ML16209A054

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Independent Spent Fuel Storage Installation, Nine Mile Point, Units 1 and 2, R.E. Ginna, Nuclear Radiological Emergency Plan Annex Revisions
ML16209A054
Person / Time
Site: Calvert Cliffs, Nine Mile Point, Ginna, 07201036  Constellation icon.png
Issue date: 07/14/2016
From: David Gudger
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
Download: ML16209A054 (11)
v • d • e


Text

10 CFR 50.4 10 CFR 72.44(f)

July 14, 2016 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Calvert Cliffs Independent Spent Fuel Storage Installation Materials License No. SNM-2505 NRC Docket No. 72-8 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRC Docket Nos. 50-220, 50-410, and 72-1036 R.E. Ginna Nuclear Power Station Renewed Facility Operating License No. DPR-18 NRC Docket Nos. 50-244 and 72-67

Subject:

Exelon Nuclear Radiological Emergency Plan Annex Revisions In accordance with 10 CFR 50.4(b)(5), "Emergency Plan and related submissions," Exelon Generation Company, LLC (EGC) is submitting the Emergency Plan Annex revisions identified in the table below for Calvert Cliffs Nuclear Power Plants (Calvert Cliffs), Nine Mile Point Nuclear Station (NMP), and R.E. Ginna Nuclear Power Station (Ginna).

Procedure No. Revision Title.

I I Exelon Nuclear Radiological Emergency Plan EP-AA-1011 1 Annex for Calvert Cliffs Station Exelon Nuclear Radiological Emergency Plan EP-AA-1012 3 Annex for Ginna Station Exelon Nuclear Radiological Emergency Plan EP-AA-1013 2 Annex for Nine Mile Point Station The changes to the Emergency Plan Annexes were evaluated under the requirements of 10 CFR 50.54(q) and were determined not to result in a reduction in the effectiveness of the Emergency Plans for Calvert Cliffs, NMP, and Ginna. This notification is being submitted within 30 days of implementation of the changes as required by 10 CFR 50, Appendix E.

The changes continue to meet the applicable planning standards established in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.

U.S. Nuclear Regulatory Commission Emergency Plan Annex Revisions July 14, 2016 Page 2 In addition, as required by 10 CFR 50.54(q)(5), this submittal includes a summary analysis of the changes to the Emergency Plan Annexes (Attachment 1) for the cited plants.

This submittal also satisfies the reporting requirements associated with 10 CFR 72.44(f), which stipulates that within six months after any change is made to the Emergency Plan, the licensee shall submit a report containing a description of the changes to the Director, Division of Spent Fuel Storage and Transportation.

A copy of the revised procedure and supporting change summary analysis are included in the attachments to this letter.

There are no regulatory commitments in this submittal.

If you have any questions or require additional information, please contact Richard Gropp at (610) 765-5557.

Respectfully, Jc~tJ

/.

David T. Gudger Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. 10 CFR 50.54(q)(5) Procedure Change Summary Analysis
2. EP~AA-1O11, Revision 1, "Exelon Nuclear Radiological Emergency Plan Annex for Calvert Cliffs Station"
3. EP-AA-1012, Revision 3, "Exelon Nuclear Radiological Emergency Plan Annex for Ginna Station"
4. EP-AA-1013, Revision 2, "Exelon Nuclear Radiological Emergency Plan Annex for Nine Mile Point Station" cc: w/ Attachment 1 only Regional Administrator - NRC Region I Director, NRC Division of Spent Fuel Storage and Transportation, ONMSS NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Station NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Senior Resident Inspector - R.E. Ginna Nuclear Power Station NRC Project Manager, NRR - Calvert Cliffs Nuclear Power Station NRC Project Manager, NRR - Nine Mile Point Nuclear Station NRC Project Manager, NRR - R. E. Ginna Nuclear Power Station S. T. Gray, State of Maryland A. L. Peterson, NYSERDA

ATTACHMENT 1 10 CFR 50.54(q)(5) Procedure Change Summary Analysis Page 1 of 8 10 CFR 50.54(g)(5) Procedure Change Summary Analysis Proceduresffitles Exelon Generation Company, LLC (EGC) is submitting the following Emergency Plan Annex revisions for Calvert Cliffs Nuclear Power Station (Calvert Cliffs), Nine Mile Point Nuclear Station (NMP) and the R.E. Ginna Nuclear Power Station (Ginna):

  • EP-AA-1013, Revision 2, "Exelon Nuclear Radiological Emergency Plan Annex for Nine Mile Point Station" Description of Procedures These documents are the Emergency Plan Station Annexes for the cited plants.

Discussion of Changes

1. Training Frequency Revision (Calvert Cliffs, Ginna, and Nine Point)

Description of Changes By letter dated July 29, 2015, Exelon submitted a License Amendment (LAR) pursuant to 10 CFR 50.90 to define the annual training frequency for Exelon ERO personnel for the facilities noted below as "once per calendar year not to exceed 18 months between training sessions."

,. Calvert Cliffs

  • Nine Mile Point
  • R.E. Ginna Subsequently, by letter dated March 17, 2016, the NRC approved the LAR (reference ML15352A164).

Planning Standard 10 CFR 50.47(b)(15) specifies that Radiological Emergency Response Organization (ERO) training is provided to those who may be called on to assist in an emergency. This is further expanded in regulatory guidance provided in NUREG-0654, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," which specifies that organizations shall establish specialized initial and periodic retraining programs for those who may be called on to assist in an emergency.

The proposed changes would revise the description of Emergency Response Organization (ERO) requalification training frequency defined in the station Emergency Plans listed above. The proposed frequency will be defined as "once per calendar year not to exceed 18

Attachment 1 Page 2 of 8 months between training sessions." In this context, training session refers to the annual requalification training received by the ERO.

Description of How the Change Still Complies with Regulations The revision to the ERO training frequency for the noted stations was approved by the NRG as documented in a letter and supporting Safety Evaluation Report (SER) dated March 17, 2016. The NRG approved the training frequency where annual training is defined as "is defined as once per calendar year not to exceed 18 months between training sessions. "

Description of Why the Change is Not a Reduction in Effectiveness (RIE)

This is a conforming change to an NRG-approved and supporting SER. Further evaluation under the 10 CFR 50.54(q) process is not required based on the guidance specified in Regulatory Guide (RG) 1.219, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors," Section 5.1.a.

2. On-Shift Staffing Requirements (Calvert Cliffs)

Description of Changes A change is being made to Figure 2-1, "Minimum On-Shift Staffing Requirements," to reflect the number of persons required to support the Fire Brigade. This is an enhancement to allow the Figure to provide a comprehensive view of the required on-shift staff. The actual number of persons on the Calvert Cliffs Fire Brigade has not changed as a result of this revision. Note that the number of Fire Brigade members is evaluated under 1o CFR 50, Appendix R, and not under 10 CFR 50.54(q).

Description of How the Change Still Complies with Regulations The Calvert Cliffs Emergency Plan Annex Figure 2-1, "Minimum On-Site Staffing Requirements" table is being revised to reflect the actual Fire Brigade compliment required on shift. The actual Fire Brigade requirements for Calvert Cliffs are found in Updated Final Safety Analysis Report () Section 9.9:5, which states:

9.9.5 FIRE BRIGADE; COMPOSITION, RESPONSIBILITY, AND TRAINING Calvert Cliffs Nuclear Power Plant has a designated fire brigade of at least five members available on each shift. Members of the fire brigade do not include the minimum operations shift crew necessary for safe shutdown of both units. The fire brigade is trained and equipped to respond to fire-related emergencies at CCNPP. A mutual aid agreement has been established with off-site fire departments to provide assistance to the plant fire brigade on an as-needed basis.

The on-shift fire brigade wilf be staffed with a fire brigade leader and at least two fire brigade members that have sufficient training and knowledge of nuclear safety systems to understand the effects of fire and fire suppression on nuclear safety performance

  • criteria. The sufficient training and knowledge is permitted to be provided by an Operations Technical Advisor dedicated to respond with the fire brigade.

Page 3 of 8 A note (f) has been added to Figure 2-1 to explain the role of the Operations Advisor on the Fire Brigade and that an extra person may be required on shift if the Fire Brigade does not have sufficient nuclear safety system training and knowledge.

Description of Why the Change is Not a Reduction in Effectiveness (RIE)

This is considered an editorial change to the table in that the actual Fire Brigade requirements are determined and evaluated under 10 CFR 50, Appendix R and the site UFSAR. The number is placed in the Emergency Plan as an enhancement to allow reviewers to identify the total on-shift compliment on one (1) table. Changes to the Fire Brigade compliment will continue to be made in accordance with 10 CFR 50, Appendix R and not 10 CFR 50.54(q).

3. Manual Dose Assessment (Ginna)

Description of Changes A change is being made to the Ginna Emergency Plan Annex to remove reference to the manual method to perform dose assessment. The manual method was Ginna's original means of assessing projected doses resulting from accident conditions. Subsequently, more sophisticated versions of Dose Assessment software were developed and added to the Emergency Plan; however, the description of the manual method was retained. RG 1.219 allows changes to the Emergency Plan to re-establish the last NRG-approved licensing basis as long as the changes were based on an operating philosophy to exceed minimum requirements and not a done to compensate for special circumstances which existed at the time of the change (e.g., performance issues or other deficiencies).

Description of How the Change Still Complies with Regulations Planning Standard 10 CFR 50.47(b)(9) states that adequate methods, systems and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use. Furthermore, NUREG-0654,Section II.I, Accident Assessment Evaluation Criteria II.I ensures, with respect to Dose Assessment, that:

  • Methods to be used for determining the source term of releases of radioactive material within plant systems are established as well as the magnitude of the release of radioactive materials based on plant system parameters and effiuent monitors.
  • Each licensee shall establish the relationship between effluent monitor readings and onsite and offsite exposures and contamination for various meteorological conditions.
  • Each licensee shall establish the methodology for determining the release rate/projected doses if the instrumentation used for assessment are offscale or inoperable.
  • Each organization, where appropriate, shall provide methods, equipment and expertise to make rapid assessments of the actual or potential magnitude and locations of any radiological hazards through liquid or gaseous release pathways.
  • Each organization shall establish means for relating the various measured parameters (e.g., contamination levels, water and air activity levels) to dose rates for key isotopes.

Page 4 of 8 Ginna's Emergency Plan Annex currently describes how the station meets these requirements. Specifically, the Emergency Plan discusses multiple means to perform Dose Assessment including a procedure based manual method, a computer spreadsheet which mimics the manual methodology, and a sophisticated computer method which incorporates updated industry guidance. Ginna utilizes the sophisticated URI computer-based program to perform dose assessments with their ERO, including on shift. The inclusion of the additional methods in the Emergency Plan exceeds the requirements of NUREG-0654.

Background

A review of the historical licensing basis documentation was performed to establish the licensing basis and identify the reasons for including the three (3) dose assessment methods in the Emergency Plan. This review included a comparison of the initial Revision O licensing basis and subsequent revisions to the Emergency Plan with respect to dose assessment capabilities.

Ginna's initial Revision O to the site Emergency Plan contained the following description of the Dose Assessment capabilities.

A procedure for estimating off-site doses for areas around the plant is used at the TSC and EOF. Based upon these results, protective actions can be recommended As required by NUREG-0654, the original Emergency Plan described a single procedure based on a method for estimating offsite doses. The method was performed manually using tables and graph overlays.

As technology advanced, these manual methods were incorporated into a simple computer-based spreadsheet. The methodology was essentially the same; however, computers were used rather than paper tables and graphs. In 1989, Revision 8 of the Ginna Emergency Plan was implemented to recognize the computer-based spreadsheet in the Technical Support Center (TSC) and Emergency Operations Facility (EOF) which mimics the manual method, while maintaining the manual method in the Main Control Room (MCR). The following statement was added to the Emergency Plan to describe the computer-based program used:

A computer program operating on a micro- computer is also available in the TSC and EOF. This system mimics the overlay method of calculating downwind dose rates and airborne contamination levels.

As of 1981, the requirements of NUREG-0654 continued to be met with the additional redundancy offered by the computer spreadsheet program in the TSC and EOF. The addition of the computer was the result of the availability of improved technology and not by performance issues or identified deficiencies. The addition created a more robust method of estimating offsite dose. The discussion of the manual procedure methods was maintained in the Emergency Plan and continued to be used in the MCR.

As part of the 1989 revision, Ginna also added a more sophisticated computer-based program for dose assessment. This program (i.e., MIDAS) utilized advanced methodologies to accomplish the dose assessments and meet the guidance requirements of NUREG-0654.

Page 5 of 8 The more sophisticated programs provided more accurate and timely dose assessment estimates, surpassing the capabilities of the manual procedure methods. The following statement was added to the Ginna Emergency Plan:

A more sophisticated computer program, which uses the methods for environmental dose calculations required by Federal regulations, is also available to assess doses during and after an emergency.

The revision was made as a result of a change in available technology and not driven by performance issues or identified deficiencies. The addition was an enhancement that met the regulatory requirements and exceeded the requirements by including two (2) diverse methods for dose assessment.

The 1989 Ginna Emergency Plan recognized two (2) methods which supported dose assessment (a procedure-driven method which could be used with or without the aid of a computer spreadsheet and the more sophisticated MIDAS computer model).

In 2005, the MIDAS computer model was replaced by NRC's computer-based program (i.e.,

RASCAL) (EOF8) at the TSC and EOF. The RASCAL model offered improvements over MIDAS in that it was self-contained and did not require a dial-up remote access to run.

There were no changes needed to the description in the Emergency Plan for this change.

In 2014, Ginna replaced the computer-based program (RASCAL) with Exelon's Unified Rascal Interface (URI) for performance of dose assessment. URI was also placed in the MCR for use with on-shift assessments. This change was evaluated pursuant to 10 CFR 50.54(q).

Assessment The change to remove the reference to the manual procedure method arid the associated computer supporting spreadsheet method from the Emergency Plan is considered acceptable. These methods have been superseded initially by MIDAS, then RASCAL-based EOF8 and now by the current URI dose assessment program. URI incorporates updated methodologies for dose assessment and is considered more comprehensive, timely, and accurate than the original tables and graphs used in the manual method. URI continues to satisfy all the NUREG-0654 guidance requirements, is an acceptable method for performing dose assessment, and used successfully by many licensees in the industry.

Note that when the MIDAS system was incorporated at the station, Ginna could have elected to remove the manual procedure methods from the Emergency Plan and completely credit the sophisticated computer-based model without a reduction in effectiveness. The station elected to retain the manual methods, as well as the descriptions contained in the station Emergency Plan at the time.

RG 1.219 provides the governing guidance pertaining to which changes can be made without obtaining prior NRC approval. The process involves evaluating the NRG-approved licensing basis and determining whether a proposed change would reduce the effectiveness (i.e., capabilities and timeliness) of performing an emergency planning function. In this revision to the Emergency Plan, Ginna proposes to remove a discussion regarding the original manual dose assessment contained in the Emergency Plan licensing basis. For this change, the licensing basis was revised to add additional computer-based dose assessment

,

  • Attachment 1 Page 6 of 8 methods, while retaining the original manual methods which have since become obsolete.

This exceeded the regulatory requirements and guidance established in NUREG-0654.

RG 1.219 allows a revision of the Emergency Plan to remove these original methods without considering the revision as a reduction in effectiveness if it can be shown that the original level of commitment can be maintained. An example in RG 1.219, Section 1.6 specifies that a licensee should consider why regulatory requirements were exceeded when making a change to re-establish a previous licensing basis. RG 1.219 provides the following discussion with respect to reasons for exceeding regulatory requirements in the Emergency Plan:

Was it a matter of exceeding the regulatory minimum as an operating philosophy, or was it done to compensate for special circumstances that existed when the decision was made? A decrease .... in the first case might not reduce effectiveness; a decrease ... in the second case would reduce effectiveness if the special circumstances still existed.

For Ginna's change, there were no special circumstances that required the station to maintain both dose assessment methods to be described in the Emergency Plan. There were no performance*issues or identified deficiencies which required multiple methods for dose assessment to be maintained. There were no commitments to the NRG to require multiple methods for dose assessment to be maintained at the station. The additional methods were added due to technological advancements and changes in available methodology. Ginna elected to maintain the description of the manual methods as an enhancement to the program.

Due to the rudimentary methodology of the manual method and associated computer-based spreadsheet, the burden of maintaining a spreadsheet method, as well as the burden of maintaining ERO proficiency with manual methods, Ginna is removing the manual method and associated computer-based spreadsheet method from the Emergency Plan.

The current URI methodology meets the regulatory requirements and guidance established of NUREG-0654 stated above. The URI program is accepted and used at the other Exelon stations, as well as other licensees in the industry. The URI program is considered more accurate and timely than the manual methods previously used at the station. The program is used both as a network-based program, and will also be implemented as a stand-alone self-contained program to satisfy Cyber Security requirements by 2017. This redundancy with the implementation of URI ensures a robust method will be available at the Emergency Response Facilities (ERFs) for dose assessment. The availability of backup power to the ERFs and the Uninterruptible Power Supplies (UPSs) will further ensure that the dose assessment function will be maintained using a more sophisticated dose assessment method than could be provided by the manual methods. The MCR and TSC have two (2) redundant Personal Computers (PCs) with standalone versions of URI installed, while the EOF has three (3) redundant PCs. The UPS is available for at least four (4) hours at all of the ERFs, as well as dedicated backup generators at the TSC and EOF. Therefore, the URI method will provide for a more accurate, reliable, and timelier means of performing the dose assessment function. Also, as noted, above this change was evaluated pursuant to 10 CFR 50.54(q).

  • ' Attachment 1 Page 7 of 8 Specific Emergency Plan Changes Step 5.3.3 was revised to delete reference to X/Q "tables" and just reference the X/Q values.

With the deletion of the manual method for dose assessment, the tables no longer exist.

Step .5.3.3 was revised to delete a statement that: "The airborne concentration is multiplied by the X/Q value and divided by the wind speed to obtain an estimated release rate from the plant." The sentence provides specific details of how release rates are determined with respect to X/Q and windspeed. This is accomplished through the URI program and such calculations are no longer performed. In its place, the statement: "Field Team survey results can be used to back calculate doses at the site boundary and offsite," to establish that release rates can still be obtained through the use of Field Team surveys through URI. This maintains the level of commitment to the NUREG-0654 guidance and does not reduce the effectiveness of the Emergency Plan.

11 Step 5.3.3 was revised to delete the sentence: A procedure for manually estimating offsite doses for areas around the plant is available in the Control Room, TSC and EOF. Based 11 upon these results, protective actions can be recommended. This procedure for manually estimating offsite dose is no longer necessary with the implementation of the more sophisticate URI dose assessment software. While the Emergency Plan maintained the description of both methods for a period of time, it has been established above that this decision exceeded regulatory requirements and was not done as a result of performance issues or identified deficiencies. As such, the level of commitment in the last NRG-approved licensing basis has not been reduced with the deletion of the manual method.

Step 5.3.3 was revised to delete reference to the overlay method, which was associated with the manual methods. The sentence was revised to maintain the requirement to calculate downwind dose rates and airborne concentrations as stipulated by the guidance in NUREG-0654. .

Some editorial changes were implemented as part of this revision to maintain sentence 11 11 structure. For example, the phrase A more sophisticated... was replaced with the phrase "The sophisticated ... " in Step 5.3.3.

In addition a revision was made to Step 5.3.1 O to delete reference to the manual calculation methods of dose assessment, leaving reference to the computerized calculation methods.

This is acceptable for reasons stated above.

The deletion of the manual methods of performing dose assessment (procedure and spreadsheet) from the Ginna Emergency Plan essentially re-establishes the original licensing basis. URI not only satisfies the original commitment for dose assessment found in the last NRC approved Emergency Plan, but it also satisfies current regulatory regulations and guidance for the performance of dose assessment.

Tummary, Ginna originally relied on a manual proceduralized method to perform dose assessment as described in Revision O of their Emergency Plan. Following advances in technology, Ginna implemented a computer-based dose assessment method which replaced the manual method. Following the adoption of the computer software to perform dose assessment, the manual method was no longer required to support any aspects of dose assessment. The Emergency Plan retained reference to this manual method even though it was no longer required; this change to the Emergency Plan is removing reference to an outdated manual method of dose assessment.

    • Attachment 1 Page 8 of 8 Description of Why the Change is Not a Reduction in Effectiveness (RIE)

This revision does not constitute a Reduction in Effectiveness as discussed above. There are no Regulatory Commitments impacted by this revision to the Emergency Plan. The current Computer method which remains in the Emergency Plan is an industry proven and NRC accepted method which has been installed at Ginna's ERFs with redundancy and continues to satisfy the Regulatory requirements referenced in the Emergency Plan.

4. Position Titles (Nine Mile Point EP-AA-1013, Revision 2)

Description of Changes A revision was made regarding editorial .changes to Figures 2.3 TSC Staffing and Figure 2.5 EOF Staffing. Specifically changes were made to revise position titles. No changes to responsibilities were made as a result of this change.

Description of How the Change Still Complies with Regulations Editorial changes to Figures 2.3 TSC Staffing and Figure 2.5 EOF Staffing were made to revise position titles. No technical changes were made and no changes to responsibilities were made as a result of this change. These changes do not impact the compliance with EP regulatory requirements.

Description of Why the Change is Not a Reduction in Effectiveness (RIE)

Per RG 1.219, these types of changes do not result in a Reduction in Effectiveness of the Emergency Plan. Regulatory requirements and emergency planning commitments were not impacted.

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