of Emergency Action Levels," dated January 2003 (ADAMS Accession No. ML030230250), respectively, as acceptable alternatives to the guidance provided in NUREG-0654 for development of EALs to comply with 10 CFR 50.47 and Appendix E to 10 CFR Part 50.
In a letter to NEI dated February 22,2008 (ADAMS Accession No. ML080430535), the NRC staff concluded that the guidance contained in I\\IEI 99-01, Revision 5, is an acceptable method to develop an EAL scheme that meets the requirements of in Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4). Henceforth NEI 99-01, Revision 5, will be referred to as NEI 99-01.
NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," dated November 1980 (NUREG-0654) (ADAMS Accession No. ML040420012), includes the following criteria:
Section 11.0.1 - An emergency classification and emergency action level scheme as set forth in Appendix 1 must be established by the licensee.
Section 11.0.2 - The initiating conditions shall include the example conditions found in Appendix 1 [of NUREG-0654].
-4 Guidance is also provided in Regulatory Issue Summary (RIS) 2005-02, "Clarifying the Process for Making Emergency Plan Changes," dated February 14, 2005 (ADAMS Accession No. ML042580404). This RIS provides guidance to licensees when evaluating proposed changes to their emergency preparedness programs.
3.0 TECHNICAL EVALUATION
The licensee submitted the proposed changes for a technical and regulatory review before implementing them, as required under 10 CFR 50.54(q). This evaluation is based on a revision to EALs CU4 and SU9 provided in the licensee's letter dated August 11, 2009. In the letter, the licensee submitted the proposed EALs, their technical basis, and justification for each change.
The NRC staff has reviewed the technical basis for the proposed EALs and the licensee's justifications.
The requested changes to the licensee's EALs are to align these EALs with the latest endorsed EAL guidance, NEI 99-01, and site Technical Specifications. Specifically, the requested changes to these EALs are as follows:
CU4 - This EAL has been deleted from the latest endorsed EAL scheme as it is bounded by other EALs applicable in cold shutdown operating modes and is more in alignment with the site-specific Technical Specifications. The licensee proposes deleting this EAL from its approved EAL scheme.
SU9 - The licensee proposes revising this EAL to align it with the values and time periods stated in its Technical Specification 3.4.7, which would also prevent erroneous EAL classifications.
The NRC staff reviewed the proposed EALs against the guidance in NEI 99-01 to determine if the EALs for Waterford 3, as provided in its application, meet the guidelines in that document.
The staff considered the following !\\lEI 99-01 guidelines in its review:
Consistency (i.e., the EALs would lead to similar decisions under similar circumstances at different plants)
Human engineering and user friendliness Potential for classification upgrade only when there is an increasing threat to public health and safety Ease of upgrading and downgrading Thoroughness in addressing and disposing of the issues of completeness and accuracy raised regarding Appendix 1 to NUREG-0654 Technical completeness for each classification level
- 5 Logical progression in classification for multiple events Objective and observable values The NRC staff reviewed the proposed EALs and has determined that they are consistent with EALs implemented at similar designed plants, that they use objective and observable values, and that they are consistent with the intent of NEI 99-01.
The NRC staff reviewed the proposed EALs to determine if they are worded in a manner that addresses human engineering and user friendliness concerns. The proposed EALs use procedure language, including specific tag numbers for instrument readings and alarms and use flow charts, critical safety function status trees, check lists, and combinations of the above.
Based on this review, the staff has determined that the proposed EALs meet the guidelines in NEI 99-01 in these areas.
The NRC staff reviewed the proposed EAL sets1 for technical completeness and has determined that classification upgrades are based upon an increasing threat to public health and safety, that they can effectively support upgrading and downgrading, and that they follow a logical progression for multiple events. Based on this review, the NRC staff concludes that the EALs are in accordance with the intent of NEI 99-01 in these areas.
The NRC staff also reviewed the proposed EALs for technical completeness and accuracy for each classification level. The proposed EALs are based on risk assessment to set the boundaries of the emergency classification levels and assure that all EALs that trigger that emergency classification are in the same range of relative risk. Precursor conditions of more serious emergencies also represent a potential risk to the public and are appropriately classified. The staff has determined that the proposed EALs are consistent with NEI 99-01, which is an acceptable alternative to EALs based on NUREG-0654, Appendix 1.
Based on its review of the proposed EALs, the NRC staff concludes that these EALs meet the guidelines in NEI 99-01 for all of the areas listed above in this section. Therefore, the staff further concludes that the proposed EALs meet NEI 99-01, which is an acceptable method for use in complying with the regulatory requirements listed in Section 2.0 of this safety evaluation.
1 EAL sets are groups of EALs within a category related to a common concern. For example, unusual event, alert, site area emergency, and general emergency EALs related to a failure of the plant to shut down through an automatic scram would be considered an EAL set.
- 6
4.0 CONCLUSION
The NRC staff performed a technical and regulatory review of the proposed changes to the Waterford 3 EALs. The staff has determined that the proposed changes meet the guidelines in I\\JEI 99-01, which is an acceptable method for the development of an EAL scheme that meets the regulatory requirements. Based on this determination, the staff concludes that the proposed EALs do not result in a decrease in effectiveness, meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, and that they also provide reasonable assurance that the licensee will take adequate protective measures in a radiological emergency.
Therefore, the NRC staff concludes that the proposed EAL changes are acceptable.
Principal Contributor: D. Johnson Date: October 13, 2009
- 2 If you have any questions, please contact me at (301) 415-1480 or by electronic mail at kaly. kalyanam@nrc.gov.
Sincerely, IRA!
N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosure:
As stated cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC LPLIV R/F RidsAcrsAcnw_MailCTR Resource RidsNrrDorlDpr Resource RidsNrrDorlLpl4 Resource RidsNrrPMWaterford Resource RidsNrrLAJBurkhardt Resource RidsNsirDprDdep Resource RidsOgcRp Resource RidsRgn4MailCenter Resource DJohnson, NSIR/DPR/DDEP/ORLP ADAMS Accession No. ML092600263 d
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NRR/DORLlLPL4/BC NRR/DORLlLPL4/PM NAME NKalyanam JBurkhardt KWiliiams MMarkley BSingal for NKalyanam DATE 9/28/09 9/24/09 9/9109 10/13/09 10/13/09 OFFICIAL RECORD COpy