ONS-2016-028, Response to Request for Additional Information (RAI) Re License Amendment Request (LAR) to Change Emergency Plan to Upgrade ONS Emergency Action Levels Based on NEI 99-01, Revision 6

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Response to Request for Additional Information (RAI) Re License Amendment Request (LAR) to Change Emergency Plan to Upgrade ONS Emergency Action Levels Based on NEI 99-01, Revision 6
ML16085A132
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 03/18/2016
From: Batson S
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 2015-04, ONS-2016-028
Download: ML16085A132 (8)
v • d • e


Text

SCOTTL. BATSON

(_~DUKE Vice President

~

Oconee Nuclear Station ENERGY Duke Energy ON01VP I 7800 Rochester Hwy Seneca, SC 29672 o: 864-873-3274 f: 864-873-4208 Scott.Batson@duke-energy.com ONS-2016-028 10 CFR 50.90 10 CFR 50 Appendix E March 18, 2016 Attn: Document Control Desk U. S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 Duke Energy Carolinas, LLC (Duke Energy)

Oconee Nuclear Station, Units 1, 2, and 3 Docket Numbers 50-269, 50-270, and 50-287 Renewed Operating License Nos. DPR-38, DPR-47, and DPR-55

Subject:

Response to Request for Additional Information (RAI) Regarding the License Amendment Request (LAR) to Change the Oconee Nuclear Station (ONS)

Emergency Plan to Upgrade ONS Emergency Action Levels Based on NEI 99-01, Revision 6 License Amendment Request No. 2015-04 By letter dated June 23, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15183A060), Duke Energy requested approval of a proposed change to the Emergency Action Levels (EALs) used at Oconee Nuclear Station (ONS). Duke Energy proposes to revise their current ONS EAL scheme to one based upon Nuclear Energy Institute (NEI) document NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6 (ADAMS Accession No. ML12326A805).

The NRC staff reviewed the request and determined that additional information is needed to complete their review. A letter requesting additional information was sent December 15, 2015 (ADAMS Accession No. ML15345A398). Duke Energy responded to this request by letter dated February 4, 2016 (ADAMS Accession No. ML16041A237). The NRC issued an additional RAI by letter dated February 26, 2016 (ADAMS Accession No. ML ML16056A583).

The enclosure provides the ONS response to this most recent RAI.

ONS anticipates that the LAR, as approved, will be effective upon issuance and requests implementation by March 31, 2017, due to the need for operator training. This request supersedes the previous ONS request for a 180-day implementation period.

This letter makes no new commitments or changes to existing commitments. Should you have any questions regarding this request, please contact Chris Wasik, Regulatory Affairs Manager, at (864) 873-5789.

U.S. Nuclear Regulatory Commission March 18, 2016 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 18th day of March, 2016.

Sincerely, dY?td:r-Scott L. Batson Vice President Oconee Nuclear Station

Enclosure:

Response to Request for Additional Information

U.S. Nuclear Regulatory Commission March 18, 2016 Page 3 cc w/

Enclosures:

Ms. Catherine Haney, Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Mr. James. H~ll. Senior Project Manager (by electronic mail only)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 G9A Rockville, MD 20852 Mr. Jeffrey Whited, Project Manager (by electronic mail only)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 B 1A Rockville, MD 20852 Mr. Eddy Crowe NRC Senior Resident Inspector Oconee Nuclear Site Ms. Susan Jenkins, Manager Radioactive & Infectious Waste Management Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St.

Columbia, SC 29201

U.S. Nuclear Regulatory Commission March 18, 2016 Page4 cc w/o

Enclosures:

Mr. Scott Krein, Director Oconee County Emergency Preparedness 415 South Pine Street Walhalla, SC 29691 Ms. Denise Kwiatek, Deputy Director Pickens County Emergency Preparedness 1509 Walhalla Highway Pickens, SC 29671 Mr. Kim Stenson, Director South Carolina Emergency Management Division 2779 Fish Hatchery Road West Columbia, SC 29172

U.S. Nuclear Regulatory Commission March 18, 2016 Page 5 bee w/enclosures:

T.D.Ray M. C. Nolan C. T. Dunton T. L. Patterson C. J. Wasik P. M. Street T. R. Byrne - GO C. A. Fletcher - CNS J. N. Robertson - MNS L. J. Grzeck - BNP J. R. Caves - HNP M. S. Connelly - RNP NSRB, EC05N ELL, EC2ZF File - T.S. Working ONS Document Management

ONS-2016-028 Enclosure ENCLOSURE RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST NO. 2015-04 OCONEE NUCLEAR POWER STATION, UNIT 1, 2, AND 3 DOCKET NOS 50-269, 50-270, and 50-287 RENEWED LICENSE NOS. DPR-38, DPR-47, and DPR-55 2 Pages Follow

ONS-2016-028 Enclosure RAl-24 Please explain, in greater detail, the response to RAl-05, submitted by letter dated February 4, 2016. In particular, please explain why the values and thresholds developed for EALs RU1, RA 1, RS 1, and RG 1, in accordance with NEI 99-01, Revision 6, are about a factor of 7 different than those developed for your present EAL scheme which used the NUMARC/NESP-007 EAL scheme development guidance. The assumptions for the NUMARC and NEI guidance are essentially the same (except using different dose calculation method(s)), therefore this less conservative value(s) for the EALs presently in place requires more information to allow the NRC staff to better understand not only what is proposed but also why it is so different than what is currently approved, and if the currently approved EALs have been under-conservative since approval.

Duke Energy Response In NEI 99-01 Rev. 6, the Developer Notes for AA 1, AS1, and AG1 it is stated that acceptable sources of information for assumed meteorological data, atmospheric dispersion factors, and isotopic mix "include, but are not limited to, the RETS!ODCM and values used in the site's emergency dose assessment methodology." Additionally, the Developer Notes for AU1 state that as appropriate, the Radiological Effluent Technical Specifications (RETS) or Offsite Dose Calculation Manual (ODCM) methodology should be used for establishing the monitor thresholds.

As such, in the development of the effluent monitor threshold value for RU1 .1, Oconee's ODCM methodology was used. In regards to RA1 .1, RS1 .1 and RG1 .1, Oconee's emergency dose assessment software, Unified Rascal Interface (URI), was used to develop the effluent monitor threshold values.

The currently approved EALs were developed in accordance with the NRG-approved guidance in NUMARC/NESP-007, Rev. 2, and they are conservative.

Key differences in the calculation of the NEI 99-01 Rev. 6 EAL radiation monitor threshold values from the current NUMARC/NESP-007 Rev. 2 values are summarized in Table 1 below.

Table 1 INPUT Proposed (NEI 99-01 Rev.6) Current (NUMARC/NESP-007 Rev.2)

URI/RASCAL values as 1 Source Term ODCM values described in NUREG-1940 Dose 2 ICRP-60 values in URI/RASCAL Reg. Guide 1.109 values Conversion URI/RASCAL dispersion methodology with model-derived ODCM methodology using highest Dispersion XIQ to the affected sector for the 3* annual average X/Q of 16 directional Model entire release duration using sectors.

median wind speed and stability class.

  • For RU1 .1 difference is due to 1 and 2 only.

ONS-2016-028 Enclosure Given the differences noted in Table 1 above, a change of about one order of magnitude (10 1) in the EAL effluent monitor threshold values is reasonable and well below the range (10 2 to 104 ) of the most likely dose assessment uncertainty factors discussed in NUREG/CR-5247.

For example, basing the X/Q on a single sector for the entire release duration using URI/RASCAL dispersion methodology results in a X/Q value that is significantly larger than an ODCM-based annual average X/Q. As discussed in NEI 99-01, Rev 4, Appendix A, "the sector annual average XIQ value is normalized for the percentage of time that the wind blows into that sector. In an actual event, the wind direction may be into the affected sector for the entire release duration.

Many sites experience typical sector X!Qs that are 10-20 times higher than the calculated annual average for the sector."

SCOTTL. BATSON

(_~DUKE Vice President

~

Oconee Nuclear Station ENERGY Duke Energy ON01VP I 7800 Rochester Hwy Seneca, SC 29672 o: 864-873-3274 f: 864-873-4208 Scott.Batson@duke-energy.com ONS-2016-028 10 CFR 50.90 10 CFR 50 Appendix E March 18, 2016 Attn: Document Control Desk U. S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 Duke Energy Carolinas, LLC (Duke Energy)

Oconee Nuclear Station, Units 1, 2, and 3 Docket Numbers 50-269, 50-270, and 50-287 Renewed Operating License Nos. DPR-38, DPR-47, and DPR-55

Subject:

Response to Request for Additional Information (RAI) Regarding the License Amendment Request (LAR) to Change the Oconee Nuclear Station (ONS)

Emergency Plan to Upgrade ONS Emergency Action Levels Based on NEI 99-01, Revision 6 License Amendment Request No. 2015-04 By letter dated June 23, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15183A060), Duke Energy requested approval of a proposed change to the Emergency Action Levels (EALs) used at Oconee Nuclear Station (ONS). Duke Energy proposes to revise their current ONS EAL scheme to one based upon Nuclear Energy Institute (NEI) document NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6 (ADAMS Accession No. ML12326A805).

The NRC staff reviewed the request and determined that additional information is needed to complete their review. A letter requesting additional information was sent December 15, 2015 (ADAMS Accession No. ML15345A398). Duke Energy responded to this request by letter dated February 4, 2016 (ADAMS Accession No. ML16041A237). The NRC issued an additional RAI by letter dated February 26, 2016 (ADAMS Accession No. ML ML16056A583).

The enclosure provides the ONS response to this most recent RAI.

ONS anticipates that the LAR, as approved, will be effective upon issuance and requests implementation by March 31, 2017, due to the need for operator training. This request supersedes the previous ONS request for a 180-day implementation period.

This letter makes no new commitments or changes to existing commitments. Should you have any questions regarding this request, please contact Chris Wasik, Regulatory Affairs Manager, at (864) 873-5789.

U.S. Nuclear Regulatory Commission March 18, 2016 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 18th day of March, 2016.

Sincerely, dY?td:r-Scott L. Batson Vice President Oconee Nuclear Station

Enclosure:

Response to Request for Additional Information

U.S. Nuclear Regulatory Commission March 18, 2016 Page 3 cc w/

Enclosures:

Ms. Catherine Haney, Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Mr. James. H~ll. Senior Project Manager (by electronic mail only)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 G9A Rockville, MD 20852 Mr. Jeffrey Whited, Project Manager (by electronic mail only)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 B 1A Rockville, MD 20852 Mr. Eddy Crowe NRC Senior Resident Inspector Oconee Nuclear Site Ms. Susan Jenkins, Manager Radioactive & Infectious Waste Management Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St.

Columbia, SC 29201

U.S. Nuclear Regulatory Commission March 18, 2016 Page4 cc w/o

Enclosures:

Mr. Scott Krein, Director Oconee County Emergency Preparedness 415 South Pine Street Walhalla, SC 29691 Ms. Denise Kwiatek, Deputy Director Pickens County Emergency Preparedness 1509 Walhalla Highway Pickens, SC 29671 Mr. Kim Stenson, Director South Carolina Emergency Management Division 2779 Fish Hatchery Road West Columbia, SC 29172

U.S. Nuclear Regulatory Commission March 18, 2016 Page 5 bee w/enclosures:

T.D.Ray M. C. Nolan C. T. Dunton T. L. Patterson C. J. Wasik P. M. Street T. R. Byrne - GO C. A. Fletcher - CNS J. N. Robertson - MNS L. J. Grzeck - BNP J. R. Caves - HNP M. S. Connelly - RNP NSRB, EC05N ELL, EC2ZF File - T.S. Working ONS Document Management

ONS-2016-028 Enclosure ENCLOSURE RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST NO. 2015-04 OCONEE NUCLEAR POWER STATION, UNIT 1, 2, AND 3 DOCKET NOS 50-269, 50-270, and 50-287 RENEWED LICENSE NOS. DPR-38, DPR-47, and DPR-55 2 Pages Follow

ONS-2016-028 Enclosure RAl-24 Please explain, in greater detail, the response to RAl-05, submitted by letter dated February 4, 2016. In particular, please explain why the values and thresholds developed for EALs RU1, RA 1, RS 1, and RG 1, in accordance with NEI 99-01, Revision 6, are about a factor of 7 different than those developed for your present EAL scheme which used the NUMARC/NESP-007 EAL scheme development guidance. The assumptions for the NUMARC and NEI guidance are essentially the same (except using different dose calculation method(s)), therefore this less conservative value(s) for the EALs presently in place requires more information to allow the NRC staff to better understand not only what is proposed but also why it is so different than what is currently approved, and if the currently approved EALs have been under-conservative since approval.

Duke Energy Response In NEI 99-01 Rev. 6, the Developer Notes for AA 1, AS1, and AG1 it is stated that acceptable sources of information for assumed meteorological data, atmospheric dispersion factors, and isotopic mix "include, but are not limited to, the RETS!ODCM and values used in the site's emergency dose assessment methodology." Additionally, the Developer Notes for AU1 state that as appropriate, the Radiological Effluent Technical Specifications (RETS) or Offsite Dose Calculation Manual (ODCM) methodology should be used for establishing the monitor thresholds.

As such, in the development of the effluent monitor threshold value for RU1 .1, Oconee's ODCM methodology was used. In regards to RA1 .1, RS1 .1 and RG1 .1, Oconee's emergency dose assessment software, Unified Rascal Interface (URI), was used to develop the effluent monitor threshold values.

The currently approved EALs were developed in accordance with the NRG-approved guidance in NUMARC/NESP-007, Rev. 2, and they are conservative.

Key differences in the calculation of the NEI 99-01 Rev. 6 EAL radiation monitor threshold values from the current NUMARC/NESP-007 Rev. 2 values are summarized in Table 1 below.

Table 1 INPUT Proposed (NEI 99-01 Rev.6) Current (NUMARC/NESP-007 Rev.2)

URI/RASCAL values as 1 Source Term ODCM values described in NUREG-1940 Dose 2 ICRP-60 values in URI/RASCAL Reg. Guide 1.109 values Conversion URI/RASCAL dispersion methodology with model-derived ODCM methodology using highest Dispersion XIQ to the affected sector for the 3* annual average X/Q of 16 directional Model entire release duration using sectors.

median wind speed and stability class.

  • For RU1 .1 difference is due to 1 and 2 only.

ONS-2016-028 Enclosure Given the differences noted in Table 1 above, a change of about one order of magnitude (10 1) in the EAL effluent monitor threshold values is reasonable and well below the range (10 2 to 104 ) of the most likely dose assessment uncertainty factors discussed in NUREG/CR-5247.

For example, basing the X/Q on a single sector for the entire release duration using URI/RASCAL dispersion methodology results in a X/Q value that is significantly larger than an ODCM-based annual average X/Q. As discussed in NEI 99-01, Rev 4, Appendix A, "the sector annual average XIQ value is normalized for the percentage of time that the wind blows into that sector. In an actual event, the wind direction may be into the affected sector for the entire release duration.

Many sites experience typical sector X!Qs that are 10-20 times higher than the calculated annual average for the sector."

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