ML15063A355

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Issuance of Amendment to Revise Emergency Action Levels to a Scheme Based on NEI 99-01, Revision 6
ML15063A355
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 04/13/2015
From: Shawn Williams
Plant Licensing Branch II
To: Gatlin T
South Carolina Electric & Gas Co
Williams S
References
TAC MF3927
Download: ML15063A355 (25)
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Text

UNITED STATES .,

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 13, 2015 Mr. Thomas D. Gatlin Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 800 Jenkinsville, SC 29065

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 - ISSUANCE OF AMENDMENT TO REVISE EMERGENCY ACTION LEVELS TO A SCHEME BASED ON NEI 99-01, REVISION 6 (TAC NO. MF3927)

Dear Mr. Gatlin:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 200 to Renewed Facility Operating License No. NPF-12 for the Virgil C. Summer Nuclear Station, Unit 1 (VCSNS), in response to your letter dated April 7, 2014, as supplemented by letters dated October 3, 2014, and March 18, 2015. *This amendment approves a revision to the emergency action levels from a scheme based on NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels" to a scheme based on NEI 99-01, Revision 6, "Development of Emergency Action.Levels for Non-Passive Reactors."

~.A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, Shawn Williams, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosures:

1. Amendment No. 200 to NPF-12
2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED .STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTH CAROLINA ELECTRIC & GAS COMPANY SOUTH CAROLINA PUBLIC SERVICE AUTHORITY DOCKET NO. 50-395 VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 200 Renewed License No. NPF-12

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment to the Virgil C. Summer Nuclear Station, Unit 1, (the facility) Renewed Facility Operating License No. NPF-12 filed by the South Carolina Electric & Gas Company (the licensee), dated April 7, 2014, as supplemented by letters dated October 3, 2014, and March 18, 2015, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations as set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by page changes, as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No.

NPF-12 is hereby amended to read as.follows:

. (2) Technical Specifications and Environmental Protection Plan The Technical.Specifications contained in Appendix A, as revised through Amendment No. 200, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license .. South Carolina Electric & Gas Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This amendment is effective as of its date of issuance and shall be implemented within 180 days of issuance.

FOR THE NUCLEAR REGULA TORY COMMISSION Robert J. Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-12 Date of Issuance: April 13, 2015

ATIACHMENT TO LICENSE AMENDMENT NO. 200 RENEWED FACILITY OPERATING LICENSE NO. NPF-12 DOCKET NO. 50-395 Replace the following page of the Renewed Facility Operating License No. NPF-12 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Pages Insert Pages NPF-12, Page 3 NPF-12, Page 3

(3) . SCE&G, pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage amounts required for reactor operation, as described in the Final Safety Analysis Report, as amended through Amendment No. 33; (4) SCE&G, pursuant to the Act and 10 CFR. Part 30, 40 and 70 to receive, possess and use at ahy time byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed neutron

  • sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) SCE&G, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus of components; and (6) SCE&G, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess., but not separate, such byproduct and special nuclear materials as my be produced by the operation of the facility.

C. This renewed license shall be deemed to contain, and is subject to, the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below.:

(1) Maximum Power Level SCE&G is authorized to perathe the facility at reactor core power levels

. not in excess of 2900 megawatts thermal in accordance with the conditions specified herein and in Attachment 1 to this renewed license.

The preoccupation tests, startup tests .and other items identified in Attachment 1 to this renewed license shall be completed as specified.

Attachment '1 is hereby incorporated into this renewed license.

(2) Technical Specifications and Environmental Protection Plant The Technical Specifications contained in Appendix A, as revised through Amendment No. in and the Environmental Protection Plan contained in Appendix 8, are hereoy incorporated in the renewed license. South Carolina Electric & Gas Company shall operate the facility In accordance with the Tech.nical Specifications and the Environmental Protection Plan.

Renewed Facility Operating License No. NPF-12 Amendment No. 200

UNITED .STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 200 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-12 SOUTH CAROLINA ELECTRIC & GAS COMPANY SOUTH CAROLINA PUBLIC SERVICE AUTHORITY VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 DOCKET NO. 50-395

1.0 INTRODUCTION

By letter dated April 7, 2014 (Reference 13), as supplemented by letters dated October 3, 2014 (Reference 14) and March 18, 2015 (Reference 16), South Carolina Electric & Gas Company (SCE&G, the licensee) submitted a proposed change to the emergency action levels (EALs) used at the Virgil C. Summer Nuclear Station, Unit 1 (VCSNS). The supplemental letters provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on June 6, 2014 (79 FR 32771).

SCE&G proposes to change the EALs from a scheme based on NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels" to a scheme based on NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," dated November 2012 (Reference 6).

2.0 REGULATORY EVALUATION

The NRC staff reviewed the proposed revision against the following regulations and guidance described below.

2.1 Regulations Title 10 of the Code of Federal Regulations (10 CFR), Section 50.47, "Emergency plans," sets forth emergency plan requirements for nuclear power plant facilities. The regulations in 10 CFR 50.47(a)(1 )(i) state, 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 Enclosure 2

protective measures can and will be taken in the event of a radiological emergency.

Section 50.47(b) establishes the standards that the onsite and offsite emergency response plans must meet for 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.

Planning Standard (4) of this section requires that onsite and offsite emergency response plans contain:

A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the. nuclear facility licensee, and State *and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

Section 50.47(b)(4) to 10 CFR emphasizes a standard emergency classification and action level scheme, assuring that implementation methods are relatively consistent throughout the industry for a given reactor and containment design while simultaneously providing an opportunity for a licensee to modify its EAL scheme as necessary to address plant-specific design considerations or preferences.

Section IV.B of Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," to 10 .CFR Part 50, states, in part:

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 used 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. By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant.

The EAL scheme change proposed by SCE&G was submitted to the NRC for a technical and regulatory review prior to its implementation consistent with Appendix E to 10 CFR Part 50, Section IV.B.2, which states that, "A licensee desiring to change its entire emergency action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change." This NRC staff review is based upon a change to the VCSNS EAL scheme provided in the licensee's application letter and supplemented by the licensee's responses to the NRC staff's requests for additional information. Enclosure 1 of the licensee's letter dated October 3, 2014 (Reference 15) contains the final version of the licensee's proposed plant-specific EAL scheme for VCSNS and is the final version reviewed by the NRC staff for

  • acceptability.

2.2 Guidance EAL development guidance was initially established via Generic Letter (GL) 79-50 (Reference 1) and was subsequently established in NUREG-0654/FEMA-REP-1 (Reference 2), which was endorsed as an approach acceptable to the NRC for the development of an EAL scheme via NRC Regulatory Guide (RG) 1.101, Revision 2 (Reference 8).

As industry and regulatory experience was gained with the implementation and use of EAL schemes, the industry issued revised EAL scheme development guidance to reflect lessons learned. To date, NUMARC/NESP-007 (Reference 3), NEI 99-01, Revision 4 (Reference 4) NEI 99-01, Revision 5 (Reference 5) and NEI 99-01, Revision 6 (Reference 6) have been provided to the NRC for review and endorsement as generic (i.e., non-plant-specific) EAL development guidance. NRC RG 1.101, Revisions 3 and 4 (Reference 8) .endorsed NUMARC/NESP-007 and NEI 99-01 Revision 4 as acceptable alternatives for licensees to consider in the development of

  • their plant-specific EAL schemes, as well as allowing for licensees to develop plant-specific EALs based upon an alternative approach not endorsed by the NRC. NEI 99-01, Revision 5 was endorsed by the NRC as acceptable generic (i.e., non-plant-specific) EAL Scheme development guidance via letter dated February 22, 2008 (Reference 9). NEI 99-01, Revision 6 was endorsed by the NRC as acceptable generic (i.e., non-plant-specific) EAL scheme development guidance via letter dated March 28, 2013 (Reference 7).

The EAL development guidance contained in GL 79-50, NUREG-0654/FEMA-REP-1, NUMARC/NESP-007, NEI 99-01, Revision 4, NEI 99-01, Revision 5, and NEI 99-01, Revision 6 are all considered generic EAL scheme development guidance, as they are not plant-specific and

  • may not be entirely applicable for some reactor designs. However, the guidance contained in these documents bounds the most typical accident/event scenarios for which emergency response is necessary, in a format that allows for industry standardization and co11sistent regulatory oversight. Most licensees choose to initially develop their plant-specific EAL schemes using the most recently endorsed EAL development guidance with appropriate plant-specific alterations as applicable. Pursuant to 10 CFR Part 50, Appendix E, Section IV.B.2, a later revision to an EAL must be approved by the NRC before implementation, if the licensee is changing from one EAL scheme to another EAL scheme.

In sum, the NRC staff considers the following methods acceptable for use in developing plant-specific EALs that meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), with the understanding that licensees may want to develop EALs that differ from the applicable guidance document as allowed in RG 1.101 and in the applicable endorsement letters:

  • Appendix 1, "Emergency Action Level Guidelines for Nuclear Power Plants," to NUREG~0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," dated November 1980 (Reference 2);
  • NUMARC/NESP-007, Revision 2, "Methodology for Development of Emergency Action Levels," dated January* 1992 (Reference 3);
  • NEI 99-01, Revision 4, "Methodology for Development of Emergency Action Levels," dated January 2003 (Reference 4);
  • NEI 99-01; Revision 5, "Methodology for Development of Emergency Action Levels," dated February 2008 (Reference 5); and
  • NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," dated Novem_ber 2012 (Reference 6).

NRC Regulatory Issue Summary (RIS) 2003-18, with Supplements 1 and 2, "Use of NEI 99-01,

'Methodology for Development of Emergency Action Levels"' (Reference 10), also provide guidance for developing or changing a standard emergency classification and action level scheme. In addition, this RIS and its supplements provide recommendations to assist licensees, consistent with Section IV. B of Appendix E to 10 CFR Part 50, in determining whether to seek prior NRC approval of deviations from the guidance.

Regardless of the generic EAL scheme development guidance document used by a licensee to develop its EAL scheme, or if a licensee chooses to develop its EAL scheme using an alternative approach not endorsed by the NRC, or a combination of the two (which is most typical), the NRC staff will review the EAL scheme to assure that it meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4).

3.0 TECHNICAL EVLAUATION In its application and supplemental letters, the licensee submitted its proposed EAL scheme, along with the technical basis, a comparison matrix, the EAL numbering scheme, and an explanation of any difference or deviation from NEI 99-01, Revision 6. The comparison matrix provided a cross- reference relating the proposed EAL scheme to the EAL scheme in NEI 99-01, Revision 6.

The licensee currently utilizes an EAL scheme based on previous guidance with plant-specific modifications due to design differences and/or licensee preference. The licensee is converting to an EAL scheme using the development guidance from NEI 99-01, Revision 6 (Reference 6) with plant-specific modifications due to design differences and/or licensee preference.

The proposed plant-specific EAL scheme is unique to the licensee; however, to ensure consistency and regulatory stability, the NRC staff reviewed the proposed plant-specific EAL scheme to ensure that the following key characteristics of an effective EAL scheme are in place:

  • Consistency (i.e., the EALs would lead to similar decisions under similar circumstances at different plants), up to and including standardization in intent, if not in actual wording;
  • Human factors 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 in Appendix 1 to NUREG-0654;
  • Technical completeness for each classification level;
  • Logical progression in classification for multiple events; and
  • The use of objective and observable values.

To aid in understanding the nomenclature used in this safety evaluation, for each category of EALs reviewed the following naming/numbering convention is used: the first letter signifies the category; the second letter signifies the classification level (G =General Emergency (GE), S =

Site Area Emergency (SAE), A= Alert, and U = Notification of Unusual Event (UE)); and the number is the applicable number from the plant-specific EAL scheme.

For ease of use, this safety evaluation will use the numbering system from the proposed plant-specific EAL scheme, however, the numbering system from the generic EAL scheme development guidance (Reference 6) shall be annotated in [brackets] to aid in cross-referencing the proposed site-specific EAL numbering convention with that of the guidance when the numbering is different.

3.1 Category 'R' - Abnormal Radiological Release/Radiological Effluent 3.1.1 EAL Set RG1/RS1/RA1/RU1 [AG1/AS1/AA1/AU1]

. This EAL set is based upon plant-specific indications of a release of radioactivity (gaseous and/or liquid). The NRC staff has determined that the progression from UE to .GE is appropriate and consistent with EAL scheme development guidance.

  • The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance, as well as using 'R' in lieu of 'A' to reference this category.

However, the NRC staff has determined that the numbering, sequencing, and format of this EAL set is consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is therefore considered part of a standard EAL scheme.

The instrumentation and set points derived for this EAL set are consistent with the overall EAL scheme development guidance, address the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of

.Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.1.2 EAL Set RG2/RS2/RA2/RU2 [AG2/AS2/AA2/AU2]

This EAL set is based upon plant-specific indications of fuel uncovery, including spent fuel stored in the spent fuel pool or refueling pathway. The NRG staff has determined that the progression from UE to GE is appropriate and consistent with EAL scheme development guidance. The SAE and GE classification levels for this specific accident progression are also bounded by indications available in the fission product barrier matrix, as well as in EALs RS1 and RG1.

The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance, as well as using 'R' in lieu of 'A' to reference this category.

However, the NRC staff has determined that the numbering, sequencing, and format of this EAL

set is consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is therefore consider~d part of a standard EAL scheme.

The instrumentation and set points derived for this EAL set are consistent with the overall EAL scheme development guidance, address the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff co.ncludes that the plant-specific implementation method. for this EAL set is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.1.3 EAL RA3 [AA3]

This EAL is not part of an EAL set within the overall EAL scheme. This EAL is based upon indications of a rise in plant radiation levels that impedes normal access to the Control Room (CR) and Central Alarm Station (CAS), as well as other areas where access may be needed during an event. This Alert EAL is primarily intended to ensure that the plant emergency response organization is activated to support the CR in removing the impediment to normal access.

Indications of increasing radiation levels in the plant are bounded by indication of fission product barrier loss or potential loss, as well as in RS1 and RG1.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance, as well as using 'R' in lieu of 'A' to reference this category.

However, the NRC staff has determined that the numbering, sequencing, and format of this EAL is consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is therefore considered part of a standard EAL scheme.

The NRC staff concludes that the plant-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.2 Category 'C' - Cold Shutdown/Refueling System Malfunction 3.2.1 EAL Set CG1/CS1/CA1/CU1 This EAL set is based upon a loss of reactor pressure vessel inventory and/or reactor coolant system (RCS) leakage. The NRC staff has determined that the progression from UE to GE is appropriate and consistent with EAL scheme development guidance.

The NRC staff has al.so determined that the numbering, sequencing, and format of this EAL set are consistent with the overall EAL scheme development guidance and with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The instrumentation and set points derived for this EAL set are consistent with the overall EAL scheme development guidance, address the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.2.2 EAL CA2/CU2 This EAL set is based upon a loss of available power to emergency power electrical busses. The NRC staff has determined that the progression from UE to Alert is appropriate and consistent with EAL scheme development guidance. The SAE and GE classification levels for this specific accident progression are bounded by indications available in.EALs RS1 and RG1.

The NRC staff has also determined that the numbering, sequencing, and format of this EAL set are consistent with the overall EAL scheme development guidance and with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The instrumentation and set points derived for this EAL set are consistent with the overall EAL scheme development guidance, address the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.2.3 EAL Set CA3/CU3 This EAL set is based upon an inability to maintain control of decay heat removal. The NRC staff

  • has determined that the progression from UE to Alert is appropriate and consistent with EAL scheme development guidance. The SAE and GE classification levels for this specific accident progression are bounded by indications available in EALs RS1 and RG1.

The NRC staff has also determined that the numbering, sequencing, and format of this EAL set are consistent with the overall EAL scheme development guidance and with the plant~specific .

implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). .

The instrumentation and set points derived for this EAL set are consistent with the overall EAL scheme development guidance, address the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of

Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.2.4 EAL CU4 This EAL is not part of an EAL set within the overall EAL scheme. The EAL's intent is to ensure that an EAL is declared when a loss of direct current (DC) power event occurs, as this condition compromises the ability of the licensee to monitor and control the removal of decay heat during Cold Shutdown or Refueling modes of operation. The Alert, SAE, and GE classification levels for this specific accident progression are bounded by indications available in EALs RA1, RS1, and RG1.

The NRC staff has determined that the numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance and with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The instrumentation and set points derived for this EAL are consistent with the overall EAL scheme development guidance, address the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.2.5 EAL CU5 This EAL is not part of an EAL set within the overall EAL scheme. The EAL's intent is to highlight the importance of emergency communications by ensuring that an EAL is declared if normal communication methods for onsite and offsite personnel, or for offsite response organizations including the NRC, are lost. The NRC staff has determined that no escalation path is necessary for this EAL.

The NRC staff has also determined that the numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance and with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The communication methods derived for this EAL are consistent with the overall EAL scheme development guidance, address the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.2.6 EAL CA6 This EAL is not part of an EAL set within the overall EAL scheme. The EAL's intent is to ensure that an EAL is declared when hazardous events lead to potential damage to safety systems. The SAE and GE classification levels for this accident progression are bounded by indications available in EALs CS1, RS1, and RG1.

The NRC staff has determined that the numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance and with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.3 Category 'E' - Independent Spent Fuel Storage Installation (ISFSI) 3.3.1 EAL EU1 This EAL is not part of an EAL set within the overall EAL scheme. The EAL's intent is limited to radiological events at the ISFSI. The NRC staff has determined that, while security-related events at the ISFSI are also of concern, they are bounded by the licensee's EAL HA 1.

The NRC staff has also determined that the numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance and with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.4 Category 'F' - Fission Product Barrier Matrix This category is unique in the overall EAL scheme, as the thresholds are not intended to be stand-alone indicators of a particular event occurring at the plant. Rather, they are to be used as triggers within the particular logic configuration needed to reflect a loss or potential loss of a fission product barrier. U.S. nuclear power plants have three fission product barriers: fuel cladding, the RCS, and the primary containment. Licensees are to develop thresholds that provide EAL decision-makers input into making an event declaration based upon degradation of one or more of these fission product barriers.

There are numerous triggers used as logic inputs to decide on the appropriate classification based upon the number of loss and/or potential loss indicators that are triggered for each barrier.

By design, these indicators are redundant with other similar indicators in the Category 'R' and Category 'S' EAL sets, due to the importance for licensees to be able to recognize reactor and/or

.fission product barrier events as timely as possible using the best available indicators from

  • several different perspectives.

The NRC staff verified that the logic used to determine the appropriate emergency classification is consistent with the generic EAL scheme development guidance.

The instrumentation and set points derived for this EAL 1category are consistent with the overall EAL scheme development guidance, address the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The licensee chose to modify this EAL category by using a plant-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. However, the NRC staff has determined that the numbering, sequencing, and format of this EAL category is consistent with the overall EAL scheme development guidance and with the plant-specific implementation strategies provided, and is therefore consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL category is in alignment with the key charact~ristics of an effective EAL scheme and, while different than that provided in the generic EAL development guidance, continues to meet the requirements of .

.Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.5 Category 'H' - Hazards 3.5.1 EAL Set HG1/HS1/HA1/HU1 This EAL set is based upon security-related events originally developed in accordance with the .

guidance from NRC Bulletin 2005-02 (Reference 11) or RIS 2006-12 (Reference 12) for licensees to implement regardless of the specific version of the generic EAL scheme development guidance used, or if the particular licensee developed its EAL scheme using an alternative approach.

Based upon lessons learned from the implementation and use of this EAL set, particularly the insights gained from combined security and emergency preparedness drills, the NRC staff and the industry worked to enhance the language of these EALs so as to eliminate any confusion without changing the intent of the EAL set as set forth in NRC Bulletin 2005-02 and RIS 2006-12.

The NRC staff has determined that the numbering, sequencing, and format of this EAL set are consistent with the overall EAL scheme development guidance and with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff has also determined that this EAL set is consistent with the guidance provided in NRC Bulletin 2005-02 and RIS 2006-12, as further enhanced by the lessons learned from implementation and drills, and revised in NEI 99-01, Revision 6 (Reference 6).

The NRC staff concludes that the plant-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.5.2 EAL HU2 This EAL is not part of an EAL set within the overall EAL scheme. This EAL is based upon the effect that a seismic event may have on the facility. The Alert, SAE, and GE classification levels for this specific accident progression are bounded by indications available in the fission product barrier matrix, as well as in EALs RA 1, RS 1, RG 1, CA6, and SA9.

The NRC staff has determined that the numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance and with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continLJes to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.5.3 EAL HU3 This EAL is not part of an EAL set within the overall EAL scheme. This EAL is based upon the effect that natural and destructive hazards may have on the facility. The Alert, SAE, and GE classification levels for this specific accident progression are bounded by indications available in the fission product barrier matrix, as well as in EALs RA1, RS1, RG1, CA6, and SA9.

The NRC staff has determined that the numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance and with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The instrumentation and set points derived for th[s EAL are consistent with the overall EAL scheme development guidance, address the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme and, while different than that provided in the generic EAL development guidance, continues to meet the requirements of Section IVofAppendix Eto 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.5.4 EAL HU4 This EAL is not part of an EAL set within the overall EAL scheme. This EAL is based upon the effect that fires may have on the facility. The Alert, SAE, and GE classification levels for this specific accident progression are bounded by indications available in the fission product barrier matrix, as well as in EALs RA1, RS1, RG1, CA6, and SA9.

The NRC staff has determined that the numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance and with the plant-specific

implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme and, while different than that provided in the* generic EAL development guidance, continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.5.5 EAL HAS This EAL is not part of an EAL set within the overall EAL scheme. This EAL is based upon the effect that toxic, corrosive, asphyxiant, or flammable gases may have on the facility. The SAE and GE classification levels for this specific accident progression are bounded by indications available in the fission product barrier matrix, as well as in EALs RS1 and RG1.

The NRC staff has determined that the numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance and with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme and, while different than that provided in the generic EAL development guidance, continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.5.6 EAL Set HS6/HA6 This EAL set is based upon CR evacuation and the inability to control critical plant systems remotely. The NRC staff has determined that the progression from Alert to SAE is appropriate and consistent with EAL scheme development guidance. The GE classification level for this specific accident progression is bounded by indications available in the fission product barrier matrix, as well as in EAL RG1.

The NRC staff has also determined that the numbering, sequencing, and format of this EAL set are consistent with the overall EAL scheme development guidance and with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.5.7 EAL Set HG7/HS7/HA7/HU7 This EAL set is based upon providing the decision-makers with EALs to consider when, in their judgment, an emergency classification is warranted.

The NRC staff has determined that the numbering, sequencing and format of this EAL set are consistent with the overall EAL scheme development guidance, are consistent with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme and, while different than that provided in the generic EAL development guidance, continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable

  • for implementation.

3.6 Category 'S'...:... System Malfunction 3.6.1 EAL Set SG1/SS1/SA1/SU1 [SG8]

Thi.s EAL set is based upon a loss of available alternating current (AC) power sources to the emergency busses. The NRC staff has determined that the progression from UE to GE is appropriate and consistent with EAL scheme development guidance. The licensee also chose to incorporate EAL SG8 (Reference 6) into the site-specific EAL SG1.

The NRC staff has also determined thafthe numbering, sequencing, and format of this EAL set are consistent with the overall EAL scheme development guidance and with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The instrumentation, values, and listing of applicable power sources derived for this EAL set are consistent with the overall EAL scheme development guidance, address the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation .method for this EAL set is in

  • alignment with the key characteristics of an effective EAL scheme, meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.6.2 EAL SS2 [SS8]

This EAL is not part of an EAL set within the overall EAL scheme. The EAL's intent is to ensure that an EAL is declared when a loss of DC power event occurs, as this condition compromises the  !

ability of the licensee to monitor and control the removal of decay heat. The GE classification level for this event is bounded by indications available in the fission product barrier matrix, as well as in EALs RG1 and SG1.

The NRC staff has determined that the numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance, are consistent with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.6.3 EAL Set SA3/SU3 [SA2/SU2]

This EAL set is based upon the effect that a loss of available indicators in the CR has on the facility. The NRC staff h_as determined that the progression from UE to Alert is appropriate and consistent with EAL scheme development guidance. The SAE and GE classification levels for this specific accident progression are bounded by indications available in the fission product barrier matrix, as well as in EALs RS1 and RG1.

The NRC staff has also determined that the numbering, sequencing, and format of this EAL set are consistent with the overall EAL scheme development guidance and with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The instrumentation and set points derived for this EAL set are consistent with the overall EAL scheme development guidance, address the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.6.4 EAL SU4 [SU3]

This EAL is not part of an EAL set within the overall EAL scheme. The EAL's intent is to ensure that an EAL is declared when the plant has indications of fuel clad degradation. By design, this EAL is redundant with corresponding indicators from a loss or potential loss of fission product barriers, as well as radiation monitoring, to ensure that reactor and/or ffssion product barrier events are recognized regardless of the particular EAL table a licensee may be referring to. EAL escalation is bounded by indications available in the fission product barrier matrix, as well as in EALs RA1, RS1, and RG1.

The NRC staff has determined that the numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance, are consistent with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.6.5 EAL SU5 [SU4]

This EAL is not part of an EAL set within the overall EAL scheme. The EAL's intent is to ensure*

that an EAL is declared when the plant has indications of RCS leakage. By design, this EAL is redundant with corresponding indicators from a loss or potential loss of fission product barriers, as well as radiation monitoring, to ensure reactor and/or fission product barrier events are recognized regardless of the particular EAL table a licensee may be referring to. EAL escalation is bounded by indications available in the fission product barrier matrix, as well as in EALs RA 1, RS1, and RG1.

The NRC staff has determined that the numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance, are consistent with the plant-specific implementation strategies provided, and are consistent with a sta'ndard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.6.6 EAL Set SS6/SA6/SU6 [SS5/SA5/SU5]

This EAL set is based upon the effect that a failure of the reactor protection system may have on the plant. The NRC staff has determined that the progression from UE to SAE is appropriate and consistent with EAL scheme development guidance. The GE classification level for this event is bounded by indications available in the fission product barrier matrix, as well as in EAL RG1.

The NRC staff has also determined that the numbering, sequencing, and format of this EAL set are consistent with the overall EAL scheme development guidance and with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The instrumentation and set points derived for this EAL set are consistent with the overall EAL scheme development guidance, address the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme and, while different than that provided in the generic EAL development guidance, continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.6. 7 EAL SU? [SU6]

This EAL is not part of an EAL set within the overall EAL scheme. The EAL's intent is to highlight the importance of emergency communications by ensuring that an EAL is declared if normal communication methods for onsite and offsite personnel, or for offsite response organizations including the NRC, are lost. The NRC staff has determined that no escalation path is necessary.

The NRC staff has also determined that the numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance and with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The communication methods derived for this EAL are consistent with the overall EAL scheme development guidance, address the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme; meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.6.8 EAL SU8 [SU?]

This EAL is not part of an EAL set within the overall EAL scheme. The EAL's intent is to ensure that an EAL is declared when the plant has indications of containment barrier degradation~ By design, this EAL is redundant with corresponding indicators from a loss or potential loss of fission product barriers, as well as radiation monitoring, to ensure reactor and/or fission product barrier events are recognized regardless of the particular EAL table a licensee may be referring to. EAL escalation is bounded by indications available in the fission product barrier matrix, as well as in EALs RA1, RS1, and RG1.

The NRC staff has determined that the numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance, are consistent with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of Section IVof Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.6.9 EAL SA9 This EAL is not part of an EAL set within the overall EAL. The EAL's intent is to ensure that an EAL is declared when hazardous events lead to potential damage to safety systems. The SAE and GE classification levels for this accident progression are bounded by indications available in the fission product barrier matrix, as well as in EALs RS1 and RG1.

The NRC staff has determined that the numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance and with the plant-specific implementation strategies provided, and are consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).

The NRC staff concludes that the plant-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, meets the requirements of

Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and is therefore acceptable for implementation.

3.7 Summary The NRC staff has reviewed the technical bases for the proposed EAL scheme, the modifications from NEI 99-01, Revision 6, and the licensee's evaluation of the proposed changes. The licensee chose to modify its proposed EAL scheme from the generic EAL scheme development guidance provided in NEI 99-01, Revision 6, in order to adopt a format that is better aligned with how it currently implements its EALs, as well as with plant-specific writer's guides and preferences. The NRC staff determined that these modifications do not alter the intent of any specific EAL within an EAL set, EAL category, or within the entire EAL scheme as stated in NEI 99-01, Revision 6 (Reference 6).

Based on its review, the NRC staff has determined that the proposed EAL scheme uses objective and observable values, is worded in a manner that addresses human factors engineering and user friendliness concerns, follows logical progressions for escalating events, and allows for event downgrading and upgrading based upon the potential risk to the public health and safety.

Risk assessments were appropriately used to set the boundaries of the emergency classification levels and ensure that all EALs that trigger an emergency classification are in the same range of relative risk. In addition, the NRC staff has determined that the proposed EAL scheme is technically complete and consistent with EAL schemes implemented at similarly designed plants.

3.8 Conclusion Based on the above, the NRC staff has determined that the proposed changes meet the requirements in Appendix E to 10 CFR Part 50 and the planning standards of 10 CFR 50.47(b).

Therefore, the NRC staff concludes that the proposed EAL scheme, as stated in Enclosure 1 of the licensee's letter dated October 3, 2014 (Reference 14) and provided as a stand-alone document (Reference 15), is acceptable and provides reasonable assurance that the licensee can and will take adequate protective measures in the event of a radiological emergency.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the South Carolina State official was notified of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding published iri the Federal Register on June 6, 2014 (79 FR 32771 ). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection

with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, t.hat: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. Generic Letter 79-50 dated October 10, 1979 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML031320278).
2. U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," NUREG-0654/FEMA-REP-1, Revision 1, November 1980 (ADAMS Accession No. ML040420012).
3. Nuclear Management and Resources Council/National Environmental Studies Project (NUMARC/NESP) - 007, Revision 2, "Methodology for Development of Emergency Action Levels," January 1992 (ADAMS Accession No. ML041120174).
4. NEI 99-01, Revision 4, "Methodology for Development of Emergency Action Levels,"

January 2003 (ADAMS Accession-No. ML041470143).

5. NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels,"

February 2008 (ADAMS Accession No. ML080450149).

6. NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," November 2012 (ADAMS Accession No. ML13091A209 [package]).
7. Thaggard, M., U.S. Nuclear Regulatory Commission, Letter to Ms. Perkins-Grew, Nuclear Energy Institute, "U.S. Nuclear Regulatory Commission Review and Endorsement of NEl-99-01, Revision 6, dated November, 2012," March 28, 2013 (ADAMS Accession No. ML12346A463).
8. U.S. Nuclear Regulatory Commission, "Emergency Planning and Preparedness for Nuclear Power Reactors," Regulatory Guide 1.101, Revision 2, October 1981 (ADAMS Accession No. ML090440294), Revision 3, August 1992 (ADAMS Accession No. ML003740302), and Revision 4, July 2003 (ADAMS Accession No.

M L032020276).

9. Miller, C. G., U.S. Nuclear Regulatory Commission, Letter to Alan Nelson, Nuclear Energy Institute, "U.S. Nuclear Regulatory Commission Review and Endorsement of NEl-99-01, Revision 5, dated February 2008," February 22, 2008 (ADAMS Accession No. ML080430535).
10. U.S. Nuclear Regulatory Commission, Regulatory Issue Summary 2003-18, with Supplements 1 and 2, "Use of NEl-99-01, 'Methodology for Development of Emergency Action Levels,' Revision 4, dated January 2003, October 8, 2003 (ADAMS Accession Nos. ML032580518, ML041550395, and ML051450482).
11. NRC Bulletin 2005-02, "Emergency Preparedness and Response Actions for Security-Based Events, July 18, 2005 (ADAMS Accession No. ML051740058).
12. NRC Regulatory Issue Summary 2006-12, "Endorsement of Nuclear Energy Institute Guidance 'Enhancements to Emergency Preparedness Programs for Hostile Action,'"

July 19, 2006 (ADAMS Accession No. ML072670421).

13. Letter from SCE&.G to U.S. Nuclear Regulatory Commission, "Request for NRC Approval of Proposed Changes to Emergency Action Levels, April 7, 2014 (ADAMS Accession No. ML14122A144 [package]).
14. Letter from SCE&G to U.S. Nuclear Regulatory Commission, "Request for NRC Approval of Proposed Changes to Emergency Action Levels; Response to Request for Additional Information, October 3, 2014 (ADAMS Accession No. ML14288A391

[package]).

15. EPP-108, Enclosure 1, "Emergency Action Level Technical Bases, Revision 1 (ADAMS Accession No. ML14288A383).
16. Letter from SCE&G to U.S. Nuclear Regulatory Commission, "Request for NRC Approval of Proposed Changes to Emergency Action Levels; Supplemental Information, March 18, 2015 (ADAMS Accession No. ML15082A387).

Principal Contributors:

Don Johnson, NSIR/DPR/ORLOB Date: April 13, 2015

April 13, 2015 Mr. Thomas D. Gatlin

  • Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 800 Jenkinsville, SC 29065 .

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 - ISSUANCE OF AMENDMENT TO REVISE EMERGENCY ACTION LEVELS TO A SCHEME BASED ON NEI 99-01, REVISION 6 (TAC NO. MF3927)

Dear Mr. Gatlin:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 200 to Renewed Facility Operating License No. NPF-12 for the Virgil C. Summer Nuclear Station, Unit 1 (VCSNS), in response to your letter dated April 7, 2014, as supplemented by letters dated October 3, 2014, and March 18, 2015. This amendment approves a revision to the emergency action levels from a scheme based on NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels" to a scheme based on NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors."

A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissio.n's biweekly Federal Register notice.

Sincerely,

/RA/

Shawn Williams, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosures:

1. Amendment No. 200 to NPF-12
2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

Public LPL2-1 R/F RidsNrrDssStsb Resource RidsNrrPMSummer Resource RidsAcrs_AcnwMailCTR Resource RidsNrrLASFigueroa Resource RidsNrrDraApla Resource RidsNrrDorlDpr Resource RidsRgn2MailCenter Resource DJohnson, NSIR ADAMS A ccess1on No.: ML15063A355 *B1y memo dated 03/18/15 OFFICE NRR/LPL2-1 /PM NRR/LPL2-1/LA NSIR/DPR/ORLOB NAME SWilliams SFiqueroa JAnderson*

DATE 03/23/15 03/19/15 03/18/15 OFFICE OGCINLO NRR/LPL2-1 /BC NRR/LPL2-1/PM NAME JWachutka RPascarelli SWilliams DATE 03/25/15 04/08/15 04/13/15 OFFICIAL RECORD COPY

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