0CAN071105, Supplement to Proposed Emergency Action Levels Using NEI 99-01 Revision 5 Scheme
| ML112082804 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 07/27/2011 |
| From: | David Bice Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 0CAN071105 | |
| Download: ML112082804 (5) | |
Text
0CAN071105 July 27, 2011 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Supplement to Proposed Emergency Action Levels Using NEI 99-01 Revision 5 Scheme Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6
Reference:
- 1.
Entergy letter dated July 18, 2011 (0CAN071102), Proposed Emergency Action Levels Using NEI 99-01 Revision 5 Scheme
- 2.
Letter from Christopher G. Miller (U.S. Nuclear Regulatory Commission) to Alan Nelson (Nuclear Energy Institute) - U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 5, dated February 2008, dated February 22, 2008 (ML080430535)
Dear Sir or Madam:
In Reference 1, Entergy Operations, Inc. (Entergy) submitted changes to the Arkansas Nuclear One (ANO) Emergency Action Levels (EALs), consistent with NEI 99-01, Revision 5, Methodology for Development of Emergency Action Levels. The Reference 1 submittal stated that ANO was upgrading its EALs from NEI 99-01, Revision 4 to Revision 5. This supplement to the Reference 1 letter is intended to provide clarification in this regard. Because ANO has not yet implemented NEI 99-01, Revision 4, as approved by NRC Safety Evaluation Report dated October 6, 2005, the ANO EALs are more specifically being revised from NUREG 0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, which is the current implemented version of the EALs at ANO.
In addition, Entergy has determined that the commitment presented in the original letter is unnecessary (Attachment 6 of the Reference 1 submittal). This resulted in minor changes to two pages (#6 and #13) in Attachment 1 of the original submittal, which are included with this supplement. Entergy requests the associated Reference 1, Attachment 1 pages be replaced with the two pages contained herein and that Attachment 6 of the Reference 1 submittal be deleted (i.e., no longer a part of the NRC review for ANOs EAL upgrades).
Entergy Operations, Inc.
1448 S.R. 333 Russellville, AR 72802 Tel 479-858-5338 David B. Bice Acting Manager, Licensing Arkansas Nuclear One
0CAN071105 Page 2 of 2 If you have any questions or require additional information, please contact me.
Sincerely, Original signed by David B. Bice DBB/dbb
Attachment:
Revision to Entergy letter 0CAN071102, Attachment 1, Pages 6 and 13 (letter dated July 18, 2011) cc:
Mr. Elmo Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam MS O-8 B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852
Attachment to 0CAN071105 Revision to Entergy letter 0CAN071102, Attachment 1, Pages 6 and 13 (letter dated July 18, 2011) to 0CAN071102 Page 6 of 110 NEI 99-01 Revision 5 EAL Deviation-Differences Document ANO: AU1 (Contd)
- 2.
VALID reading on any of the following radiation monitors > 2 times the alarm setpoint established by a current release permit for 60 minutes:
EFFLUENT MONITORS - Unit 1 RX-9820 Containment Purge (Channel 7 or 9)
RE-4830 Waste Gas Radiation Monitor RE-4642 Liquid Radwaste Monitor EFFLUENT MONITORS - Unit 2 2RX-9820 Containment Purge (Channel 7 or 9) 2RE-2429 Waste Gas Decay Tank Vent Line Radiation Monitor 2RE-2330 Regenerative Waste Discharge Monitor 2RE-4423 Radwaste Liquid Discharge Monitor 2RE-4425 SG Blowdown to Flume Radiation Monitor OR
- 3.
Confirmed grab sample analyses for gaseous or liquid releases indicates concentrations or release rates > 2 times the applicable values of the ODCM for 60 minutes.
Deviations:
None.
Differences:
The second (superfluous) reading is deleted in ANO EAL #2.
The radiation monitor channel is identified in EAL #1 in order to provide site-specific detail.
A table is provided in the EAL document that lists the applicable radiation monitors for EAL #2.
ANO has installed telemetered perimeter monitoring devices. These devices, however, are neither qualified nor intended to provide an accurate indication of the dose rate at the perimeter of the site. They are only intended to provide early indication of a potential unmonitored offsite release. Therefore, ANO has not included an EAL comparable to NEI 99-01 Revision 5 AU1 EAL #4.
The Radiological Dose Assessment Computer System (RDACS) is ANOs current real-time dose assessment system, but is out-dated. RDACS is currently scheduled to be replaced prior to implementation of the new EALs with a system that is not a real-time system; therefore, an EAL comparable to NEI 99-01, Revision 5, AU1 EAL #5 has not been included.
to 0CAN071102 Page 13 of 110 NEI 99-01 Revision 5 EAL Deviation-Differences Document Differences:
The radiation monitor channel is identified in EAL #1 in order to provide site-specific detail.
The second (superfluous) reading is deleted in the ANO EAL #2.
EAL #2 and its associated basis information are revised and a table added to provide site-specific information for radiation monitors that may not be capable of providing values within the calibrated range of the monitor at or above the 200 multiple for an alarm setpoint established by a radioactivity discharge permit.
ANO has installed telemetered perimeter monitoring devices. These devices, however, are neither qualified nor intended to provide an accurate indication of the dose rate at the perimeter of the site. They are only intended to provide early indication of a potential unmonitored offsite release. Therefore, ANO has not included an EAL comparable to NEI 99-01, Revision 5, AA1 EAL #4.
The Radiological Dose Assessment Computer System (RDACS) is ANOs current real-time dose assessment system, but is out-dated. RDACS is currently scheduled to be replaced prior to implementation of the new EALs with a system that is not a real-time system; therefore, an EAL comparable to NEI 99-01, Revision 5, AU1 EAL #5 has not been included.