ML20198M498
| ML20198M498 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 01/27/2021 |
| From: | Ellen Brown Plant Licensing Branch II |
| To: | Moul D Florida Power & Light Co |
| Brown E | |
| References | |
| EPID L-2019-LLA-0271, L-2019-203 | |
| Download: ML20198M498 (37) | |
Text
January 27, 2021 Mr. Don Moul Executive Vice President, Nuclear Division and Chief Nuclear Officer Florida Power & Light Company Mail Stop: EX/JB 700 Universe Blvd.
Juno Beach, FL 33408
SUBJECT:
TURKEY POINT NUCLEAR GENERATING PLANT, UNIT NOS. 3 AND 4 -
ISSUANCE OF AMENDMENT NOS. 294 AND 287 REGARDING EMERGENCY ACTION LEVEL SCHEME UPGRADE (EPID L-2019-LLA-0271) (L-2019-203)
Dear Mr. Moul:
The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 294 to Subsequent Renewed Facility Operating License No. DPR-31 and Amendment No. 287 to Subsequent Renewed Facility Operating License No. DPR-41 for the Turkey Point Nuclear Generating Plant, Unit Nos. 3 and 4, respectively (Turkey Point). The amendments revise the Turkey Point Emergency Action Level scheme to one based on the Nuclear Energy Institute (NEI) document NEI 99 01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, dated November 21, 2012, in response to the application from Florida Power & Light Company dated December 6, 2019, as supplemented by letters dated June 8, and November 5, 2020 (Agencywide Documents Access and Management System Accession Nos. ML19343A373, ML20160A463 and ML20310A382, respectively).
A copy of the Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
Eva A. Brown, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251
Enclosures:
- 1. Amendment No.294 to DPR-31
- 2. Amendment No.287 to DPR-41
- 3. Safety Evaluation cc: Listserv
FLORIDA POWER & LIGHT COMPANY DOCKET NO. 50-250 TURKEY POINT NUCLEAR GENERATING UNIT NO. 3 AMENDMENT TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSE Amendment No.294 Subsequent Renewed License No. DPR-31
- 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Florida Power & Light Company (the licensee) dated December 6, 2019, as supplemented by letters dated June 8 and November 5, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions 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 Commissions regulations; 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 Commissions regulations, and all applicable requirements have been satisfied.
- 2.
Accordingly, by Amendment No. 294, Subsequent Renewed Facility Operating License No. DPR-31 is hereby amended to authorize revision of Turkey Points Emergency Plan as set forth in Florida Power & Light Companys application dated December 6, 2019, as supplemented by letters dated June 8 and November 5, 2020, and evaluated in the NRC staffs safety evaluation dated January 27, 2021, and to reflect the issuance of this amendment by hereby amending paragraph 3B.
- 3.
This license amendment is effective as of its date of issuance and shall be implemented within 184 days.
FOR THE NUCLEAR REGULATORY COMMISSION Ho K. Nieh, Director Office of Nuclear Reactor Regulation
Attachment:
Changes to the Subsequent Renewed Facility Operating License and Technical Specifications Date of Issuance: January 27, 2021 Craig G.
Erlanger Digitally signed by Craig G. Erlanger Date: 2021.01.27 17:27:37 -05'00'
FLORIDA POWER & LIGHT COMPANY DOCKET NO. 50-251 TURKEY POINT NUCLEAR GENERATING UNIT NO. 4 AMENDMENT TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSE Amendment No.287 Subsequent Renewed License No. DPR-41
- 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Florida Power & Light Company (the licensee) dated December 6, 2019, as supplemented by letters dated June 8 and November 5, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions 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 Commissions regulations; 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 Commissions regulations, and all applicable requirements have been satisfied.
- 2.
Accordingly, by Amendment No. 287, Subsequent Renewed Facility Operating License No. DPR-41 is hereby amended to authorize revision of Turkey Points Emergency Plan as set forth in Florida Power & Light Companys application dated December 6, 2019, as supplemented by letters dated June 8 and November 5, 2020, and evaluated in the NRC staffs safety evaluation dated January 27, 2021, and to reflect the issuance of this amendment by hereby amending paragraph 3B.
- 4.
This license amendment is effective as of its date of issuance and shall be implemented within 184 days.
FOR THE NUCLEAR REGULATORY COMMISSION Ho K. Nieh, Director Office of Nuclear Reactor Regulation
Attachment:
Changes to the Subsequent Renewed Facility Operating License and Technical Specifications Date of Issuance: January 27, 2021 Craig G.
Erlanger Digitally signed by Craig G. Erlanger Date: 2021.01.27 17:28:07 -05'00'
ATTACHMENT TO LICENSE AMENDMENT NOS. 294 AND 287 TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 SUBSEQUENT RENEWED FACILITY OPERATING LICENSE NOS. DPR-31 AND DPR-41 DOCKET NOS. 50-250 AND 50-251 Replace page 3 of Subsequent Renewed Facility Operating License No. DPR-31 with the attached page 3. The revised page is identified by amendment number and contains a marginal line indicating the area of change.
Replace page 3 of Subsequent Renewed Facility Operating License No. DPR-41 with the attached page 3. The revised page is identified by amendment number and contains a marginal line indicating the area of change.
3 Subsequent Renewed License No. DPR-31 Amendment No. 294 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 below:
A.
Maximum Power Level The applicant is authorized to operate the facility at reactor core power levels not in excess of 2644 megawatts (thermal).
B.
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 294, are hereby incorporated into this subsequent renewed license. The Environmental Protection Plan contained in Appendix B is hereby incorporated into this subsequent renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
C.
Final Safety Analysis Report The licensees Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on November 1, 2001, describes certain future inspection activities to be completed before the period of extended operation.
The licensee shall complete these activities no later than July 19, 2012.
The Final Safety Analysis Report supplement as revised on November 1, 2001, described above, shall be included in the next scheduled update to the Final Safety Analysis Report required by 10 CFR 50.71(e)(4), following the issuance of this renewed license. Until that update is complete, the licensee may make changes to the programs described in such supplement without prior Commission approval, provided that the licensee evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.
D.
Fire Protection FPL shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment requests dated June 28, 2012 and October 17, 2018 (and supplements dated September 19, 2012; March 18, April 16, and May 15, 2013; January 7, April 4, June 6, July 18, September 12, November 5, and December 2, 2014; and February 18, 2015; October 24, and December 3, 2018; and January 31, 2019), and as approved in the safety evaluations dated May 28, 2015 and March 27, 2019. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the
3 Subsequent Renewed License No. DPR-41 Amendment No. 287 A.
Maximum Power Level The applicant is authorized to operate the facility at reactor core power levels not in excess of 2644 megawatts (thermal).
B.
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 287 are hereby incorporated into this subsequent renewed operating license. The Environmental Protection Plan contained in Appendix B is hereby incorporated into this subsequent renewed license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
C.
Final Safety Analysis Report The licensees Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on November 1, 2001, describes certain future inspection activities to be completed before the period of extended operation.
The licensee shall complete these activities no later than April 10, 2013.
The Final Safety Analysis Report supplement as revised on November 1, 2001, described above, shall be included in the next scheduled update to the Final Safety Analysis Report required by 10 CFR 50.71(e)(4), following the issuance of this renewed license. Until that update is complete, the licensee may make changes to the programs described in such supplement without prior Commission approval, provided that the licensee evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.
D.
Fire Protection FPL shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment requests dated June 28, 2012 and October 17, 2018 (and supplements dated September 19, 2012; March 18, April 16, and May 15, 2013; January 7, April 4, June 6, July 18, September 12, November 5, and December 2, 2014; and February 18, 2015; October 24, and December 3, 2018; and January 31, 2019), and as approved in the safety evaluations dated May 28, 2015 and March 27, 2019. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR AMENDMENT NO. 294 TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSE NO. DPR-31 AND AMENDMENT NO. 287 TO SUBSEQUENT RENEWED FACILITY OPERATING LICENSE NO. DPR-41 FLORIDA POWER & LIGHT COMPANY TURKEY POINT NUCLEAR GENERATING UNIT NOS. 3 AND 4 DOCKET NOS. 50-250 AND 50-251
1.0 INTRODUCTION
By application dated December 6, 2019, as supplemented by letters dated June 8 and November 5, 2020 (Agencywide Documents Access and Management System Accession (ADAMS) Nos. ML19343A373, ML20160A463 and ML20310A382, respectively), Florida Power
& Light Company (FPL) requested the U.S. Nuclear Regulatory Commissions (NRC) approval for an emergency action level (EAL) scheme change for Turkey Point Nuclear Plant, Units 3 and 4 (Turkey Point). The proposed changes would revise the EAL scheme to one based on the Nuclear Energy Institute (NEI) document NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, dated November 21, 2012 (ADAMS Accession No. ML12346A463).
The supplemental letters dated June 8 and November 5, 2020, provided additional information that clarified the application, but did not expand the scope of the application as originally noticed nor change the NRC staff proposed no significant hazards consideration determination as published in the Federal Register on December 31, 2019 (84 FR 72388).
2.0 REGULATORY EVALUATION
2.1 Regulations The applicable regulations and guidance for emergency plans are provided in Sections 2.1 and 2.2 below.
Title 10 of the Code of Federal Regulations (10 CFR), Section 50.47, Emergency plans, sets forth emergency plan requirements for nuclear power reactors. Section 50.47(b) of 10 CFR establishes the planning standards that the on-site and off-site emergency response plans must meet for the NRC staff to make a finding that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.
Specifically, Planning Standard (4) of this section requires that on-site and off-site emergency response plans meet the following:
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 off-site response measures.
The use of a standard emergency classification and action level scheme ensures that implementation methods are relatively consistent throughout the industry for a given reactor and containment design but permit site-specific design considerations and preferences.
Section IV.B.1 of Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, 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 on-site and off-site 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.
Section IV.B.2 of Appendix E to 10 CFR Part 50 states:
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. Licensees shall follow the change process in
§ 50.54(q) for all other emergency action level changes.
2.2 Guidance The EAL development guidance was initially established in Generic Letter 79-50, Emergency Plans Submittal Dates, dated October 10, 1979 (ADAMS Accession No. ML031320278). This guidance was subsequently revised in NUREG-0654/FEMA-REP-1 (NUREG-0654), Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, dated November 1980 (ADAMS Accession No. ML040420012). NUREG-0654, Revision 1, was endorsed by NRC Regulatory Guide (RG) 1.101, Revision 2, Emergency Planning and Preparedness for Nuclear Power Reactors, dated October 1981 (ADAMS Accession No. ML090440294), as an approach acceptable to the NRC for the development of an EAL scheme.
As industry and regulatory experience were gained with the implementation and use of EAL schemes, the industry issued revised EAL scheme development guidance to reflect lessons learned, numerous of which have been provided to the NRC for review and endorsement as generic (i.e., non-site-specific) EAL development guidance. Most recently, the industry developed NEI 99-01, Revision 6, which was endorsed by the NRC in a letter dated March 28, 2013, as acceptable generic EAL scheme development guidance (ADAMS Accession No. ML13091A209).
Although the EAL development guidance contained in NEI 99-01, Revision 6, is generic and may not be entirely applicable for some non-passive, large light-water reactor designs, it bounds the most typical accident and event scenarios for which emergency response is necessary, in a format that allows for industry standardization and consistent regulatory oversight. Licensees may choose to develop site-specific EAL schemes using NEI 99-01, Revision 6, with appropriate site-specific alterations as applicable.
NRC Regulatory Issue Summary (RIS) 2003-18, Revision 4, Use of NEI 99-01, Methodology for Development of Emergency Action Levels, dated October 8, 2003, including Supplements 1 and 2 (ADAMS Accession Nos. ML032580518, ML041550395, and ML051450482, respectively), also provides guidance for developing or changing a standard EAL scheme. In addition, this RIS and its supplements provide recommendations to assist licensees, consistent with Section IV.B.2 of Appendix E to 10 CFR Part 50, in determining whether to seek prior NRC approval of deviations from the guidance.
In summary, the NRC staff considers NEI 99-01, Revision 6, as an acceptable method to develop site-specific EALs that meet the requirements of Section IV.B of Appendix E to 10 CFR Part 50 and planning standard 10 CFR 50.47(b)(4), with the understanding that licensees may want to develop EALs that differ from the guidance document as allowed in RG 1.101.
2.3 NRC Staff Review In its application dated December 6, 2019, as supplemented by letters dated June 8 and November 5, 2020, the licensee proposed to revise the EAL scheme for Turkey Point based on NEI 99-01, Revision 6. The licensee submitted the proposed EAL scheme, the technical basis containing an evaluation and rationale for each proposed EAL change, and a comparison matrix providing a comparison of the proposed initiating conditions, mode applicability, and EAL wording to that found in NEI 99-01, Revision 6. The comparison matrix also included a description of global changes applicable to the EAL scheme and a justification for any differences or deviations from NEI 99-01, Revision 6. The NRC staff notes that the November 5, 2020 supplement updated the atmospheric dispersion factor used in support of the development of the revised EAL scheme. While the supplemental information required revision to the associated EAL Scheme Wallcharts, the NRC confirmed that the changes had minimal impact on the acceptability of the proposed EAL scheme. The application states that the licensee used the terms difference and deviation as defined in RIS 2003-18, as supplemented, when comparing its proposed site-specific EALs to the generic EALs in NEI 99-01, Revision 6.
The NRC staff reviewed the application, as supplemented, and verified that the proposed EAL scheme is consistent with the guidance provided in NEI 99-01, Revision 6, to ensure that the proposed EAL scheme meets the requirements of Section IV.B of Appendix E to 10 CFR Part 50 and planning standard 10 CFR 50.47(b)(4). However, the NRC staff found that both the current and proposed EALs have modifications from the NEI 99-01, Revision 6, guidance due to specific plant designs and licensee preference.
In reviewing the application, as supplemented, the NRC staff also verified that the instrumentation and setpoints derived for this proposed EAL scheme are consistent with the overall EAL scheme development guidance, address the site-specific implementation strategies provided, and are consistent with a standard EAL scheme.
Although the EALs must be site-specific, the NRC staff reviewed the proposed EALs for the following key characteristics of an effective EAL scheme to ensure:
Consistency, including standardization of intent, if not in actual wording (i.e., the EALs would lead to similar decisions under similar circumstances at different plants);
Human factors engineering and user friendliness; Potential for emergency classification level upgrade only when there is an increasing threat to public health and safety; Ease of upgrading and downgrading the emergency classification level; Thoroughness in addressing issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654 (i.e., the EALs are unambiguous and are based on site-specific indicators);
Technical completeness for each classification level; Logical progression in classification for multiple events, and The use of objective and observable values.
The NRC staff verified 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. The NRC staff verified that risk assessments were appropriately used to set the boundaries of the emergency classification levels and ensure that all EALs that trigger the declaration of an emergency classification level are in the same range of relative risk. In addition, the NRC staff verified that the proposed EAL scheme is technically complete for each emergency classification level, accurate, and consistent with EAL schemes implemented at similarly designed plants.
To aid in understanding the nomenclature used in this safety evaluation, the following conventions are used (e.g., RU1 or RA1):
the first letter signifies the EAL recognition category:
o A or R - Abnormal Radiation Levels/Radiological Effluent, o C - Cold Shutdown/Refueling System Malfunction, o E - Independent Spent Fuel Storage Installation, o F - Fission Product Barrier, o H - Hazards and Other Conditions Affecting Plant Safety, and o S or M - System Malfunction.
the second letter signifies the emergency classification level:
o U = Notification of Unusual Event (Unusual Event),
o A = Alert, o S = Site Area Emergency, and o G = General Emergency.
the number is the applicable number from the site-specific EAL scheme.
An EAL set refers to EALs within an EAL Recognition Category that include an escalation path for one or more emergency classification levels. Not all EAL Recognition Categories require an EAL set.
This safety evaluation uses the numbering system from the proposed site-specific EAL scheme.
However, the numbering system from the generic EAL scheme development guidance contained in NEI 99-01, Revision 6, is annotated in [brackets] to aid in cross-referencing the site-specific EAL numbering convention with that of the guidance, where applicable.
3.0 TECHNICAL EVALUATION
3.1 Recognition Category R - Abnormal Radiation Levels/Radiological Effluent 3.1.1 EAL Set RU1/RA1/RS1/RG1 [AU1/AA1/AS1/AG1]
The intent of this EAL set is to ensure that an emergency classification level is declared upon site-specific indications of a release of radioactivity (gaseous or liquid). In recognition of the lower possible radioactivity concentrations, the assessment of liquid releases is limited to the Unusual Event and Alert classification levels. This set provides for accident assessments using pre-calculated values based on assumed conditions, real-time parameters, and field monitoring results.
The NRC staff verified that the progression from an Unusual Event to a General Emergency classification level is appropriate and consistent with EAL scheme development guidance.
RU1 - This EAL addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period (e.g., an uncontrolled release).
RA1 - This EAL addresses a release of gaseous or liquid radioactivity that results in projected or actual off-site doses greater than or equal to 1 percent of the U.S. Environmental Protection Agency (EPA) early phase protective action guides (PAGs) (ADAMS Accession No. ML17044A073).
RS1 - This EAL addresses a release of gaseous radioactivity that results in projected or actual off-site doses greater than or equal to 10 percent of the EPA early phase PAGs.
RG1 - This EAL addresses a release of gaseous radioactivity that results in projected or actual off-site doses greater than or equal to the EPA early phase PAGs.
The NRC staff has reviewed the proposed removal of the main steam radiation monitors from the respective effluent monitor threshold tables. Considering that the main steam radiation monitors are process monitors designed to detect gross fuel failures and not to assess potential offsite release rates, and that a steam generator tube leak would be bounded by the fission product barrier, and off-site dose assessment or field monitoring, the NRC staff finds this change to be acceptable.
The licensee provided justification that the proposed radiation monitors used to assess effluent gaseous release points were acceptable based on site-specific gaseous discharge paths. 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. The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.
3.1.2 EAL Set RU2/RA2/RS2/RG2 [AU2/AA2/AS2/AG2]
The intent of this EAL set is to ensure that an emergency classification level is declared upon site-specific indications of potential or actual damage to an irradiated fuel assembly or multiple assemblies. It addresses a lowering of water level over irradiated fuel or fuel uncovery (i.e., level below the top of the fuel), and a spectrum of fuel handling accidents that result in mechanical damage to irradiated fuel (e.g., a dropped fuel assembly). Some of these EALs rely on the SFP water level instrumentation required by NRC Order EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, dated March 12, 2012 (ADAMS Accession No. ML12056A044).
The NRC staff has verified that the progression from an Unusual Event to a General Emergency classification level is appropriate and consistent with EAL scheme development guidance.
RU2 - This EAL addresses a decrease in water level above irradiated fuel that causes elevated radiation levels.
RA2 - This EAL addresses events that have caused imminent or actual damage to an irradiated fuel assembly or a significant lowering of water level within the SFP.
RS2 - This EAL addresses a significant loss of SFP water inventory control and makeup capability leading to imminent fuel damage and addresses NRC Order EA-12-051.
RG2 - This EAL addresses a significant loss of SFP water inventory control and makeup capability leading to a prolonged uncovery of irradiated fuel and addresses NRC Order EA-12-051.
The use of IMMINENT in the basis discussion relative to RA2.1 refers to imminent damage of an irradiated fuel assembly. Section 5.5 of NEI 99-01, Revision 6, refers to making an emergency classification when the Emergency Director determines that conditions that could lead to meeting or exceeding an EAL within a short amount of time. Although different from the guidance in NEI 99-01, Revision 6, this change is acceptable because the guidance in NEI 99-01, Revision 6, is intended to ensure that an Alert classification level should be declared only when an actual or potential substantial degradation of the level of safety of the plant has occurred due to a hazardous event.
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. The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.
3.1.3 EAL RA3 [AA3]
The intent of this EAL is to ensure that an emergency classification level is declared when elevated radiation levels in certain plant rooms and areas are enough to preclude or impede personnel from performing actions necessary to maintain normal plant operation or to perform a normal plant cooldown and shutdown. This includes equipment in the control room and the central alarm station. The Alert classification level is primarily intended to ensure that the licensee emergency response organization (ERO) is activated to support the control room in removing the impediment to normal access, as well as assisting in quantifying potential damage to the fuel. Indications of increasing radiation levels in the plant are bounded by Recognition Category F, as well as EALs 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. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.
3.2 Recognition Category C - Cold Shutdown/Refueling System Malfunction 3.2.1 EAL Set CU1/CA1/CS1/CG1 [CU1/CA1/CS1/CG1]
The intent of this EAL set is to ensure an emergency classification level is declared upon a loss of reactor pressure vessel (RPV) inventory and/or reactor coolant system (RCS) leakage.
The NRC staff verified that the progression from an Unusual Event to a General Emergency classification level is appropriate and consistent with EAL scheme development guidance.
CU1 - This EAL addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band) or a loss of the ability to monitor RPV/RCS level concurrent with indications of reactor coolant leakage.
CA1 - This EAL addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel in the RPV/RCS (i.e., a precursor to a challenge to the fuel clad barrier).
CS1 - This EAL addresses a significant and prolonged loss of RPV/RCS inventory control and makeup capability leading to imminent fuel damage.
CG1 - This EAL addresses the inability to restore and maintain RPV/RCS level above the top of active fuel with containment challenged.
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. The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.
3.2.2 EAL Set CU2/CA2 [CU2/CA2]
The intent of this EAL set is to ensure that an emergency classification level is declared upon a loss of available alternating current (AC) power to emergency power electrical busses.
The NRC staff verified that the progression from an Unusual Event to an Alert classification level is appropriate and consistent with EAL scheme development guidance. The Site Area Emergency and General Emergency classification levels for this specific accident progression are bounded by EALs RS1 and RG1.
CU2 - This EAL describes a significant degradation of off-site and on-site AC power sources such that any additional single failure would result in a loss of all AC power to safety systems.
CA2 - This EAL addresses a loss of all AC power that compromises the performance of all safety systems requiring electric power, including those necessary for emergency core cooling, containment heat removal/pressure control, irradiated fuel heat removal, and the ultimate heat sink.
The licensee modified this EAL set by using a site-specific implementation method that uses a numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and ease of upgrading/downgrading for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.
3.2.3 EAL Set CU3/CA3 [CU3/CA3]
The intent of this EAL set is to ensure that an emergency classification level is declared based on the inability to maintain control of decay heat removal.
The NRC staff verified that the progression from an Unusual Event to an Alert classification level is appropriate and consistent with EAL scheme development guidance. The progression to a Site Area Emergency and/or a General Emergency classification level is bounded by EALs RS1 and RG1.
CU3 - This EAL addresses an unplanned increase in RCS temperature above the technical specification cold shutdown temperature limit or the inability to determine RCS temperature and level.
CA3 - This EAL addresses conditions involving a loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed.
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. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and ease of upgrading/downgrading for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.
3.2.4 EAL CU4 [CU4]
The intent of this EAL is to ensure that an emergency classification level is declared upon a loss of vital direct current (DC) power that compromises the ability to monitor and control operable safety systems. This EAL is primarily intended to ensure that key licensee ERO members and offsite response organizations (OROs) are aware of the event, resources necessary to respond to the event are mobilized, and to ensure that any necessary compensatory measures are promptly implemented. The Alert, Site Area Emergency and General Emergency classification levels for a protracted loss of vital DC power are bounded by EALs CA1, CA3, CS1, CG1, RA1, 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. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.
3.2.5 EAL CU5 [CU5]
The intent of this EAL is to highlight the importance of emergency communications by ensuring that an emergency classification level is declared if normal communication methods for on-site and off-site personnel, or with OROs, including the NRC, are lost. This EAL is primarily intended to ensure that key licensee ERO members and OROs are aware of the loss of communications capabilities, the resources necessary to restore communications are mobilized, and compensatory measures are promptly implemented. Considering that a loss of emergency communications capability would not involve an actual or potential substantial degradation to the level of safety of the plant, no escalation path is necessary for this EAL.
The communication methods derived for this EAL are consistent with the overall EAL scheme development guidance.
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. The NRC staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.
3.2.6 EAL CA6 [CA6]
The intent of this EAL is to ensure that an emergency classification level is declared when hazardous events lead to potential damage to safety systems. The hazardous events of interest include, but are not limited to, an earthquake, flooding, high winds, tornado strike, explosion, fire, or any other hazard applicable for the site. This EAL is primarily intended to ensure that the licensee ERO is activated to support the control room in understanding the event impacts and restoring affected safety system equipment to service. Indications of hazard-induced damage to components containing radioactive materials are bounded by EALs CS1, CG1, RS1 and RG1.
As described in NEI 99-01, Revision 6, an Alert classification level exists when events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant. Any releases are expected to be limited to small fractions of the EPA early phase PAG exposure levels. The guidance in NEI 99-01, Revision 6, is intended to ensure that an Alert classification level should be declared only when an actual or potential substantial degradation of the level of safety of the plant has occurred because of a hazardous event. However, there may be cases where a hazardous event only causes damage to a single safety system component or a single safety system train. Additionally, an Alert classification level should not be declared if the damage from the hazardous event is limited to a safety system component or a safety system train that was inoperable or out of service prior to the event occurring.
The licensee proposed that an Alert classification level will be declared when a hazardous event results in indications of degraded performance to one train of a safety system with either indications of degraded performance on a second safety system train or visible damage to a second safety system train, such that the operability or reliability of the second safety system train is a concern. Although different from the guidance in NEI 99-01, Revision 6, this change is consistent with the intent of NEI 99-01, Revision 6, which is intended to ensure that an Alert classification level should be declared only when an actual or potential substantial degradation of the level of safety of the plant has occurred due to a hazardous event.
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. The NRC staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.
3.3 Recognition Category E - Independent Spent Fuel Storage Installation 3.3.1 EAL EU1 [E-HU1]
This EAL applies to an event that results in damage to the confinement boundary of a storage cask containing irradiated fuel. This EAL is primarily intended to ensure that key licensee ERO members and OROs are aware of the cask damage, resources necessary to respond to the event are mobilized, and protective measures, if warranted, are promptly implemented.
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. The NRC staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.
3.4 Recognition Category F - Fission Product Barrier Matrix 3.4.1 EAL Set FA1/FS1/FG1 [FA1/FS1/FG1]
The intent of this EAL set is to ensure that an emergency classification level is declared upon a loss or potential loss of one or more fission product barriers. This EAL set uses plant condition-based thresholds as triggers within a particular logic configuration needed to reflect a loss or potential loss of a fission product barrier. Non-passive, large light-water reactors in the United States have three fission product barriers: fuel cladding, the RCS, and 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 emergency classification level based upon the number of loss and/or potential loss indicators that are met for each barrier. These indicators are redundant with other similar indicators in Recognition Categories R and S.
The NRC staff verified that the logic used to determine the appropriate emergency classification level is consistent with the generic EAL scheme development guidance in NEI 99-01, Revision 6. The progression from an Alert to a General Emergency classification level is appropriate and consistent with EAL scheme development guidance.
FA1 - This EAL addresses any loss or any potential loss of either the fuel clad or RCS barrier.
FS1 - This EAL addresses loss or potential loss of any two barriers.
FG1 - This EAL addresses loss of any two barriers and loss or potential loss of the third barrier.
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. The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.
3.5 Recognition Category H - Hazards and Other Conditions Affecting Plant Safety 3.5.1 EAL Set HU1/HA1/HS1 [HU1/HA1/HS1/HG1]
The intent of this EAL set is to ensure that an emergency classification level is declared based upon a security-related event. This EAL set was developed in accordance with the guidance from NRC Bulletin 2005-02, Emergency Preparedness and Response Actions for Security-Based Events, dated July 18, 2005 (ADAMS Accession No. ML051740058), and RIS 2006-12, Endorsement of Nuclear Energy Institute Guidance Enhancements to Emergency Preparedness Programs for Hostile Action, July 19, 2006 (ADAMS Accession No. ML061530290), 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, FPL proposed to not develop EAL HG1, as provided in NEI 99-01, Revision 6.
EAL HG1 of NEI 99-01, Revision 6, addresses a hostile action that results in the loss of physical control of the facility. Such an action can reasonably be expected to exceed EPA early phase PAG exposure levels off-site for more than the immediate site area, which is the criteria for EAL HG7 in NEI 99-01, Revision 6. Therefore, in NEI 99-01, Revision 6, EAL HG1 is bounded by EAL HG7. Additionally, any event that could result in a radiological release in excess of EPA early phase PAGs would be bounded by EALs RG1 [AG1] or RG2 [AG2] in NEI 99-01, Revision 6. The NRC staff verified that the FPL EALs RG1, RG2, and HG7 bound the events addressed by EAL HG1 in NEI 99-01, Revision 6.
The NRC staff also verified that the progression from an Unusual Event to a Site Area Emergency classification level is appropriate and consistent with EAL scheme development guidance.
HU1 - This EAL addresses events that pose a threat to plant personnel or safety system equipment.
HA1 - This EAL addresses the occurrence of a hostile action within the Owner Controlled Area or notification of an aircraft attack threat.
HS1 - This EAL addresses the occurrence of a hostile action within the Protected Area.
The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and ease of upgrading/downgrading for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.
3.5.2 EAL HU2 [HU2]
The intent of this EAL is to ensure that an emergency classification level is declared based upon a seismic event that results in accelerations at the site greater than specified for an operating basis earthquake. This EAL is primarily intended to ensure that key licensee ERO members and OROs are aware of the earthquake magnitude at the site and that post-event damage assessments are promptly implemented. This EAL is considered part of an EAL set containing EALs CA6 and SA9, depending on the operating mode applicable at the time of the event.
Indications of earthquake-induced damage to components containing radioactive materials are bounded by Recognition Category F, as well as EALs RA1, RS1, or 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. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.
3.5.3 EAL HU3 [HU3]
The intent of this EAL is to ensure that an emergency classification level is declared based upon the effects that natural or technological hazard events may have on the facility that are considered to be precursors to a more significant event or condition or have potential impacts that warrant emergency notification to local, State, and Federal authorities. Specific hazards addressed include:
Tornado striking within the protected area; Internal room or area flooding requiring the electrical isolation of a safety system component; Movement of personnel within the protected area that is impeded due to an off-site event involving hazardous materials; A hazardous event that results in on-site conditions that are sufficient to prohibit the plant staff from accessing the site via personal vehicles, and Other site-specific events.
This EAL is primarily intended to ensure that key licensee ERO members and OROs are aware of the hazardous event affecting the site, and post-event damage assessments are promptly implemented. In addition, other site-specific events that may impact the effective implementation of the site emergency plan are considered.
This EAL is considered part of an EAL set containing EALs CA6 and SA9, depending on the operating mode applicable at the time of the event. Indications of hazard-induced damage to components containing radioactive materials are bounded by Recognition Category F, as well as EALs RA1, RS1, or 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. The NRC staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.
3.5.4 EAL HU4 [HU4]
The intent of this EAL is to ensure that an emergency classification level is declared based upon the effect that a fire may have on the facility, which would be indicative of a potential degradation of the level of safety of the plant. This EAL is primarily intended to ensure that key licensee ERO members and OROs are aware of the fire, and post-event damage assessments are promptly implemented. This EAL is considered part of an EAL set containing EALs CA6 and SA9, depending on the operating mode applicable at the time of the event. Indications of a protracted fire involving radioactive materials are bounded by Recognition Category F, as well as EALs 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. The NRC staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.
3.5.5 EAL HA5 [HA5]
The intent of this EAL is to ensure that an emergency classification level is declared based upon the effect that toxic, corrosive, asphyxiating or flammable gases may have on the facility, which precludes or impedes access to equipment necessary to maintain normal plant operation or is required for a normal plant cooldown and shutdown. This EAL is primarily intended to ensure that the licensee ERO is activated to support the control room in removing the impediment to normal access to the affected area or room. Indications of a protracted loss of access to equipment necessary for normal plant operations, cooldown, or shutdown are bounded by Recognition Category F, as well as EALs 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. The NRC staff verified that the numbering, sequencing, and formatting for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.
3.5.6 EAL Set HA6/HS6 [HA6/HS6]
The intent of this EAL set is to ensure that an emergency classification level is declared based upon a control room evacuation with the inability to control critical plant systems remotely.
The NRC staff verified that the progression from an Alert to a Site Area Emergency classification level is appropriate and consistent with EAL scheme development guidance. A General Emergency classification level for this specific accident progression is bounded by Recognition Category F, as well as EAL RG1.
HA6 - This EAL addresses an evacuation of the control room that results in transfer of plant control to alternate locations outside the control room.
HS6 - This EAL addresses an evacuation of the control room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner.
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. The NRC staff verified that the numbering, sequencing, formatting, and ease of upgrading/downgrading for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.
3.5.7 EAL Set HU7/HA7/HS7/HG7 [HU7/HA7/HS7/HG7]
The intent of this EAL set is to provide decision-makers with an escalating emergency classification level path to consider when, in their judgment, entry into the sites emergency plan and mobilization of the licensee ERO and ORO is warranted.
The NRC staff verified that the progression from an Unusual Event to a General Emergency classification level is appropriate and consistent with EAL scheme development guidance.
HU7 - This EAL addresses unanticipated conditions not addressed explicitly elsewhere but, in the judgement of the Emergency Director, warrant declaration of an emergency due to conditions existing that are believed to fall under the emergency classification level description for an Unusual Event.
HA7 - This EAL addresses unanticipated conditions not addressed explicitly elsewhere but, in the judgement of the Emergency Director, warrant declaration of an emergency due to conditions existing that are believed to fall under the emergency classification level description for an Alert.
HS7 - This EAL addresses unanticipated conditions not addressed explicitly elsewhere but, in the judgement of the Emergency Director, warrant declaration of an emergency due to conditions existing that are believed to fall under the emergency classification level description for a Site Area Emergency.
HG7 - This EAL addresses unanticipated conditions not addressed explicitly elsewhere but, in the judgement of the Emergency Director, warrant declaration of an emergency due to conditions existing that are believed to fall under the emergency classification level description for a General Emergency.
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. The NRC staff verified that the numbering, sequencing, formatting, and ease of upgrading/downgrading for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.
3.6 Recognition Category S - System Malfunction 3.6.1 EAL Set SU1/SA1/SS1/SG1 [SU1/SA1/SS1/SG1]
The intent of this EAL set is to ensure that an emergency classification level is declared based upon a loss of available AC power sources to the emergency busses.
The NRC staff reviewed the licensees evaluation and justification for site-specific changes associated with this EAL set and verified that the progression from an Unusual Event to a General Emergency classification level is appropriate and consistent with EAL scheme development guidance.
SU1 - This EAL addresses a prolonged loss of off-site AC power.
SA1 - This EAL describes a significant degradation of off-site and on-site AC power sources such that any additional single failure would result in a loss of all AC power to safety systems.
SS1 - This EAL addresses a loss of all AC power that compromises the performance of all safety systems requiring electric power, including those necessary for emergency core cooling, containment heat removal/pressure control, irradiated fuel heat removal, and the ultimate heat sink.
SG1 - This EAL addresses a prolonged loss of all power sources to AC emergency busses.
For SG1, the licensee proposed an alternate threshold value that was based on the capability to establish long-term reactor coolant system heat removal rather than based solely on a coping time that may no longer lead to the loss of one or more fission product barriers. Because the licensee currently has procedures and equipment to restore core cooling, containment, and spent fuel pool cooling capabilities indefinitely, the NRC staff finds that the proposed threshold values for SG1 are acceptable.
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. The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.
3.6.2 EAL Set SU3/SA3 [SU2/SA2]
The intent of this EAL set is to ensure that an emergency classification level is declared based upon the effect that a loss of available indicators in the control room has on the facility.
The NRC staff verified that the progression from an Unusual Event to an Alert classification level is appropriate and consistent with EAL scheme development guidance. The Site Area Emergency and General Emergency classification levels for this specific accident progression are bounded by Recognition Category F, as well as EALs RS1 and RG1.
SU3 - This EAL addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain safety system parameters from within the control room.
SA3 - This EAL addresses the difficulty associated with monitoring rapidly changing plant conditions during a transient without the ability to obtain safety system parameters from within the control room.
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. The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.
3.6.3 EAL SU4 [SU3]
The intent of this EAL is to ensure that an emergency classification level is declared when RCS activity is greater than technical specification allowable limits. This EAL is primarily intended to ensure that key licensee ERO members are aware of the elevated reactor coolant activity and support the control room in implementation of appropriate response measures. Escalation from this emergency classification level is bounded by Recognition Category F, as well as EALs RA1, 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. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.
3.6.4 EAL SU5 [SU4]
The intent of this EAL is to ensure that an emergency classification level is declared when the plant has indications of RCS leakage. By design, the indications for this EAL are redundant to corresponding indicators for 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. This EAL is primarily intended to ensure that key licensee ERO members are aware of the RCS leakage and support the control room in implementation of appropriate response measures.
Escalation from this emergency classification level is bounded by Recognition Category F, as well as EALs RA1, 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. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.
3.6.5 EAL Set SU6/SA6/SS6 [SU5/SA5/SS5]
The intent of this EAL set is to ensure that an emergency classification level is declared based upon the effect that a failure of the reactor protection system (RPS) may have on the plant.
The NRC staff verified that the progression from an Unusual Event to a Site Area Emergency classification level is appropriate and consistent with EAL scheme development guidance. A General Emergency classification level for this event is bounded by Recognition Category F, as well as EAL RG1.
SU6 - This EAL addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or a subsequent automatic trip is successful in shutting down the reactor.
SA6 - This EAL addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and subsequent operator manual actions taken at the reactor control consoles to shut down the reactor are also unsuccessful.
SS6 - This EAL addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, all subsequent operator actions to manually shut down the reactor are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS.
For the Turkey Point EAL scheme, the licensee chose to add the condition as indicated by reactor power 5 [percent]. In response to a request for information, FPL stated the change was based on the Critical Safety Function Safety Trees Subcriticality Red Path (5 percent), and the Technical Specification power level defining reactor operation. FPL further states that reactor power below 5 percent ensures that the heat load to available heat sinks is below post-trip decay heat level normally accommodated with auxiliary feed water (AFW) flow. FPL also states that this is the intended basis for the [SU5], [SA5], and [SS5] EALs in NEI 99-01, Revision 6. Based on a review of NEI 99-01, Revision 6, and the proposed EAL Set SU6.SA6/SS6, the NRC staff determined that although the basis discussion for SU6 does state that if manual actions are successful in shutting down the reactor that core heat generation will quickly fall to a level within the capability of the plants decay heat removal systems, there is no statement in the SU6 [SU5] basis discussion that specifically supports FPLs assertion that the capacity of AFW is the intended bases for this EAL There is no corresponding statement relative to Turkey Points decay heat removal systems in either SA6 or SS6. Additionally, the Category - System Malfunction EAL category 6, Reactor Trip System (RTS) Failure specifically states, [f]or EAL classification, however, ATWS [Anticipated Transient Without Scram] is intended to mean any scram failure event that does not achieve reactor shutdown. If RTS actuation fails to properly result in reactor shutdown, positive control of reactivity is at risk and could cause a threat to fuel clad, RCS and containment integrity. Thus, NRC staff does not accept the licensees conclusion that 5 percent reactor power is the only condition that is required to indicate a successful reactor trip. However, as noted above, the intent of this EAL set is to declare an event following a failure of the RPS. Because the RPS is designed to place the reactor in a subcritical condition when certain setpoints are exceeded, a failure of the RPS would be indicated by reactor power rising subsequent to reaching or exceeding an RPS setpoint or condition. As such, the NRC staff concludes that the threshold values for this EAL set should be consistent with a subcritical reactor. For EAL SU6, a subcritical reactor would be indicated by reactor power dropping below 5 percent and continuing to lower. For EALs SA6 and SS6, the NRC staff finds that adding the condition that reactor power is 5 percent as an indication that the reactor is not shutdown is acceptable 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. The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.
3.6.6 EAL SU7 [SU6]
The intent of this EAL is to highlight the importance of emergency communications by ensuring that an emergency classification level is declared if normal communication methods for on-site and off-site personnel, or with OROs, including the NRC, are lost. This EAL is primarily intended to ensure that key licensee ERO members, OROs, and the NRC are aware of the loss of communication capabilities, the resources necessary to restore communications are mobilized, and to ensure that compensatory measures are promptly implemented. Considering that a loss of emergency communications capability would not involve an actual or potential substantial degradation to the level of safety of the plant, no escalation path is necessary for this EAL.
The communication methods derived for this EAL are consistent with the overall EAL scheme development guidance.
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. The NRC staff verified that the numbering, sequencing, formatting, and logical progression for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4).
The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.
3.6.7 EAL SU8 [SU7]
The intent of this EAL is to ensure that an emergency classification level is declared when the plant has indications of containment barrier degradation. It also addresses an event that results in high containment pressure with a concurrent failure of containment pressure control systems.
The indications for this EAL are redundant to 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.
This EAL is primarily intended to ensure that key licensee ERO members, OROs, and the NRC are aware of significant challenges to containment integrity and to ensure that compensatory measures are promptly implemented. Escalation is bounded by Recognition Category F, as well as EALs RA1, 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. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns; is technically complete for this emergency classification level; addresses issues regarding completeness and accuracy of Appendix 1 to NUREG-0654 and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.
3.6.8 EAL Set SS2/SG2 [SS8/SG8]
The intent of this EAL set is to ensure that an emergency classification level is declared when a loss of DC power occurs, as this condition compromises the ability of the licensee to monitor and control safety systems.
The NRC staff verified that the progression from a Site Area Emergency to a General Emergency classification level is appropriate and consistent with EAL scheme development guidance.
SS2 - This EAL addresses a loss of vital DC power that compromises the ability to monitor and control safety systems.
SG2 - This EAL addresses a concurrent and prolonged loss of both AC and vital DC power.
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. The NRC staff verified that the numbering, sequencing, formatting, logical progression, ease of upgrading/downgrading, and instrumentation and setpoints for this EAL set are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL set is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for each emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG-0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL set is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL set acceptable.
3.6.9 EAL SA9 [SA9]
The intent of this EAL is to ensure that an emergency classification level is declared when hazardous events lead to potential damage to safety systems needed for the current operating mode. The hazardous events of interest include, but are not limited to, an earthquake, flooding, high winds, tornado strike, explosion, fire, or any other hazard applicable for FPL. This EAL is primarily intended to ensure that the licensee ERO is activated to support the control room in understanding the event impacts and restoring affected safety system equipment to service.
Indications of hazard-induced damage to components containing radioactive materials are bounded by Recognition Category F, as well as EALs RS1 and RG1.
As described in NEI 99-01, Revision 6, an Alert classification level exists when events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant. Any releases are expected to be limited to small fractions of the EPA early phase PAG exposure levels. The guidance in NEI 99-01, Revision 6, is intended to ensure that an Alert classification level should be declared only when an actual or potential substantial degradation of the level of safety of the plant has occurred because of a hazardous event. However, there may be cases where a hazardous event only causes damage to a single safety system component or a single safety system train. Additionally, an Alert classification level should not be declared if the damage from the hazardous event is limited to a safety system component or a safety system train that was inoperable or out of service prior to the event occurring.
The licensee proposed that an Alert classification level be declared when a hazardous event results in indications of degraded performance to one train of a safety system with either indications of degraded performance on a second safety system train or visible damage to a second safety system train, such that the operability or reliability of the second safety system train is a concern. Although different from the guidance in NEI 99 01, Revision 6, this change is consistent with the intent of NEI 99 01, Revision 6, which is intended to ensure that an Alert classification level should be declared only when an actual or potential substantial degradation of the level of safety of the plant has occurred due to a hazardous event.
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. The NRC staff verified that the numbering, sequencing, formatting, logical progression, and instrumentation and setpoints for this EAL are consistent with the overall EAL scheme development guidance and address the site-specific implementation strategies provided and are, therefore, consistent with a standard EAL scheme, as required by 10 CFR 50.47(b)(4). The NRC staff also verified that the EAL is worded in an unambiguous manner that addresses human factors engineering and user-friendliness concerns, is technically complete for this emergency classification level, addresses issues regarding completeness and accuracy raised in Appendix 1 to NUREG 0654, and uses objective and observable values based on site-specific indications.
Based on the above, the NRC staff concludes that the site-specific implementation method for this EAL is consistent with the key characteristics of an effective EAL scheme (identified in Section 2.3 above) and meets the requirements of 10 CFR 50.47(b)(4) and Section IV.B of Appendix E to 10 CFR Part 50. Therefore, the NRC staff finds this EAL acceptable.
3.7 Review Summary The NRC staff reviewed the technical bases for the proposed EAL scheme; the modifications from NEI 99-01, Revision 6, and the licensees 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, to adopt a format that is better aligned with how it currently implements its EALs, as well as with site-specific writers guides and preferences. The NRC staff verified that these modifications do not alter the intent of any specific EAL within a set, recognition category, or within the entire EAL scheme described in NEI 99-01, Revision 6.
Thus, the proposed changes meet the requirements in Appendix E to 10 CFR Part 50 and planning standard 10 CFR 50.47(b)(4).
The NRC staff 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 determined that the proposed EAL scheme is technically complete and consistent with EAL schemes implemented at similarly designed plants.
The NRC staff verified that the instrumentation and setpoints derived for this proposed EAL scheme are consistent with the overall EAL scheme development guidance, address the site-specific implementation strategies provided, and are consistent with a standard EAL scheme.
Based on its review, the NRC staff finds that the licensees proposed EAL scheme is acceptable and provides reasonable assurance that the licensee can and will take adequate protective measures in the event of a radiological emergency. Specifically, the staff concludes that the licensees proposed EAL scheme and site-specific EAL technical basis document provided by letter dated December 6, 2019, as supplemented by letter dated June 8, 2020, is acceptable for implementation.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the NRC staff notified the State of Florida official (Ms. Cynthia Becker, M.P.H., Chief of the Bureau of Radiation Control, Florida Department of Health) on July 15, 2020, of the proposed issuance of the amendments. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 because the amendment approves an acceptable EAL scheme that is required for operation of the facility.
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 off-site, 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 in the Federal Register on December 31, 2019 (84 FR 72388). 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 aforementioned considerations, that the change (1) continues to meet the requirements in Appendix E to 10 CFR Part 50 and the planning standards of 10 CFR 50.47(b); and (2) continues to provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.
The Commission has further concluded, based on the consideration discussed above, that: (1) there is reasonable assurance 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 Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
7.0 REFERENCES
- 1.
Florida Power & Light Company letter to U.S. Nuclear Regulatory Commission, License Amendment Request 264, Adopt Emergency Action Level (EAL) Scheme Described in NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors, dated December 6, 2019 (ADAMS Accession No. ML19343A371 [Package]).
- 2.
Florida Power & Light Company letter to U.S. Nuclear Regulatory Commission, Response to Request for Additional Information Regarding License Amendment Request 264, Adopt Emergency Action Level (EAL) Scheme Described in NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactor, dated June 8, 2020 (ADAMS Accession No. ML20160A463).
- 3.
U.S. Nuclear Regulatory Commission, letter to Ms. Susan Perkins-Grew, Nuclear Energy Institute, U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99 01, Revision 6, dated November 2012 (TAC No. D92368), dated March 28, 2013 (ADAMS Accession No. ML12346A463).
- 4.
U.S. Nuclear Regulatory Commission, Generic Letter 79-50, dated October 10, 1979 (ADAMS Accession No. ML031320278).
- 5.
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, dated November 1980 (ADAMS Accession No. ML040420012).
- 6.
U.S. Nuclear Regulatory Commission, Emergency Planning and Preparedness for Nuclear Power Reactors, Regulatory Guide 1.101, Revision 2, dated October 1981 (ADAMS Accession No. ML090440294); Revision 3, dated August 1992 (ADAMS Accession No. ML003740302); and Revision 4, dated July 2003 (ADAMS Accession No. ML032020276).
- 7.
NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, dated November 2012 (ADAMS Package Accession No. ML13091A209).
- 8.
U.S. Nuclear Regulatory Commission, Regulatory Issue Summary 2003-18, Use of NEI 99-01, Methodology for Development of Emergency Action Levels, Revision 4, dated January 2003, dated October 8, 2003, including Supplement 1, dated July 13, 2004, and Supplement 2, dated December 12, 2005 (ADAMS Accession Nos. ML032580518, ML041550395, and ML051450482, respectively).
- 9.
U.S. Environmental Protection Agency, PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incidents, dated January 2017 (ADAMS Accession No. ML17044A073).
- 10.
U.S. Nuclear Regulatory Commission, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Effective Immediately), dated March 12, 2012 (ADAMS Accession No. ML12056A044).
- 11.
U.S. Nuclear Regulatory Commission,Bulletin 2005-02, Emergency Preparedness and Response Actions for Security-Based Events, dated July 18, 2005 (ADAMS Accession No. ML051740058).
- 12.
U.S. Nuclear Regulatory Commission, Regulatory Issue Summary 2006-12, Endorsement of Nuclear Energy Institute Guidance, Enhancements to Emergency Preparedness Programs for Hostile Action, dated July 19, 2006 (ADAMS Accession No. ML061530290).
Principal Contributor:
R. Hoffman, NSIR Date: January 27, 2021
- by memorandum
- by e-mail OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LA*
NSIR/DPR/RLB/BC**
OGC - NLO**
NAME EBrown BAbeywickrama JAnderson MYoung DATE 08/13/2020 08/10/2020 06/23/2020 12/21/2020 OFFICE NRR/DORL/LPL2-2/BC* NRR/DORL/D NRR/OD*
NAME UShoop CErlanger HNieh (CErlanger for)
DATE 01/22/2021 01/26/2021 01/27/2021