ML15238A357
| ML15238A357 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, Catawba, McGuire  |
| Issue date: | 12/20/1996 |
| From: | Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Tuckman M DUKE POWER CO. |
| References | |
| NUDOCS 9701140244 | |
| Download: ML15238A357 (9) | |
Text
December 20, 1996 Duke Power Company ATTN: Mr. M. S. Tuckman Senior Vice President Nuclear Generation P. 0. Box 1006 Charlotte, NC 28201-1006
SUBJECT:
CAPABILITY FOR ON-SHIFT DOSE ASSESSMENT AT CATAWBA, MCGUIRE, AND OCONEE NUCLEAR SITES
Dear Mr. Tuckman:
As you may know, the NRC has recently reaffirmed that nuclear power plant licensees are required to maintain an on-shift capability to assess the potential dose to the public from radiological releases that may occur during the course of an accident. On July 14, 1996, a letter to the Union Electric Company from the NRC's Office of Nuclear Reactor Regulation imposed a compliance backfit upon the Callaway Plant's emergency preparedness program.
This backfit specified restoration of the Callaway Plant's capability to perform on-shift dose assessment in response to accident conditions. In a letter to the NRC dated September 13, 1996, the Union Electric Company agreed to reestablish a capability to perform on-shift dose assessment and to modify its Emergency Plan accordingly.
Based upon our review of the Emergency Plans for your Catawba, McGuire, and Oconee facilities, we believe that those plans are not in compliance with 10 CFR Part 50 Appendix E.IV.B. We request that you assess the status of your Emergency Plan commitments for your Catawba, McGuire, and Oconee facilities in this regard, and inform us, within 30 days of the date of this letter, of any measures you may be considering with respect to the resolution of this issue.
Should you have any questions regarding this request, please contact Mr. James Kreh of my staff on 404-331-2604.
Sincerely, (Original signed by A. F. Gibson)
Albert F. Gibson, Director Division of Reactor Safety Docket Nos. 50-269, 50-270, 50-287, 50-369, 50-370, 50-413, and 50-414 License Nos. NPF-9, NPF-17, NPF-35, NPF-52, DPR-38, DPR-47, and DRP-55
Enclosure:
Ltr. 07/24/96 J. W. Roe, NRC to D. Schnell, Union Electric Co.
cc: (See page 2) 140084 9701140244 961220 PDR ADOCK 05000269 F
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cc w/encl:
Richard P. Wilson, Esq.
Mr. W. R. McCollum Assistant Attorney General Site Vice President S. C. Attorney General's Catawba Site Office 4800 Concord Road P. 0. Box 11549 York, SC 29745-9635 Columbia, SC 29211 M. S. Kitlan Michael Hirsch Regulatory Compliance Manager Federal Emergency Mgmt. Agency Duke Power Company 500 C Street, Sw, Room 840 4800 Concord Road Washington, D. C. 20472 York, SC 29745-9635 North Carolina Electric Robert P. Gruber Membership Corporation Executive Director P. 0. Box 27306 Public Staff - NCUC Raleigh, NC 27611 P. 0. Box 29520 Raleigh, NC 27626-0520 Karen E. Long Assistant Attorney General Paul R. Newton N. C. Department of Justice Legal Department (PB05E)
P. 0. Box 629 Duke Power Company Raleigh, NC 27602 422 South Church Street Charlotte, NC 28242-0001 Saluda River Electric Cooperative, Inc.
J. M. McGarry, III, Esq.
P. 0. Box 929 Winston and Strawn Laurens, SC 29360 1400 L Street, NW Washington, D. C. 20005 Peter R. Harden IV Account Sales Manager North Carolina MPA-1 Power Systems Field Sales Suite 600 Westinghouse Electric Corporation P. 0. Box 29513 P. 0. Box 7288 Raleigh, NC 27626-0513 Charlotte, NC 28241 Max Batavia, Chief County Manager of York County Bureau of Radiological Health York County Courthouse S. C. Department of Health York, SC 29745 and Environmental Control 2600 Bull Street Piedmont Municipal Power Agency Columbia, SC 29201 121 Village Drive Greer, SC 29651 cc w/encl cont'd: (See page 3)
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cc w/encl:
Karen E. Long G. A. Copp Assistant Attorney General Licensing - ECO50 N. C. Department of Justice Duke Power Company P. 0. Box 629 P. 0. Box 1007 Raleigh, NC 27602 Charlotte, NC 28201-1007 Mr. J. W. Hampton T. Richard Puryear Vice President Owners Group Oconee Site North Carolina Electric P. 0. Box 1439 Membership Corporation Seneca, SC 29679 4800 Concord Road York, SC 29745 Mr. J. E. Burchfield Compliance Mr. T. C. McMeekin Duke Power Company Vice President P. 0. Box 1439 McGuire Site Seneca, SC 29679 12700 Hagers Ferry Road Huntersville, NC 28078-8985 Mr. Robert B. Borsum Babcock and Wilcox Company James Snyder Nuclear Power Generation Division Regulatory Compliance 1700 Rockville Pike, Suite 525 Duke Power Company Rockville, MD 20852 12700 Hagers Ferry Road Huntersville, NC 28078-8985 County Supervisor of Oconee County Dayne H. Brown, Director Walhalla, SC 29621 Division of Radiation Protection Manager, LIS N. C. Department of NUS Corporation Environment, 2650 McCormick Drive Health & Natural Resources Clearwater, FL 34619-1035 P. 0. Box 27687 Raleigh, NC 27611-7687 County Manager of Mecklenburg County 720 East Fourth Street Charlotte, NC 28202 Dr. John M. Barry, Director Mecklenburg County Department of Environmental Protection 700 North Tryon Street Charlotte, NC 28203
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Distribution:
P. Tam, NRR V. Nerses, NRR D. LaBarge, NRR R. V. Crienjak, RII S. Rudisail, RII R. Carroll, RII N. Economos, RII G. A. Hallstrom, RII PUBLIC NRC Resident Inspector U.S. Nuclear Regulatory Comm.
4830 Concord Road York, SC 29745 NRC Resident Inspector U.S. Nuclear Regulatory Commission 12700 Hagers Ferry Road Huntersville, NC 28078-8985 NRC Resident Inspector U.S. Nuclear Regulatory Commission 78128 Rochester Highway Seneca, SC 29672 qC2 OFFICE RilDRS
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SIGNATURE NAME (K
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OFFICIAL RECORD CCP DMENT NAME: G:\\DCUMENT\\DOSEASMT.DPC,
Ame UNITED STATES NUCLEAR REGULATORY COMMISSION REGMON II 101 MARIETTA STREET, N.W., SUITE 200 ATLANTA, GEORGIA 302H199 July 24, 1996 Mr. Donald Schnell Senior Vice President - Nuclear Union Electric Company Post Office Box 149 St. Louis, Missouri 63166
SUBJECT:
COMPLIANCE BACKFIT TO MEET THE REGULATORY REQUIREMENT TO MAINTAIN THE CAPABILITY TO PERFORM ON-SHIFT DOSE ASSESSMENT - UNION ELECTRIC COMPANY, CALLAWAY PLANT, UNIT 1 (TAC NO. M93731)
Dear Mr. Schnell:
In March 1995, the NRC approved a change to the Callaway Plant Emergency Plan to remove the requirement for Union Electric Company to maintain the capability to perform on-shift dose assessments. As discussed with your staff during a teleconference on January 24, 1996, the regulations require licensees to maintain the capability on-shift to perform dose assessments in response to accident conditions. Therefore, this change conflicted with the applicable regulations. The enclosed evaluation provides the basis for the staff's resolution of this issue.
You are requested to respond to this letter in writing within 60 calendar days of the date of this letter by describing the actions that you plan to take to ensure compliance with NRC regulatory requirements. Please specify the date by which full compliance will be achieved.
Should you decide to appeal the staff's resolution, you must do so within 60 calendar days of the date of this letter. Appeals should be addressed to the Director of the Office of Nuclear Reactor Regulation with a copy to the Executive Director of Operations.
If you have any questions, please contact me at (301) 415-1354.
Sincerely, Original signed by:
Jack W. Roe, Director Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-483
Enclosure:
Evaluation cc w/encl:
See next page Enclosure
Enclosure UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483 EVALUATION OF THE BASIS FOR COMPLIANCE BACKFIT TO ESTABLISH ON-SHIFT DOSE ASSESSMENT CAPABILITY INTRODUCTION This evaluation describes the NRC staff's basis for determining that, to comply with regulations in 10 CFR Part 50, Union Electric must modify the Callaway Plant emergency preparedness (EP) program to establish on-shift dose assessment capability. This evaluation is conducted in accordance with guidance provided in NRR Office Letter Number 901, Revision 1, "Procedures for Managing Plant-Specific Backfits and 10 CFR 50.54(f) Information Requests."
Immediate imposition of the backfit was determined not to be necessary since the licensee has other diverse methods available to protect the health and safety of the public in the event of a radiological release.
BACKGROUND In a letter dated October 8, 1993, the NRC issued a notice of violation to the licensee for Callaway Plant for (1) failure of the Radiological Release Information System (RRIS) to provide accurate offsite dose projections, (2) failure to provide adequate training to dose assessment personnel, and (3) failure to correct identified deficiencies in dose assessment training.
As part of its corrective actions, the licensee stated the following:
A task team was established to define a course of action to correct problems identified with the RRIS. While the team was reviewing options, it became clear that initial protective action recommendations (PARs) should be based directly on predefined plant parameters rather than dose calculations performed while an emergency is in progress.
This change will require a revision to the Radiological Emergency Response Plan prior to implementation. The revision will specify the following approach to developing Protective Action Recommendations:
an Emergency Implementing Procedure will be used by the On-Shift Emergency Response Organization to determine the appropriate PARs. The PARs will be based on the degree of core damage and loss of fission product barriers. We will not require performance of dose calculations by the On-Shift Emergency Response Organization. Once the Onsite and EOF [emergency operations facility] Emergency Response Organizations have been mobilized, dose assessment personnel will quantify the dose to the general public based on effluent monitors..." [letter dated July 13, 1994, to the NRC].
-2 In a letter dated March 30, 1995, NRC Region III informed the licensee that the revision to the Emergency Plan eliminating the requirement to perform dose calculations by the On-Shift Emergency Response Organization was acceptable.
The Office of Nuclear Reactor Regulation became aware of the approval of this change in June of 1995 when the licensee for Comanche Peak Power Plant informed NRC Region IV of its intent to remove the capability to perform on shift dose assessments. NRR, in coordination with NRC Region IV, informed the licensee for Comanche Peak that Appendix E to 10 CFR Part 50 required licensee Emergency Plans to describe "the means to be used for determining the magnitude of and for continually assessing the impact of the release of radioactive materials."
In addition, the licensee was informed of NRR's position that a dose assessment using real-time meteorology was needed to assess the impact of the release of radioactive materials. Following this discussion, the licensee for Comanche Peak decided not to pursue eliminating the capability for performing on-shift dose assessments. On November 16, 1995, NRR finalized its position on onsite dose assessment capability, citing the applicable regulations. The staff's position was distributed to the NRC regional inspectors to ensure consistent and accurate inspections.
In a teleconference held January 24, 1996, NRR informed the licensee for the Callaway plant that the NRC was reevaluating the licensee emergency plan change and that the plan change did not appear to meet the requirements in Appendix E to 10 CFR Part 50 regarding the need to be able to continually assess the impact of release of radioactive materials. The licensee responded that this regulation was being met by "describing plant conditions to define protective action recommendations to state officials" [letter dated February 21, 1996 to the NRC].
Although the NRC recognizes that emergency classifications and initial protective action recommendations should be based upon plant conditions, dose assessment based upon real-time meteorology is needed to confirm, in a timely manner, the adequacy of initial protective actions recommendations, to classify events which may not be adequately assessed under plant-condition-based emergency action levels, and to evaluate offsite consequences of nonsevere accident events involving a release of radioactive materials. Under the licensee's existing emergency plan, these functions could not be performed until its emergency response organizations are staffed -- which may take on the order of 60 to 75 minutes to accomplish.
After consultation with the Office of General Counsel and the Office of Enforcement, it was concluded on May 28, 1996, that a compliance backfit was appropriate.
OBJECTIVE OF AND REASON FOR THE MODIFICATION The objective of the modification to the Callaway Plant EP program is to establish the capability to perform on-shift dose assessments in case of an accidental release of radioactive material.
On-shift dose assessment capability is needed to support emergency response efforts during accident situations involving actual or potential releases of radioactive material.
The results are used to classify events, evaluate offsite consequences of nonsevere accident events involving a release of radioactive materials, and
-3 refine default protective action recommendations (PARs) for severe accident events.
The licensee for the Callaway Plant currently relies on the degree of core damage and loss of fission product barriers to develop PARs before activating the Technical Support Center. The licensee does not use real-time meteorological information to continually assess the impact of the release of radioactive materials and therefore cannot classify events based on onsite and offsite dose assessments and cannot refine default PARs during the initial phase of an accident.
BASIS FOR ISSUING BACKFIT A backfit is needed to bring the licensee for the Callaway Plant into compliance with 10 CFR Part 50.
Several regulations in 10 CFR Part 50 concern the requirement for emergency plans to specify the means by which the licensee will be able to assess, at all times, the impact of the release of radioactive materials.
Onshift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times....
Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
10 CFR Part 50, Appendix E.IV.B
[The.E Plan shall contain.. information about] the means to be used for determining the magnitude of and for continually assessing the impact of the release of radioactive materials....The emergency action levels shall be based on in plant conditions and instrumentation in addition to onsite and offsite monitoring.
Regional inspectors evaluate licensees' compliance with these requirements, using Inspection Procedure (IP) 82207, "Dose Calculation and Assessment."
The procedure contains the following guidance:
03.04 Dose Assessment Dose assessment is required by 10 CFR 50.47(b)(9),
Part IV of 10 CFR Part 50, Appendix E, and guidance criteria in NUREG-0654,Section I entitled "Accident Assessment," and Appendix 2 entitled "Meteorological Criteria for Emergency Preparedness at Operating
-4 Nuclear Power Plants."
The licensee should be able to perform dose assessments for accident conditions. Dose assessment tasks should not significantly distract shift management from assuring proper event response, classification, and reporting.
03.05 Training and Organization:
By holding discussions with personnel performing dose assessment, the inspector should verify that...
- a.
There are persons on every shift who can operate required systems and get results in a timely fashion.
The Emergency Preparedness and Radiological Protection Branch of the Office of Nuclear Reactor Regulation evaluated these regulations and inspection guidance and concluded that the regulations require licensees to maintain the capability on-shift to perform dose assessment using effluent release information and real-time meteorology in response to accident conditions.
The Office of the General Counsel has reviewed this conclusion and has no legal objection to it.
CONCLUSION Modification of the EP program for the Callaway Plant to establish on-shift dose assessment capability is needed for the licensee to comply with regulations in 10 CFR Part 50.