ML20217D306

SER Accepting Licensee Proposed Changes to Edwin I Hatch Nuclear Plant Emergency Classification Scheme to Add Emergency Action Levels Related to Operation of Independent Spent Fuel Storage Installation

ML20217D306
Person / Time
Site:	Hatch
Issue date:	10/13/1999
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20217D294	List: ML20217D290 ML20217D306
References
NUDOCS 9910150113
Download: ML20217D306 (5)

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~k" UNITED STATES NUCLEAR REGULATORY COMMISSION f WASHINGTON. D.C. 2056H001

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION PROPOSED CHANGES FOR SOUTHERN NUCLEAR OPERATING COMPANY EDWIN 1. HATCH NUCLEAR PLANT EMERGENCY ACTION LEVELS DOCKET NOS 50-321 AND 50-366

1.0 INTRODUCTION

This safety evaluation addresses proposed changes to the Edwin I. Hatch Nuclear Plant (Hatch) emergency classification scheme to add emergency action levels (EAL ) related to the

- operation of its Independent Spent Fuel Storags Installation (ISFSI). These proposed EALs were submitted to the NRC by Southem Nuclear Operating Company (the licensee) in a letter dated March 5,1999. The licensee provided additionalinformation supporting their proposed EALs in a letter dated August 20,1999.

2.0 APPLICABLE REGULATIONS AND GUIDANCE

= 2.1 Regulations Title 10 of the Code of Federal Regulations (10 CFR) Section 72.32 contains emergency planning requirements for ISFSis. Subsection ~(c) of 10 CFR 72.32 states that "For an ISFSI that is: (1) located on the site, or (2) located within the exclusion area as defined in 10 CFR

, Part 100, of a nuclear ~ power reactor licensed for operation by the Commission, the emergency plan required by 10 CFR 50.47 shall be deemed to satisfy the rcquirements of this section."

Section 50.47(b)(4) states, in part: "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..." -

- Part 50,~ Appendix E,Section IV.B states, in part: "These emergency action levels shall be discussed and agreed on by the applicant and State and local governmental authorities and

. approved by the NRC."

' Appendix E, Subsection' IV.C to 10 CFR Part 50, states, in part: " Emergency action levels

- (based _not only on onsite and offsite radiation monitoring information but also on readings from m a number of sensors that indicate a potential emergency, such as pressure in the containment and response of the Emergency Core Cooling System) for notification of offsite agencies shall be described. ... The emergency classes defined shall include (1) notification of unusual events, (2) alert,- (3) site area emergency, and (4) general emergency."

l 9910150113 991013 PDR ADOCK 05000321 P PH ,

2.2 Guidance Documents Regulatory Guide 1.101, " Emergency Planning and Preparedness for Nuclear Power Reactors,"

Revision 2, states, in part: "The criteria and recommendations contained in Revision 1 of NUREG-0654/ FEMA-REP-1 are considered by the NRC staff to be acceptable methods for complying with the standards in 10 CFR 50.47 that must be met in on-site and off-site emergency response plans."

NUREG-0654/ FEMA REP-1, Rev 1,"C Mria for Preparation and Evaluation of Radiolog: cal Emergency Response Plans and Prepaw ess in Suppert of Nuclear Power Plants," includes the following criteria for EALs:

Section ll.D.1 An emergency classification and emergency action level scheme as set forth in Appendix 1 must be established by the l'censee.

i Section ll.D.2 The initiating conditions shall include the example conditions found in Appendix 1 [of NUREG-0654] . .

Regulatory Guide 1.101, Revision 3, endorsed NUMARC/NESP-007, " Methodology for Development of Emergency Action Levels," as an acceptable alternative to NUREG-0654 for developing EAL schemes. NUMARC/NESP-007 is currently being revised by the Nuclear Energy institute (NEI). The proposed revision (NEl 99-01) includes new EAL guidance for ISFSis. A revision of Regulatory Guide 1.101 which endorses NEl 99-01 is currently under development by the NRC.

NUREG-1140,"A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees,"is an NRC evaluation of the spectrum of potential accidents (and the potential consequences of these accidents) at an ISFSI.

NUREG-1567," Standard Review Plan for Spent Fuel Dry Storage Facilities, Draft Report for Comment," provides guidance for reviewing EALs for an ISFSI emergency plan which meets the requirements of 10 CFR 72.32(a). Note: the Hatch nuclear power plant emergency plan is utilized for accidents which may occur at its ISFSI (as allowed in 10 CFR 72.32(c)). Therefore, NUREG-1567 is not completely applicab!s to the Hatch emergency plan'.

3.0 _ EVALUATION The staff utilized the following criteria for determining the acceptability of the licensee's EALs for its ISFSI:

' For example,10 CFR 72.32(a) (concerning ISFSI emergency plans) specifies that EnLs be provided for classifying events as Alerts. However, Appendix E to 10 CFR Part 50 (concerning operating plan emergency plans) specifies that EALs be provided for classifying events et four classification levels depending on the seriousness of the event. The NUREG-1567 definition of (and emergency response actions associated with\the Alert classification for an ISFSI-specific emergency plan is different than that for an operating plant emergency plan.

Those differences were considered in the evaluation of the Hatch EALs.

i (1) EALs were provided for initiating emergency classification for the spectrum of accidents considered possible at the ISFSI.

(2) The classification level (e.g., Notification of Unusual Event ) af the EALs is appropriate. The level of degradation of safety of the plant, as reflected in the EAL, is consistent with the classification level.

(3)  : The new EALs have been integrated into the existing EAL scheme.

The staff also utilized guidance on EALs for ISFSis contained in NEl 99-01 and NUREG 1567 in its review. The staff evaluation of each of the licensee's ISFSI EALs is described below:

3.1 EAL 17.1 - Loss-of Confinement Boundary Hatch EAL 17.1 reads as follows:

Loss of cask confinement boundarv for any loaded soent fuel cask A Notification of Unusual Event exists when:

Direct Padiation levels outside the Independent Spent Fuel Storage Installation (ISFSI) protected area boundary exceed:

2 mrem in an hour AND Contamination levels outside the ISFSI protected area bounda ) exceed the technical specification limits for spent fuel r,torage cask surface contamination OR Direct Radiation Readings for a Loaded Spent Fuel Cask exceed the technical specification limit for overpack average surface dose rates The licensee's EAL utilizes abnormal radiation readings as indication that an event representing a potential degradation in safety has occurred at the ISFSI. The staff concludes that use of radiation readings above technical specification limits is appropriate for classifying events at the ISFSI. Therefore, the staff concludes that a Notification of Unusual Event classification is ,

appropriate.

' 3.2 EAL 17.2. -- Operational Events Hatch EAL'17.2 reads as follows:

Dearadation of ans Soont Fuel Cask due to an operational event i Direct obsesvation of a loaded spent fuel cask indicates cask confinement boundary or shielding damage due to an operational event

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- Cask handling

- Cask drop

- Cask tip-over AND ISupervisor On Shift / Emergency Director) SOS /ED judgement The licenses included EALs which represent mishandling of the cask which may result in the release of radioactive material due to damage of the cask confinement boundary. The caski.,

are designed to prevent confinement boundary damage in case of mishandling. However, if damage were to occur, this event represents a potential degradation in the level of safety of the plant. Therefore, the staff concludes that a Notification of Unusual Event classification is appropriate.

3.3 EAL 17.3 -- Environmental Phenomena or External Events Hatch EAL 17.3 reads as follows:

Degradation of any spent fuel cask due to environmental phenomena or external events Direct observation of a loaded spent fuel cask indicates cask confinement boundary or shielding damage due to environmental phenomena or external events

)

• Tornado

• Lightning 1

• Flooding j

• Earthquake  !

• Extreme environmental temperatures

• Burial under debris

• Fire

• Explosion  ;

• Aircraft Crash l

• Missile or projectile impact

• Security event AND SOS /ED judgement The licensee included EALs for environmental phenomena or external events which damage the cask confinement boundary. The casks are designed to prevent confinement boundary damage due to these type of events. However, if an even, vi ....a nutwe aid cause cask confinement damage it would represent a potential degradation in the level of safety of the plant. Therefore, the staff concludes that a Notification of Unusual Event classification is approprate.

.. o 3.4I Classification Level and Integration into Existing EAL Scheme The licensee stated that the postulated worst-case accident involving an ISFSI has insignificant consequences to the public health and safety and that no release of radioactive material requiring offsite respanse or monitoring is anticipated. Therefore the licensee's EALs specific

to operations and hazards at its ISFSI are limited to the Notification of Unusual Event classification level. Hawever, the existing EAL scheme does include EALs (e.g., release of radioactive material or emergency director judgement) at higher emergency classification levels which would also apply to events at the ISFSI.

The staff concludes that the ISFSI specific EALs classified at the Notification of Unusual Event level are adequate to cover postulated accidents at the ISFSt.

The licensee created a new section (Section 17) to Table D.1 for EALs specific to ISFSI L operations. Table D.1 containe all the licensee's EALs classified at the Notification of Unusual

- Event classification level.

The staff concludes that this is an acceptable manner for integrating the new EALs into the existing EAL scheme.

4.0 STATE AND LOCAL GOVERNMENTAL AGREEMENT

. In its March 5,1999, letter, the licensee stated that these proposed EALs were discussed and agreed upon by the licensee and State and local governmental a'uthorities as required by 10 CFR Part 50, Appendix E, Section IV.B.

5.0 CONCLUSION

The staff concludes that the EALs proposed for the Hatch ISFSI are adequate to classify

- potential events at the ISFSI. Furthermore, the staff concludes that the Hatch ISFSI EALs are  !

appropriately classified at the Notification of an Unusual Event level and have been

. appropriately integrated into the Hatch EAL scheme. Therefore, the staff concludes that the f

q proposed revised EAL scheme meets the requirements of 10 CFR 50.47(b)(4) and Appendix E  !

" to 10 CFR Part 50. i l

Principal Contributor: "J. O'Brien Date: October.13, 1999 -

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