ML20238F213
| ML20238F213 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 08/28/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20238F201 | List: |
| References | |
| NUDOCS 9809030195 | |
| Download: ML20238F213 (7) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION If WASHINGTON, D.C. 206fWo001 s...../ i SAFETY EVALUATION REPORT BY THE QFFICE OF NUCLEAR REACTOR REGULATION OF THE DEFUELED EMERGENCY PLAN FOR EMERGENCY PLANNING FOR CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT DOCKET NO. 50-213
1.0 INTRODUCTION
By letter dated December 5,1996, Connecticut Yankee Atomic Power Company (CYAPCO) submitted written certifications that the Board of Directors of CYAPCO (or the licensee) had decided to permanently cease operation at the Haddam Neck Plant (HNP) and that fuel had been permanently removed from the reac.or.
By letter dated May 30,1997, CYAPCO requested an exemption from the provision of 10 CFR 50.54(q) that requires emergency plans to meet all of the standards of 10 CFR 50.47(b) and all of the requirements of Appendix E to Part 50, on the basis that the permanently shutdown and defueled condition of the HNP had substantially reduced the risk to public health and safety. Because the licensee's proposed Defueled Emergency Plan would not meet some of the standards and requirements noted in 10 CFR 50.47(b) and Appendix E to Part 50, the exemption was required in order for the DEP to maintain compliance with the regulation.
2.0 BACKGROUND
By letter dated May 30,1997, the licensee submitted its proposed Defueled Emergency Plan (DEP) for NRC approval. The DEP proposed to discontinue offsite emergency planning activities and reduce the scope of orisite emergency planning, which reflected the shut-down and defueled status of the plant, and took into account the requested exemption. On September 19,1997, the licensee submitted the Emergency Action Levels it proposed to use with the DEP. By letter dated September 26,1997, the licensee submitted the results of an assessment of the HNP with respect to a beyond-design-basis event of a loss of all water in the spent fuel pool. As the result of a meeting with the NRC held on October 1, l 1997, the licensee submitted additional information by letter dated October 21,1997, on
! certain aspects of the DEP and identified those specific standards and requirements that the proposed DEP would no longer meet. CYAPCO submitted a letter dated December 18,
< 1997, which gave additionalinformation with respect to the proposed DEP for the HNP. 1 Following conference calls on December 23,1997, and January 8,1998, the licensee .
submitted additional information in letters dated January 22, March 25, June 19, and
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2 July 31,1998. Tables 1 and 2 of Attachment 2 to the licensee's March 25,1998, letter i
revised and consolidated the standards and requirements of 10 CFR 50.47(b) and Appendix l E to Part 50 that still apply to the DEP. I With the plant in a permanently shutdown and defueled condition, the two postulated events that could occur are resin handling and fuel handling accidents. With the exception of Kr-85, the noble gas nuclides that contribute to a whole-body dose have decayed to a negligible amount. CYAPCO calculated resin handling and fuel handling accident doses and concluded that doses at the Exclusion Area Boundary and the Low Population Zone are a small fraction of the 10 CFR 100 dose limits and, therefore, would not pose any threat to the health and safety of the public. The calculated doses would not exceed the Environmental Protection Agency (EPA) Protective Action Guides (PAGs). Since the resin handling and fuel handling events cannot lead to the release of radioactive materials beyond the current Exclusion Area Boundary in quantities that would require any offsite Federal, State, or local plume exposure protective actions, an Alert is the highest attainable emergency classification level appropriate to the HNP in the permanently shutdown and defueled condition. The present HNP Emergency Plan contains requirements in excess of those necessary to support emergency preparedness at the plant in a permanently shutdown and defueled condition and does not address changes that would be allowed on the basis of the proposed exemption.
The staff used the same acceptance criteria for its review of the DEP as are used to evaluate the adequacy of onsite emergency plans for operating nuclear power reactors, taking into consideration the current shutdown status of the HNP and reflecting incorporation of the proposed exemption. The acceptance criteria include the planning ,
standards of 10 CFR 50.47(b), the requirements of Appendix E to 10 CFR Part 50, the guidance criteria of NUREG-0654/ FEMA-REP-1, " Criteria for the Preparation and Evaluation
- of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, dated November 1980, and the guidance contained in NUMARC/NESP-007, Wiethodology for Development of Emergency Action Levels," Revision 2, dated January 1992.
l For any potential offsite impacts, the staff reviewed the DEP using the standards of 10 CFR 50.47(d), which state the requirements for a license authorizing fuel loading and low power testirg only. In 10 CFR 50.47(d), the staff recognizes the smaller risk associated with low-power operation and the staff considers the standards to be generally appropriate for reviewing the offsite aspects of the DEP.
3.0 DISCUSSION AND STAFF EVALUATION OF THE DEP 3.1 Radiological Consequences l The staff reviewed the licensee's analysis, including calculations CYRESIN-01578-RY, "Haddam Neck - Radiological Consequences From a Resin Accident
- and RAB98-01620-RY, " Scatter Dose Rates Due to CY Spent Fuel Pool Draindown," Revision 2, to verify that the licensee demonstrated the acceptability of changes to its emergency plan (EP) using
3 appropriate methods with sufficiently conservative assumptions and input parameters.
These two postulated accidents bound the possible accidents that could have an impact on an individual off site through the airborne release of radioactive materials or from direct radiation, respectively.
3.1.1 Resin Fire Decontamination of systems during decommissioning and dismantlement operations is expected to generate significant radioactive waste in the form of contaminated demineralized resins. A fire in a fully loaded resin liner could serve as a motive force for the release and transport of airborne radioactivity off site. Resins are collected and de-watered on site in containers called liners before being transported off site for disposal Using a release fraction of 1 percent, the licensee calculated that a fire in a resin liner loaded with the maximum activity allowed would result in a maximum offsite dose of 0.96 rem. The release fraction is consistent with the release fractions listed in Schedule C to 10 CFR 30.72, for mixed fission and corrosion products. The calculational methods and assumptions used in this analysis are acceptable to the staff.
3.1.2 Fuel Pool Draindown Although the fuel on site has decayed for a minimum of 2 years, a significant amount of radioactivity remains in the spent fuel poolin the form of spent fuel assemblies. Water and the concrete pool structure provide radiation shielding on the sides of the pool. However, j water alone provides most of the shielding above the spent fuel. A loss of shielding above !
the fuel could increase the radiation levels off site from the gamma rays streaming up out )
of the pool being scattered back to a receptor at the site boundary. The licensee calculated the offsite radiological impact of a postulated complete loss of spent fuel pool water. The radioactive inventory in the spent fuel was calculated with the computer code ORIGEN2.
The computer code QAD was used to adjust this source term for self-shielding by the mass of the fuel. Finally, the licensee used the GGG-F code to calculate that the dose to the
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nearest residence is 0.016 rem per hour. ORIGEN2, QAD, and GGG-F are widely used in '
the radiation-shielding industry and are acceptable to the staff.
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The licensee's calculated dose rate indicates it would take 2.6 days for this event to exceed the EPA early-phase PAG of 1 rem. The PAGs were developed to respond to a mobile airborne plume that could transport and deposit radioactive material over a large area. In contrast, the radiation field formed by the scatter from a drained spent fuel pool (SFP) would be stationary, rather than moving, and would not cause the transport or deposition of radioactive materials. The 2.6-day period available for action allows sufficient time to develop and implement mitigative actions and provides confidence that additional offsite measures could be taken without preplanning if efforts to reestablish shielding over the fuel are delayed. I 1
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- 3.1.3 EueLBeatup The licensee analyzed the heatup characteristics of the spent fuelin the absence of SFP i water, when cooling depends on the natural circulation of air through the spent fuel racks.
I By letter dated September 26,1997, the licensee presented the results of an analysis showing that as of October 1,1997, decay heat could not heat the spent fuel cladding i above 538 C, in the event that all water ~was drained from the SFP. The licensee's heat up analysis was based on a particular configuration of the spent fuelin the SFP. By letter I
dated December 18,1997, the licensee stated, that as of October 23,1997, the spent fuel l had been moved into a configuration consistent with the analysis. The staff evaluated the l- licensee's analysis by performing heat-up calculations using computer codes validated to be
! accurate to within 15 *C of actual peak fuel cladding temperatures. The licensee's value l for peak fuel cladding temperature was found to be acceptable. On the basis of an earlier
- staff determination that fuel cladding will remain intact if its temperature remains below
, 565 *C, the staff concludes that it is no longer possible for a complete loss of water from
! the Haddam Neck SFP to result in a release off site that exceeds the early-phase EPA l PAGs.
l 3.2 Assionment of Responsibility (Organizational Control)
The DEP describes the on-shift and augmented organizations that are intended to be part of the overall response organization in the event of an emergency at the HNP. The plan
- identifies by title a specific individual who is in charge of emergency response and contains l 24-hour-a-day coverage. in support of the normal shift organization, CYAPCO maintains the capability to provide corporate support, including senior personnel, facilities, equipment, and financial resources. Local agency and support services are identified, and copies of letters of agreement list support organization responsibilities and arrangements.
l 3.3 Onsite Emeroenev Organization l
The DEP describes the normal plant organization, the Defueled Emergency Response Organization (DERO), and the augmented organization covering the Technical Support Center (TSC) and the control room. The licensee has described each of the emergency response positions. The plan identifies the Emergency Director's (ED's) responsibilities, including emergency classification, offsite notifications, command and control, and authorization of onsite protective actions. The augmentation ED has a response goal of 60 minutes from notification of an event. The four additional DERO positions have a 120-minute response goal from the time of an Alert classification.
3.4 Etneroenev Resoonse Suocort and Resources CYAPCO has arrangements in place with local support agencies for ambulance services, hospital facilities, fire fighting assistance, and radiological laboratories. Letters of agreement are found in Appendix B to the DEP.
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3.5 Emeraenev Classification System Appendix F to the DEP contains an emergency classification and emergency action level (EAL) scheme, including initiating conditions associated with possible events at the HNP which would result in the declaration of a Notification of Unusual Event (NOUE) or an Alert.
Specific instruments, parameters, and equipment conditions are detailed in plant procedure DEPIP 1.5-1, " Emergency Assessment Using Defueled EAL Tables." CYAPCO has reached I agreement with appropriate State and local governmental authorities on the EALs. The staff has reviewed the EALs and determined that they are acceptable when compared to the applicable standards considering the defueled condition and shutdown status of the facility. ;
l 3.6 Notification Methods and Procedures l
The DEP specifies that the State of Connecticut and the NRC will be notified within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 1 of an emergency classification. Simultaneous notification of State and site augmentation personnel is outlined. The content of notification messages is specified, and provisions are i made for verification of notifications.
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3.7 Emeroency Communications l
1 The DEP specifies that a radio pager is used for prompt notification of the DERO and offsite j authorities. Backup communications are available using commercial telephone lines, i company tie-line telephones, and radios. Two-way radios are available in the plant between the control room and in-plant teams. A public address system is also available in the plant to link the TSC, control room, and in-plant teams. The NRC will be notified via the emergency notification system. Communication with fixed and mobile medical support facilities is described.
3.8 Public Education and information Under the DEP, the Public Information Coordinator is responsible for preparing and transmitting news releases. A media information program is provided for annually.
3.9 Emergencv Facilities and Eauioment The DEP identifies the control room and Technical Support Center (TSC) as the onsite emergency response facilities. Arrangements have been made to accommodate offsite officials at the TSC. The HNP has various appropriate monitoring systems as needed for evaluating the condition of plant systems, meteorological conditions, seismic activity, and radioactive materials. The provisions for, and the maintenance of, emergency equipment and supplies are established.
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6 3.10 Accident Assessment
, The DEP calls for onsite systems and equipment to allow for radiological accident t
- monitoring . and assessment of radiological conditions, and the performance of dose projections.
'3.11 Protective Resoonse
- The DEP outlines protective actions to be taken on site to warn personnel of hazard conditions, call for the relocation of onsite staff when ne::essary, maintain accountability of emergency responders, and limit site access when needed. The DEP has a goal to
- complete accountability of onsite personnel within 60 minutes.
-3.12 Radiological Exoosure Control in the DEP, the Radiation Assessment Coordinator (RAC) is responsible for onsite emergency radiological protection activities for plant staff and support personnel. ' Exposure ;
limits and authorization authority for exceeding limits are' defined. Contamination control measures and provision for decontamination are established.
. 3'.13 Medical and First Aid Suonort First aid and other medical supplies are provided for at the plant. Shift personnel trained in first aid are available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. The DEP contains arrangements for transportation to offsite medical facilities; two hospitals are identified for the treatment of potentially contaminated injured individuals.
3.14 - Recovery and Reentry Plannino The DEP contains general criteria for determining when to establish recovery operations. I The plan identifies the appropriate authority by position and title for initiating recovery actions.
3.15 . Exercises and Drills The DEP specifies that an annual exercise of the DEP will be conducted. The DEF also calls for an annual medical drill and an annual health physics drill. The plan allows for testing of the site relocation alarm weekly. Communication links to the State of Connecticut and the NRC are tested monthly. Quarterly tests of onsite radios and telephones are specified and include keeping phone numbers current.
3.16 Radiological Emeroency Resoonse Trainino The DEP maintains a training program to ensure that personnel assigned to the emergency response organizations are' trained prior to assuming any emergency plan responsibilities and retrained annually. The program covers basic as well as specialized training for those emergency response personnel with specific assignments. Training for participating offsite agency personnel involved in emergency response is made available annually. HNP first aid responders receive first aid training equivalent to the Red Cross Multimedia first aid program.
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3.17 Plan Development and Review l
l The requirement for an annual review of the DEP, procedures, practices, training, equipment, readiness testing, drills and exercises, letters of agreement, and adequacy of interface with offsite officials,is specified in the plan. An annualindependent audit of the DEP is also to be conducted. Responsibilities for maintaining the emergency response 4 i
facilities, plans and procedures, staffing the emergency response organization, and training l l of responders are specified in the DEP.
4.0 CONCLUSION
S The staff concludes that the licensee's proposal to discontinue offsite emergency planning activities and reduce the scope of onsite emergency planning is acceptable in view of the greatly reduced offsite radiological consequences associated with the current state of the plant, and consistent with CYAPCO's requested exemption. The staff found acceptable the licensee's findings that, in its defueled condition, a radiological accident would not result in a dose in excess of the EPA early-phase PAG (1 rem) to any individual located off site.
The licensee's proposed Defueled Emergency Plan has been reviewed by the staff against the planning standards in 10 CFR 50.47(b), as described in Tables 1 and 2 of Attachment 2 to the licensee's letter dated March 25,1998, the planning standards in 10 CFR 50.47(d),
the requirements of Appendix E to 10 CFR 50, as described in Tables 1 and 2 of Attachment 2 to the licensee's letter dated March 25,1998, the acceptance criteria in NUREG-0654/ FEMA-REP-1, Revision 1, and the guidance contained in NUMARC/NESP-007, Revision 2. The staff review took into consideration the shutdown and defueled status of the facility, the configuration of the stored fuel, and the length of time since power operation.
The staff concludes that the HNP Defueled Emergency Plan provides for an acceptable level of emergency preparedness at the HNP in its shutdown and defueled condition, and also i provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at HNP.
Principal Contributors: Daniel M. Barss Roger L. Pedersen Diane T. Jackson Date: August 28, 1998 l
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