L-PI-13-048, Supplement to License Amendment Request (LAR) to Revise Emergency Plan (EP) Emergency Action Levels (Eals): RA 1.2 and Fuel Clad Barrier Loss Criteria
| ML13172A404 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 06/21/2013 |
| From: | Jeffery Lynch Northern States Power Co, Xcel Energy |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| TAC MF0379, TAC MF0380, L-PI-13-048 | |
| Download: ML13172A404 (11) | |
Text
tl Xcel Energy JUN 2 1 2013 L-PI-13-048 10 CFR 50.90 U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 Renewed License Nos. DPR-42 and DPR-60 Supplement to License Amendment Request (LAR) to Revise Emergency Plan (EP)
Emergency Action Levels (EALs): RA 1.2 and Fuel Clad Barrier Loss Criteria (TAC Nos. MF0379 and MF0380)
By letter dated December 13, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12349A362), Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), requested NRC review and approval of changes to the Emergency Plan for the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, to revise two EALs: RA 1.2 and a Fuel Clad Barrier loss criterion. By letter dated May 9, 2013 (ML13119A155), NRC Staff requested additional information (RAls) on the December 13,2012, LAR (ML12349A362). Pursuant to a phone call with the NRC Staff on June 5, 2013, the due date for the responses to these RAls was extended. By phone call with the NRC Staff on June 11, 2013, the due date for the response to RAI 6 was extended to July 31, 2013. The enclosure to this letter provides responses to the NRC Staff requests for information, except for RAI 6. NSPM submits this supplement in accordance with the provisions of 10 CFR 50.90.
This supplement proposes additional minor technical and administrative changes to EAL RA 1. However, the supplemental information provided in this letter and enclosure does not impact the conclusions of the Determination of No Significant Hazards Consideration or Environmental Assessment presented in the December 13, 2012 (ML12349A362) submittal. With the implementation of the changes proposed in this supplement, the NSPM EP will continue to meet the requirements in 10CFR 50.47(b) and 10CFR 50 Appendix E.
In accordance with 10 CFR 50.91, NSPM is notifying the State of Minnesota of this LAR supplement by transmitting a copy of this letter and enclosure to the designated State Official.
1717 Wakonade Drive East
- Welch, Minnesota 55089-9642 Telephone: 651.388.1121
Document Control Desk Page 2 If there are any questions or if additional information is needed, please contact Mr. Dale Vincent, P.E., at 651-388-1121.
Summary of Commitments This letter contains no new commitments and no revisions to existing commitments.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on 6/~/f3 J2~t/"L-t<J'ame . Lynch Site Ice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosures (1) cc: Administrator, Region III, USNRC Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC State of Minnesota
ENCLOSURE Supplement to License Amendment Request (LAR) to Revise Emergency Plan (EP)
Emergency Action Levels (EALs): RA1.2 and Fuel Clad Barrier Loss Criteria (TAC Nos. MF0379 and MF0380)
By letter dated December 13, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12349A362), Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), requested NRC review and approval of changes to the Emergency Plan for the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, to revise two EALs: RA1.2 and a Fuel Clad Barrier loss criterion. By letter dated May 9,2013 (ML13119A155), NRC Staff requested additional information (RAls) on the December 13, 2012, LAR (ML12349A362). Pursuant to a phone call with the NRC Staff on June 5, 2013, the due date for the responses to these RAls was extended. By phone call with the NRC Staff on June 11, 2013, the due date for the response to RAI 6 was extended to July 31, 2013.
This enclosure provides the responses from NSPM to the NRC RAls provided by letter dated May 9,2013 (ML13119A155), except for RAI 6. In the course of reviewing Table R-1 for the submittal of these RAI responses, NSPM determined that additional human factors improvements to this table are required. The human factors changes and their bases are provided below. Attachment 1 to this Enclosure provides marked up Emergency Plan pages which incorporate the human factor changes and changes discussed in the responses to the RAls. Attachment 2 to this Enclosure provides final Emergency Plan pages which incorporate the human factors changes and changes discussed in the responses to the RAls. These pages supersede the corresponding pages provided in Attachment 2 to the Enclosure to the letter dated December 13, 2012 (ML12349A362).
NRC Request for Additional Information (RAil 1:
A change bar exists to the right of the row for 1(2) R-50 High Range Stack Gas Monitor on Table R-1. Is it intended that the NRC review and approve this entry? It is not described in the license amendment request.
The change bar was from a previous revision for a setpoint change for the R50 monitor that was implemented without prior approval per 10 CFR50.54(q). Attachments 1 and 2 to this Enclosure provide revised page 6-R-8 without the change bar.
Page 1 of 3
EAL RAls NRC RAI2:
Explain the purpose of the OR statement in RA 1.1 and why it is needed when Table R-1 includes R-18 with a value of 900,000 CPM.
NSPM Response to RAJ 2:
The OR statement in RA 1.1 has been removed and the supporting Basis discussion has been revised. Attachments 1 and 2 to this Enclosure provide revised pages 6-R-8 and 6-R-9 with these changes.
NRC RAI3:
Explain the difference between RA 1.1 and RA 1.2. Are there monitors addressed in RA 1.1 that do not appear in table R-1.2? Is it possible to meet only one of these EALs without meeting the other?
As noted in response to RAI 2, the OR statement in RA 1.1 has been deleted and the Basis revised. Further explanation is also provided in the Basis discussion for RA 1.2 as shown on page 6-R-9. Attachments 1 and 2 to this Enclosure provide revised pages 6-R-8 and 6-R-9 with these changes.
NRC RAI4:
Please add clarification to the basis document for the 900,000 setpoint for the R-18 radiation monitor inconsistency from the Initiating Condition language (60x vs. 200x ODCM specification).
NSPM Response to RAJ 4:
Clarification is provided in the Basis for RA 1.2. Attachments 1 and 2 to this Enclosure provide revised page 6-R-9 with these changes.
NRC RAI5:
Note 1 on Table R-1 was added in June 2008 with no explanation in the Technical Bases. Explain how this note will not cause excessive delay in EAL classification if the setpoints on Table R-1 are exceeded or remove this note.
Note 1 on Table R-1 will be removed. Attachments 1 and 2 to this Enclosure provide revised page 6-R-8 with these changes.
Page 2 of 3
EAL RAls Human Factors Changes The following human factor changes have been included in Table R-1 as shown in Attachments 1 and 2 to this enclosure:
o The units of measure (mR/hr) were removed from the 1(2) R-50 High Range Stack Gas Monitor values for General Emergency (GE) and Site Area Emergency (SAE) and placed at the column heading to be consistent with the presentation of Alert and Notification of Unusual Event (UE) values.
o Commas have been included between the thousand and the hundred place numbers in all values to be consistent.
o A space is included between the plant unit number and "R" for all radiation monitors to be consistent.
o The names of the ventilation systems have been made consistent by deleting "Unit 1" or "Unit 2" and deleting "s" from "Monitors".
o Monitors that have the same action level values for both units have been combined on a single line with the designation "1 (2)" to be consistent with site conventions.
o Each monitor is given a separate line(s) to eliminate the use of the ampersand
(&). The use of "&" (and) is ambiguous and could lead to errors since the intent is that either monitor reading at the stated value would require action, not both concurrently as implied by the use of "&".
o An extra space is removed from the Alert value for R-18. This was a typing error.
Page 3 of 3
ENCLOSURE, ATTACHMENT 1 Emergency Plan, Emergency Action Level Page (Markup)
F3-2.1, page 6-R-8 F3-2.1, page 6-R-9 2 pages follow
ABNORMAL RAD LEVELS/RADIOLOGICAL EFFLUENT RA1 Initiating Condition -- ALERT Any UNPLANNED Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds 200 Times the Offsite Dose Calculation Manual Specification for 15 Minutes or Longer.
Operating Mode Applicability: All Emergency Action Levels: (RA1.1 or RA1.2 or RA1.3)
---RA1.1. VALID reading on any effluent monitor that exceeds 200 Times the alarm setpoint established by a current radioactivity discharge permit for 15 minutes or longer GR VALID reading on effluent monitor R 18 that exceeds 900,000 cpm for 15 minutes or longer.
RA 1.2. VALID reading on one or more of the following radiation monitors (Table R-1) that exceeds the reading shown for 15 minutes or longer:
I Table R-1 Effluent Monitor Classification Thresholds I Monitor GE SAE Alert UE Gaseous mBLhr mBLhr CPM CPM 1(2) R-50 High Range Stack Gas Monitor 43+/-000--ft::lRA:H: 4+/-300--ft::lRA:H: N/A N/A 1 R-22* Shield Building Vent Rad Monitor N/A N/A 160,000*/ 1.6 E5 1.600*/ 1.6 E3 2 R-22* Shield Building Vent Rad Monitor N/A N/A 100,000*/1 E5 1+/-000*/1 E3 1QR-30* & 1R 37* Unit 1 Aux. Building Vent N/A N/A 100,000*/ 1 E5 1+/-000*/1 E3 Rad Monitors 1~=R-3ZQ* 1JfI.i.t-.&Aux. Building Vent Rad N/A N/A 100,000*/ 1 E5 1+/-000*/1 E3 Monitors 2=R-37* 1JfI.i.t-.&Aux. Building Vent Rad Monitors N/A N/A 120,000*/1.2 E5 1+/-200*/1.2 E3 R-35* Radwaste Building Vent Rad Monitor N/A N/A 100,000*/1 E5 1+/-000*/1 E3 R-25* & R 31* Spent Fuel Pool Vent Rad N/A N/A 800,000*/8 E5 8+/-000*/8 E3 Monitors B-3:1* Sgeot Fuel PQQI 'lieot Bad MQoitQ[ tILA tILA SQQ QQQ*[ SE5 S QQQ* S E3 Liquid R-18* Waste Effluent Liquid Monitor N/A N/A 900,-000*/9 E5 30,000*/3 E4 1=R-19*SG Blowdown Radiation Monitor N/A N/A 100,000*11 E5 1,000*/1 E3 2=R-19*SG Blowdown Radiation Monitor N/A N/A 60,000*/6 E4 600*/6 E2 R-21 eirc Water Discharge Monitor N/A N/A 800,000/8 E5 8+/-000/8 E3 Notes:
- 1. ERGS EAL Alarms indicate an EAL threshold MAY have been exceeded. Further evaluation of the radiation monitor reading is required to determine if the EAL threshold is exceeded.
b---*Applies when Effluent discharge not isolated.
RA 1.3. Confirmed sample analysis for gaseous or liquid release indicates concentrations or release rates, with a release duration of 15 minutes or longer, in excess of 200 Times ODCM specification.
PINGP 6-R-8 F3-2.1, Rev. 8
Basis:
This IC addresses a potential or actual decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. PINGP incorporates features intended to control the release of radioactive effluents to the environment.
Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases. These controls are located in the affsite Dose Calculation Manual (aDCM) [Ref. 3, 5]. The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of degradation in these features and/or controls.
The aDCM specification multiples are specified in ICs RU1 and RA1 only to distinguish between non-emergency conditions, and from each other. While these multiples obviously correspond to an offsite dose or dose rate, the emphasis in classifying these events is the degradation in the level of safety of the plant, NaT the magnitude of the associated dose or dose rate. Releases should not be prorated or averaged.
UNPLANNED, as used in this context, includes any release for which a radioactivity discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit. The Emergency Director should not wait until 15 minutes has elapsed, but should declare the event as soon as it is determined that the release duration has or will likely exceed 15 minutes. Also, if an ongoing release is detected and the starting time for that release is unknown, the Emergency Director should, in the absence of data to the contrary, assume that the release has exceeded 15 minutes.
RA 1.1 is intended for effluent monitoring on routine release pathways for which a discharge permit is normally prepared. This EAL addresses radioactivity releases that for whatever reason cause effluent radiation monitor readings to exceed 900,000 cpm for R 18 or 200 Times alarm setpoint for all etJ::l.ef--applicable radiation monitors established by the radioactivity discharge permit for greater than 15 minutes. These alarm setpoints are associated with a planned batch release, or a continuous release path. In either case, the setpoint is established by the -aDCM to warn of a release that is not in compliance with the aDCM specification. Indexing the EAL threshold to the aDCM setpoints in this manner insures that the EAL threshold will never be less than the setpoint established by a specific discharge permit.
RA 1.2 is similar to RA 1.1, but is intended to address effluent or accident radiation monitors on non-routine release pathways (Le., for which a discharge permit would not normally be prepared).
The aDCM establishes a methodology for determining effluent radiation monitor setpoints. The aDCM specifies default source terms and, for gaseous releases, prescribes the use of pre-determined annual average meteorology in the most limiting downwind sector for showing compliance with the regulatory commitments. These monitor reading EALs have been determined using this methodology. The specific effluent monitor setpoints are changed or managed based on monitor recalibrations and planned plant processes to ensure the final aDCM specification limits are not exceeded. As a result the EAL uses thresholds expressed as 900,000 cpm for R 18 Bf-200 Times the alarm setpoint values for all other applicable radiation monitors with the exception of the R-18 monitor. R-18, Waste Effluent Discharge Monitor. is offscale for a release via that pathway that would exceed 200 Times the aCDM limit. To maintain the ability to classify an abnormal release consistent with the intent of NEI 99-01. Revision 4, and maintain the ability to classify in a timely manner based on the monitor reading. a value of 60 Times the aCDM was selected. The limit of 60 Times the aCDM value ensures the monitor can be read onscale and is sufficiently high to limit unnecessary classifications.
RA 1.3 addresses uncontrolled releases that are detected by sample analyses, particularly on unmonitored pathways, e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.
PINGP 6-R-9 F3-2.1, Rev. 8
ENCLOSURE,ATTACHMENT2 Emergency Plan, Emergency Action Level Pages (Final)
F3-2.1, page 6-R-8 F3-2.1, page 6-R-9 2 pages follow
ABNORMAL RAil LEVELS/RADIOLOGICAL EFFLUENT RA1 Initiating Condition E~ ALERT Any UNPLANNED Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds 200 Times the Offsite Dose Calculation Manual Specification for 15 Minutes or Longer.
Operating Mode Applicability: All Emergency Action levels: (RA1.1 or RA1.2 or RA1.3)
RA 1.1. VALID reading on any effluent monitor that exceeds 200 Times the alarm setpoint established by a current radioactivity discharge permit for 15 minutes or longer RA1.2. VALID reading on one or more of the following radiation monitors (Table R-1) that exceeds the reading shown for 15 minutes or longer:
I Table R-1 Effluent Monitor Classification Thresholds I I Monitor I GE I SAE I Alert I UE I Gaseous mRfhr mRfhr CPM CPM 1(2) R-50 High Range Stack Gas Monitor 43,000 4,300 N/A N/A 1 R-22* Shield Building Vent Rad Monitor N/A N/A 160,000*/1.6 E5 1,600*/1.6 E3 2 R-22* Shield Building Vent Rad Monitor N/A N/A 100,000*/1 E5 1,000*11 E3 1(2) R-30* Aux. Building Vent Rad Monitor N/A N/A 100,000*11 E5 1,000*11 E3 1 R-37* Aux. Building Vent Rad Monitor N/A N/A 100,000*11 E5 1,000*11 E3 2 R-37* Aux. Building Vent Rad Monitor N/A N/A 120,000*/1.2 E5 1,200*/1.2 E3 R-35* Radwaste Building Vent Rad Monitor N/A N/A 100,000*11 E5 1,000*11 E3 R-25* Spent Fuel Pool Vent Rad Monitor N/A N/A 800,000*18 E5 8,000*/8 E3 R-31* Spent Fuel Pool Vent Rad Monitor N/A N/A 800,000*/8E5 8,000* 8 E3 Liquid R-18* Waste Effluent Liquid Monitor N/A N/A 900,000*/9 E5 30,000*13 E4 1 R-19*SG Blowdown Radiation Monitor N/A N/A 100,000*11 E5 1,000*11 E3 2 R-19*SG Blowdown Radiation Monitor N/A N/A 60,000*/6 E4 600*/6 E2 R-21 eirc Water Discharge Monitor N/A N/A 800,000/8 E5 8,000/8 E3 Note:
- Applies when Effluent discharge not isolated.
RA 1.3. Confirmed sample analysis for gaseous or liquid release indicates concentrations or release rates, with a release duration of 15 minutes or longer, in excess of 200 Times ODCM specification.
PINGP 6-R-8 F3-2.1, Rev. 8
Basis:
This IC addresses a potential or actual decrease in the level of safety of the plant as indicated by a radiological release that exceeds regulatory commitments for an extended period of time. PINGP incorporates features intended to control the release of radioactive effluents to the environment.
Further, there are administrative controls established to prevent unintentional releases, or control and monitor intentional releases. These controls are located in the Offsite Dose Calculation Manual (ODCM) [Ref. 3, 5]. The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of degradation in these features and/or controls, The ODCM specification multiples are specified in ICs RU1 and RA1 only to distinguish between non-emergency conditions, and from each other, While these multiples obviously correspond to an offsite dose or dose rate, the emphasis in classifying these events is the degradation in the level of safety of the plant, NOT the magnitude of the associated dose or dose rate. Releases should not be prorated or averaged.
UNPLANNED, as used in this context, includes any release for which a radioactivity discharge permit was not prepared, or a release that exceeds the conditions (e,g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit. The Emergency Director should not wait until 15 minutes has elapsed, but should declare the event as soon as it is determined that the release duration has or will likely exceed 15 minutes. Also, if an ongoing release is detected and the starting time for that release is unknown, the Emergency Director should, in the absence of data to the contrary, assume that the release has exceeded 15 minutes.
RA 1.1 is intended for effluent monitoring on routine release pathways for which a discharge permit is normally prepared. This EAL addresses radioactivity releases that for whatever reason cause effluent radiation monitor readings to exceed 200 Times alarm setpoint for all applicable radiation monitors established by the radioactivity discharge permit for greater than 15 minutes. These alarm setpoints are associated with a planned batch release, or a continuous release path. In either case, the setpoint is established by the ODCM to warn of a release that is not in compliance with the ODCM specification. Indexing the EAL threshold to the ODCM setpoints in this manner insures that the EAL threshold will never be less than the setpoint established by a specific discharge permit.
RA 1.2 is similar to RA 1.1, but is intended to address effluent or accident radiation monitors on non-routine release pathways (I.e., for which a discharge permit would not normally be prepared).
The ODCM establishes a methodology for determining effluent radiation monitor setpoints. The ODCM specifies default source terms and, for gaseous releases, prescribes the use of pre-determined annual average meteorology in the most limiting downwind sector for showing compliance with the regulatory commitments. These monitor reading EALs have been determined using this methodology. The specific effluent monitor setpoints are changed or managed based on monitor recalibrations and planned plant processes to ensure the final ODCM specification limits are not exceeded. As a result the EAL uses thresholds expressed as 200 Times the alarm setpoint values for all applicable radiation monitors with the exception of the R-18 monitor. R-18, Waste Effluent Discharge Monitor, is offscale for a release via that pathway that would exceed 200 Times the OCDM limit To maintain the ability to classify an abnormal release consistent with the intent of NEI 99-01, Revision 4, and maintain the ability to classify in a timely manner based on the monitor reading, a value of 60 Times the OCDM was selected. The limit of 60 Times the OCDM value ensures the monitor can be read onscale and is sufficiently high to limit unnecessary classifications, RA 1.3 addresses uncontrolled releases that are detected by sample analyses, particularly on unmonitored pathways, e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.
PINGP 6-R-9 F3-2.1, Rev. 8