ML17263A944

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SE Informing That Proposed EAL Changes for Plant Consistent W/Guidance in NUMARC/NESP-007 & Meet Requirements of 10CFR50.47(b)(4) & App E to 10CFR50
ML17263A944
Person / Time
Site: Ginna Constellation icon.png
Issue date: 02/15/1995
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML17263A943 List:
References
NUDOCS 9502210293
Download: ML17263A944 (8)


Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055$ 4001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ON REVISED EMERGENCY ACTION LEVELS FOR ROCHESTER GAS AND ELECTRIC CORPORATION R.

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GINNA NUCLEAR POWER PLANT DOCKET NO. 50-244

1.0 INTRODUCTION

By letter dated May 13,

1994, as supplemented by letters dated November 7,
1994, and January 23,
1995, Rochester Gas and Electric Corporation (RGEE or the licensee) proposed changes to the R.E.

Ginna Nuclear Power Plant (GNPP) emergency action levels (EALs).

Specifically, RGLE provided a plant-specific EAL guideline, a fission product barrier evaluation, and a technical basis document that describe how the proposed EALs incorporated the guidance in NUMARC/NESP-007, "Methodology for Development of Emergency Action Levels,"

Revision 2, January 1992.

The NRC has endorsed NUMARC/NESP-007 as an acceptable method by which licensees may develop site-specific emergency classification schemes.

2.0 BACKGROUND

The EAL changes proposed for the GNPP were reviewed against the requirements in 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50.

Title 10 CFR 50.47(b)(4) specifies that onsite emergency plans must meet the following standard:

"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...".

Appendix E, Subsection IV.C, specifies that "emergency action levels (based not only on onsite and offsite radiation monitoring information but also on readings from a number of sensors that indicate a potential emergency, such as pressure in containment and response of the Emergency Core Cooling System) for notification of offsite agencies shall be described...

The emergency classes defined shall include (1) notification of unusual

events, (2) alert, (3) site area emergency, and (4) general emergency."

In Revision 3 to Regulatory Guide 1. 101, "Emergency Planning and Preparedness for Nuclear Power Reactors,"

the NRC endorsed NUMARC/NESP-007, Revision 2, (NESP-007),

"Methodology for Development of Emergency Action Levels,"

as an acceptable method for licensees to meet the requirements of 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50.

The staff relied upon the guidance in NUMARC/NESP-007 as the basis for its review of the EAL changes.

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ON RGKE has divided 91 site-specific EALs into 9 subcategories:

(1)

CSFST Status, (2) Reactor Fuel, (3) Reactor Coolant System, (4) Containment, (5)

Radioactivity Release, (6) Electrical Failures, (7) Equipment Failures, (8)

Hazards, and (9) Other.

Each EAL is identified by a unique number sequence designation.

The initiating conditions associated with each EAL, that relate the EAL to its respective emergency classification, are defined in the licensee's EAL Technical Bases Document.,

Each of the EALs proposed by the licensee that address fission product barrier degradation explicitly reference the barriers which are affected by the described condition.

A majority of the proposed EALs conform closely to the guidance;

however, several of the licensee's proposed changes depart from the example EALs in NUMARC/NESP-007.

Review of the licensee's justification for these variations, as discussed below, found the variations to be acceptable.

1.

NUMARC example EALs AA2-3 and AA2-4 state:

3.

4'ater level less than (site-specific) feet for the Reactor Refueling Cavity that will result in Irradiated Fuel Uncovering.

4.

bloater level less than (site-specific) feet for the Spent Fuel Pool and Fuel Transfer Canal that will"result in Irradiated Fuel Uncovering.

Due to lack of instrumentation to measure water level in the spent fuel pool, fuel transfer canal, or refueling cavity, the licensee does not include site-specific EALs to address these examples.

The licensee does include an example EAL for visual observation of water level to address irradiated fuel uncovery.

2.

NUMARC example EAL AU2-4 states:

4.

Valid Direct Area Radiation Honitor readings increase by a factor of 1000 over normal levels.

The licensee has related its site-specific threshold for this example EAL to Area Radiatjon Monitor (ARM) alarm setpoints.

Since ARM alarm setpoints ~e nominally set by the licensee at one decade over normal levels:,

100 times the alarm setpoint was chosen as an appropriate threshold.

For those ARMs whose upper range limit is less than 100 times the alarm setpoint, the licensee has chosen the threshold of "offscale high."

3.

NUMARC example EAL HS2-1 states:

1.

The following conditions exist:

a.

Control rooN evacuation has been initiated.

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AND b.

Control of the plant cannot be established per (site-specific) procedure within (site-specific) minutes.

The NUHARC basis states that the site-specific time for transfer of control should be based upon analysis or assessments as to how quickly control must be reestablished without core uncovery and/or core damage.

However, the time should not exceed 15 minutes.

In accordance with the guestions and Answers associated with the implementation of NUHARC/NESP-007, dated June 1993, times greater than 15 minutes may be appropriate if technically justified.

The licensee states that its Appendix R submittal indicates that operators have at least 20 minutes to restore control of safety systems without resulting in core uncovery or core damage.

This is an acceptable analysis for justification of the longer time period in the EAL.

4.

,NUHARC example EALs AUl-3 and AUl-4 state:

3.

Valid reading on perimeter radiation monitoring system greater than 0.10 mR/hr above normal background for 60 minutes (for sites having telemetered perimeter monitors'.

4.

Valid indication on automatic real-time dose assessment capability greater than (site-specific value) for 60 minutes or longer (for sites having such capability).

The licensee states that it does not currently possess a telemetered radiation monitoring system or real-time dose assessment capability and, therefore, does not include site-specific EALs for these examples.

This comment is also applicable to NUHARC example EALs AA1-3, AA1-4, AS1-2, and AG1-2.

4.0 CONCLUSION

The proposed EAL changes for Ginna are consistent with the guidance in NUHARC/NESP-007, with variations as identified and accepted in this review, and, therefore, meet the requirements of 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50.

Principal Contributor:

S.

Boynton Date:

February 15, 1995

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'DISTRIBUTION'Docket Fi.le'UBLIC PDI-3 Reading SVarga JZwolinski WButler SLittle AJohnson OGC ACRS (4)

JLinville, RI RSpessard CMiller TEssig SBoynton WDean

WLazarus, RI

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