ML100550212

Request for Additional Information, Proposed Changes to the Emergency Plan

ML100550212
Person / Time
Site:	Ginna
Issue date:	03/09/2010
From:	Pickett D Plant Licensing Branch 1
To:	John Carlin Ginna
Pickett D
References
TAC ME2916
Download: ML100550212 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. John T. Carlin Vice President RE. Ginna Nuclear Power Plant RE. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, NY 14519

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RE: PROPOSED CHANGES TO THE EMERGENCY PLAN (TAC NO. ME2916)

Dear Mr. Carlin:

By letter dated November 30, 2009, pursuant to Title 10 of the Code of Federal Regulations, Section 50.90, RE. Ginna Nuclear Power Plant, LLC submitted proposed changes to the RE.

Ginna Nuclear Power Plant Emergency Plan. The changes involve upgrading selected Ginna Emergency Action Levels based on Nuclear Energy Institute 99-01, Revision 5, "Methodology for Development of Emergency Action Levels."

The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided and has determined that additional information is needed to complete its review. Enclosed is the NRC staff's request for additional information (RAI). As discussed with your staff, we understand that you intend to respond to this RAI within four weeks of the date of this letter.

Please contact me at 301-415-1364 if you have any questions.

Sincerely,

~vP~

Douglas V. Pickett, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-244

Enclosure:

As stated cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION EMERGENCY ACTION LEVEL CHANGES RE. GINNA NUCLEAR POWER PLANT DOCKET NO. 50-244

1. EAL Scheme The current emergency action levels (EALs) scheme in use at Ginna is based on NUMARC/NESP-007, January 1992, "Methodology for Development of Emergency Action Levels." The proposed changes involve upgrading selected Ginna EALs based on Nuclear Energy Institute (NEI) 99-01, Revision 5, "Methodology for Development of Emergency Action Levels," using the guidance of NRC Regulatory Issue Summary 2003-18, Supplement 2, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels."

Does Ginna have future plans to upgrade the overall EAL scheme to NEI 99-01, Revision 5?

2. Section 2.0, "Detailed Description," contains the following errors/discrepancies, please correct them or provide justification to support their inclusion:

You state ".. .the following selected hazard-based EALs ..." when it is actually hazard and system based EALs.

You state "... Nuclear Energy Institute (NEI) 99-01, Revision 5,... January 2003, as endorsed by the Nuclear Regulatory Commission (NRC) in Regulatory Guide (RG) 1.101... " when in fact the version of NEI 99-01, Revision 5, endorsed by the NRC is dated February 2008, and it was endorsed by letter [ADAMS Accession No. ML080430535] not by RG 1.101.

3. Section 6.0, "References" Please put in the ADAMS Accession Nos. of the stated documents

4. EAL 7.3.1 The "note" from NEI 99-01, Revision 5, is intended to be within the body of the EAL, not in the Basis information. Please align with staff expectations for the development of this EAL or justify why it is inappropriate for Ginna.

5. EAL 7.3.3 The "note" from NEI 99-01, Revision 5, is intended to be within the body of the EAL, not in the Basis information. Please align with staff expectations for the development of this EAL or justify why it is inappropriate for Ginna.

Enclosure

-2

6. EAL 7.3.4 The "note" from NEI 99-01, Revision 5, is intended to be within the body of the EAL, not in the Basis information. Please align with staff expectations for the development of this EAL or justify why it is inappropriate for Ginna.

There is a probable logic issue with how Ginna developed this EAL. There are three separate EAL thresholds logically "and-ed" together, however, the first threshold as two thresholds logically "or-ed." The EAL as submitted does not appear to satisfy the intent of the endorsed development guide. Please align with staff expectations for the development of this EAL or justify why it is inappropriate for Ginna.

7. EAL 8.2.1 The "note" from NEI 99-01, Revision 5, is intended to be within the body of the EAL.

Please align with staff expectations for the development of this EAL or justify why it is inappropriate for Ginna.

8. EAL 8.2.2 Please explain why there is a different table for EAL 8.2.1 and EAL 8.2.2. The staff's expectation is that these tables be the same. The difference between the Alert and the Unusual Event is evidence of visible damage or degraded performance.

9. EAL 8.3.5 The "note" from NEI 99-01, Revision 5, is intended to be within the body of the EAL.

Please align with staff expectations for the development of this EAL or justify why it is inappropriate for Ginna.

10. Attachment 4 Please explain the implementation method for Ginna.

If this is the primary tool used for EAL declaration, then please explain why the Initiating Condition (IC) and applicable "notes" are not included. The staff considers the IC-EAL, "Thresholds-Operating Modes-Notes," all to be of importance in declaring the EAL in a timely manner. The applicable Basis information is intended to be available to support understanding of the EAL and to aid in ensuring the consistency of training.

Please explain the implementation method used by Ginna, Le., do you use EAL Wallboards or do you use your Emergency Plan and Emergency Plan Implementing Procedures directly?

March 9, 2010 Mr. John T. Carlin Vice President RE. Ginna Nuclear Power Plant RE. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, NY 14519 SUB-JECr: REQUEST FOR ADDITIONAL INFORMATION RE: PROPOSED CHANGES TO THE EMERGENCY PLAN (TAC NO. ME2916)

Dear Mr. Carlin:

By letter dated November 30, 2009, pursuant to Title 10 of the Code of Federal Regulations, Section 50.90, RE. Ginna Nuclear Power Plant, LLC submitted proposed changes to the RE.

Ginna Nuclear Power Plant Emergency Plan. The changes involve upgrading selected Ginna Emergency Action Levels based on Nuclear Energy Institute 99-01, Revision 5, "Methodology for Development of Emergency Action Levels."

The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided and has determined that additional information is needed to complete its review. Enclosed is the NRC staff's request for additional information (RAI). As discussed with your staff, we understand that you intend to respond to this RAI within four weeks of the date of this letter.

Please contact me at 301-415-1364 if you have any questions.

Sincerely, IRA!

Douglas V. Pickett, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-244

Enclosure:

As stated cc w/encl: Distribution via Listserv Distribution:

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