NLS2005006, Change to Emergency Plan Implementing Procedure
| ML050320163 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 01/28/2005 |
| From: | Edington R Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| +sispmjr200508, NLS2005006 | |
| Download: ML050320163 (7) | |
Text
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- : a s ILIvL INFORATIO
Nebraska Public Power District Always there when you need us 50.54(q)
NLS2005006 January 28, 2005 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
Change to Emergency Plan Implementing Procedure Cooper Nuclear Station, NRC Docket 50-298, DPR-46 The purpose of this letter is to request approval of a change to the Cooper Nuclear Station (CNS)
Emergency Plan Implementing Procedure 5.7.1 in accordance with the requirements of 10 CFR 50.54(q). The change page is provided in the enclosure to this letter. The change involves deleting the example in Emergency Action Level (EAL) 1.1.2 of "MPF BLDG VENT HI-HI RAD" and removing the statement, "The MPF is not calculated in the Combined Effluent Monitor display" from the memo field. The text for the EAL and the CNS Emergency Plan are not modified by this change.
The Multi-Purpose Facility (MPF) at CNS houses decontamination and support equipment used in the maintenance and repair of plant components. Hot machine shop activities are also performed in this facility. The MPF Ventilation Radiation Monitoring System monitors any gaseous releases from the MPF to the atmosphere.
The existing Kaman monitor (RV-RM-10), located on the mezzanine level of the MPF, provides effluent monitoring for activities in the facility. Particulates, iodine and noble gases are monitored. The monitor has been experiencing operational problems due to obsolete equipment and associated spare parts being no longer available.
A pending design change will replace the current system with redundant continuous air monitors (CAM) that will continue to monitor particulate and iodine but not noble gases. Noble gases cannot be generated by any activities within the MPF nor are there any sources that pass through the MPF area that would discharge into the area as the result of an accident. There are no plans to add such a source to the MPF area. The new CAM will provide increased reliability.
The modification is consistent with the effluent monitoring requirements of the CNS Offsite Dose Assessment Manual (ODAM). Table D 3.3.2-1, "Radioactive Gaseous Effluent Monitoring Instrumentation," of that manual does not require a noble gas activity monitor for the MPF. ODAM Table 3-1, "Atmospheric Gaseous Release Points at the Cooper Nuclear Generating Station," does not include the MPF as a gaseous effluent release pathway.
COOPERNUCLEARSTATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811/ Fax: (402) 825-5211 www nppd corn
NLS2005006 Page 2 of 2 The proposed change does not impact the CNS Emergency Plan. Section 4.2 lists the monitored release pathways for off-site radiological assessment as the Elevated Release Point, Turbine Building Vent, Reactor Building Vent and Radwaste/Augmented Radwaste Building Vents. The MPF building vent is not included in the CNS Dose Assessment program and is not a post-accident monitored release point.
The MPF Ventilation Radiation Monitoring System does not directly interface with any systems, structures or components that are accident initiators or credited with mitigation of any accidents described in Chapter XIV of the Updated Safety Analysis Report. The MPF monitor has no control function.
This change is evaluated as a decrease in effectiveness because it excludes an event that is currently classified as a Notification of Unusual Event. The proposed change will not adversely affect the design basis functions of the MPF Ventilation Radiation Monitoring System or the station's ability to meet ODAM requirements. The proposed change does not adversely affect the health and safety of the public as the MPF is not considered a release pathway for noble gas effluents. The states of Nebraska and Missouri are in agreement with this change. The station's on-site and off-site review committees have approved the change.
Should you have any questions concerning this submittal, please contact Mr. Paul Fleming at (402) 825-2774.
Sincerely, Randall K. Edington Vice President - Nuclear and Chief Nuclear Officer
/jrs Enclosure cc: Regional Administrator w/enclosure USNRC - Region IV Senior Project Manager W/enclosure USNRC - NRR Project Directorate IV-1 Senior Resident Inspector w/enclosure USNRC NPG Distribution w/o enclosure to NLS2005006 Page 1 of3 CHANGE PAGE TO ATTACHMENT 2 OF PROCEDURE 5.7.1
I ATTACHMIENT 2 EMERGENCY ACTION LEVELS CLASSIFICATION EAL: 1.1.2 NOUE TEXT Off-Site Dose Assessment Manual (OD.AM) limits exceeded as indicated by either HIGH-HIGH alarm on a gaseous effluent radiological monitor OR Combined Effluent Monitor indication on SPDS which cannot be cleared within 30 minutes.
APPLICABILITY ALL EXAM PLE Any one of the following annunciators/SPDS indications is received AND release is verified, but not brought below ODAM limits within 30 minutes:
- RX BLDG VENT HI-HI RAD.
- ERP DISCHARGE HI-HI RAD.
- TG BLDG VENT HI-HI RAD.
- RW/ARWN VrENT HI-HI RAD.
-MDPF B LD 1'T III-IIIIT41-RAD.
MEMO Alarms should be validated prior to making classification. If any valid alarm cannot be cleared within 30 minutes, the EAL is met.
The Combined Effluent Monitor on SPDS is a sum of the fractions of the release rate/ODAM limit for the Reactor Building, Elevated Release Point, Turbine Building, and Rad \Waste/Augmented Rad Waste Buildings. It is possible for it to be in alarm with no single point at the HI-HI alarm setpoint. Tre MPF is not calculated in the eonibindll Effitimit Mon~itordspulway'.
REFERENCES NUREG-0654: N.02
. l PROCEDURE 5.7.1 I REVISION 3-12 I PAGE9 OF 88 Il PROCEDURE 5.7.1 I REVISION 3+2 I PAGE9OF88
I ATTACHMIENT 2 EMERGENCY ACTION LEVELS I ClASSIFICATION EAL: 1.1.2 NOUE Off-Site Dose Assessment IMlanual (ODANI) limits exceeded as indicated by either HIGH-HIGH alarim on a gaseous effluent. radiological monitor OR Combined Effluent Monitor indication on SPDS which cannot be cleared within 30 minutes.
APIPLICABI LITY ALL EXAMP'LE Any one of the following annunciators/SPDS indications is received AND release is verified, l)ut not brought l)elow ODAM limits within 30 minutes:
- RX BLDG VENTIHl-lHl RAD.
- ERP' DISCHARGE HI-HI RAD.
- TG BLDG VENT HI-I-II RAD.
RW/ARW' VTEN IlHl-HI RAD.
I
- Combined Effluent Monitors on SPDS exceeding ODANI limit..
M1EMO Alarms should be validated prior to making classification. If any valil alarm cannot be cleared within 30 minutes, the EAL is met.
The Combined Effluent Monitor on SPDS is a sum of the fractions of the release rate/ODAMV limit for the Reactor Building, Elevated Release Point, Turbine Building, and Rad WA'aste/Augmented Rad Waste Buildings. It is possible for it to be in alar m I with no single l)oint at tlhe HI-HI alarm setpoint.
REFERENCES NUREG-0654: N.02 IPROCEI)URE 5.7.1 REVISION 31 PAE'3 OF 88S
I ATTACHMENT 3 LIST OF NRC COMMITMENTS Correspondence No: NLS2005006 The following table identifies those actions committed to by the Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by the District. They are described to the Nuclear Regulatory Commission's (NRC) for the NRC's information and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITTED DATE COMMITMENT OR OUTAGE None 4
4 4
4 4
PROCEDURE 0.42 l REVISION 7 l PAGE 13 OF 17 l