ML062960084

Proposed Revision to Emergency Action Levels

ML062960084
Person / Time
Site:	Susquehanna
Issue date:	10/26/2006
From:	Richard Guzman NRC/NRR/ADRO/DORL/LPLI-1
To:	Mckinney B Susquehanna
Guzman R, NRR/DORL, 415-1030
References
TAC MC9602, TAC MC9603
Download: ML062960084 (6)

Text

October 26, 2006 Mr. Britt T. McKinney Sr. Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 - PROPOSED REVISION TO EMERGENCY ACTION LEVELS (TAC NOS. MC9602 AND MC9603)

Dear Mr. McKinney:

By letter dated January 6, 2006, as supplemented by letter dated May 1, 2006, PPL Susquehanna, LLC, submitted proposed changes to the Susquehanna Steam Electric Station, Units 1 and 2 (SSES 1 and 2), Emergency Action Levels (EALs) for Nuclear Regulatory Commission (NRC) review and approval.

The proposed changes revise the SSES 1 and 2 EAL entry conditions for EAL EU1 for the SSES 1 and 2 Independent Spent Fuel Storage Installation (ISFSI) to accomodate use of the approved Transnuclear 61BT dry storage canisters with both 5-year and 10-year cooling periods for spent fuel. This EAL is also revised to provide clarity for the radiological readings that may be indicative of damage to the ISFSI system.

Based on its review, the NRC staff has concluded that the proposed SSES 1 and 2 EAL changes meet the standards of Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.47(b) and the requirements of Appendix E to 10 CFR Part 50, and are therefore considered acceptable as evaluated in the enclosed safety evaluation. As agreed to by your staff, the SSES 1 and 2 EAL changes shall be implemented within 30 days from the issuance date of this letter. If you have any questions, please contact me at 301-415-1030.

Sincerely,

/RA/

Richard V. Guzman, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388

Enclosure:

Safety Evaluation cc w/encl: See next page

October 26, 2006 Mr. Britt T. McKinney Sr. Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 - PROPOSED REVISION TO EMERGENCY ACTION LEVELS (TAC NOS. MC9602 AND MC9603)

Dear Mr. McKinney:

By letter dated January 6, 2006, as supplemented by letter dated May 1, 2006, PPL Susquehanna, LLC, submitted proposed changes to the Susquehanna Steam Electric Station, Units 1 and 2 (SSES 1 and 2), Emergency Action Levels (EALs) for Nuclear Regulatory Commission (NRC) review and approval.

The proposed changes revise the SSES 1 and 2 EAL entry conditions for EAL EU1 for the SSES 1 and 2 Independent Spent Fuel Storage Installation (ISFSI) to accomodate use of the approved Transnuclear 61BT dry storage canisters with both 5-year and 10-year cooling periods for spent fuel. This EAL is also revised to provide clarity for the radiological readings that may be indicative of damage to the ISFSI system.

Based on its review, the NRC staff has concluded that the proposed SSES 1 and 2 EAL changes meet the standards of Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.47(b) and the requirements of Appendix E to 10 CFR Part 50, and are therefore considered acceptable as evaluated in the enclosed safety evaluation. As agreed to by your staff, the SSES 1 and 2 EAL changes shall be implemented within 30 days from the issuance date of this letter. If you have any questions, please contact me at 301-415-1030.

Sincerely,

/RA/

Richard V. Guzman, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388

Enclosure:

Safety Evaluation cc w/encl: See next page DISTRIBUTION PUBLIC LPLI-1 RF RidsNrrDorlLpl1-1 RidsNrrPmRGuzman RidsNrrLaSlittle RidsOgcMailCenter DJohnson EWeiss RidsAcrsAcnwMailCenter ACCESSION NO.: ML062960084

• Provided SE input. No substantive changes made.

OFFICE LPLI-1/PM LPLI-1/LA NSIR/DPR LPLI-1/BC NAME RGuzman SLittle EWeiss* RLaufer DATE 10/26/06 10/26/06 7/28/06 10/26/06 OFFICIAL RECORD COPY

Susquehanna Steam Electric Station, Unit Nos. 1 and 2 cc:

Robert A. Saccone Bryan A. Snapp, Esq Vice President - Nuclear Operations Assoc. General Counsel PPL Susquehanna, LLC PPL Services Corporation 769 Salem Blvd., NUCSB3 Two North Ninth Street, GENTW3 Berwick, PA 18603-0467 Allentown, PA 18101-1179 Terry L. Harpster Supervisor - Document Control Services General Manager - Plant Support PPL Susquehanna, LLC PPL Susquehanna, LLC Two North Ninth Street, GENPL4 769 Salem Blvd., NUCSA4 Allentown, PA 18101-1179 Berwick, PA 18603-0467 Richard W. Osborne Rocco R. Sgarro Allegheny Electric Cooperative, Inc.

Manager - Nuclear Regulatory Affairs 212 Locust Street PPL Susquehanna, LLC P.O. Box 1266 Two North Ninth Street, GENPL4 Harrisburg, PA 17108-1266 Allentown, PA 18101-1179 Director, Bureau of Radiation Protection Walter E. Morrissey Pennsylvania Department of Supervising Engineer Environmental Protection Nuclear Regulatory Affairs Rachel Carson State Office Building PPL Susquehanna, LLC P.O. Box 8469 769 Salem Blvd., NUCSA4 Harrisburg, PA 17105-8469 Berwick, PA 18603-0467 Senior Resident Inspector Michael H. Crowthers U.S. Nuclear Regulatory Commission Supervising Engineer P.O. Box 35, NUCSA4 Nuclear Regulatory Affairs Berwick, PA 18603-0035 PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Regional Administrator, Region 1 Allentown, PA 18101-1179 U.S. Nuclear Regulatory Commission 475 Allendale Road Steven M. Cook King of Prussia, PA 19406 Manager - Quality Assurance PPL Susquehanna, LLC Board of Supervisors 769 Salem Blvd., NUCSB2 Salem Township Berwick, PA 18603-0467 P.O. Box 405 Berwick, PA 18603-0035 Luis A. Ramos Community Relations Manager, Dr. Judith Johnsrud Susquehanna National Energy Committee PPL Susquehanna, LLC Sierra Club 634 Salem Blvd., SSO 443 Orlando Avenue Berwick, PA 18603-0467 State College, PA 16803

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE PROPOSED EMERGENCY ACTION LEVELS FOR PPL SUSQUEHANNA, LLC SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS. 50-387 AND 50-388

1.0 INTRODUCTION

In its application dated January 6, 2006 (Agencywide Documents Access and Management System Accession No. ML060190489, as supplemented by letter dated May 1, 2006 (ML061290595), PPL Susquehanna, LLC (PPL, the licensee) requested a change to the emergency action levels (EALs) for the Susquehanna Steam Electric Station, Units 1 and 2 (SSES 1 and 2).

The proposed changes revise the EAL entry conditions for EAL EU1 for the SSES 1 and 2 Independent Spent Fuel Storage Installation (ISFSI) to accommodate use of the approved Transnuclear 61BT dry storage containers with both 5-year and 10-year cooling periods for spent fuel. This EAL is also revised to provide clarity for the radiological readings that may be indicative of damage to the ISFSI system.

2.0 REGULATORY EVALUATION

The regulatory requirements and guidance which the Nuclear Regulatory Commission (NRC) staff considered in its review of the application are as follows:

2.1 Regulations Paragraph (a)(1) to Section 50.47, Emergency plans, of Title 10 of the Code of Federal Regulations (10 CFR) Part 50 states in part, that no operating license for a nuclear power reactor will be issued unless a finding is made by the NRC that the state of onsite and offsite emergency preparedness provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. Section 50.47 also establishes standards that must be met by the onsite and offsite emergency response plans for NRC staff to make a positive finding that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. One of these standards, 50.47(b)(4), stipulates that emergency plans include a standard emergency classification and action level scheme.

Enclosure

Section IV.B to Appendix E of 10 CFR Part 50, Emergency Planning and Preparedness for Production and Utilization Facilities, provides that emergency plans are to include EALs, which are to be used as criteria for determining the need for notification and participation of local and State agencies and which are to be used for determining when and what type of protective measures should be considered both onsite and offsite to protect public health and safety.

EALs are to be based on in-plant conditions and instrumentation, and also on onsite and offsite monitoring.Section IV.B of Appendix E also provides that initial EALs shall be discussed and agreed on by the applicant and State and local authorities, be approved by NRC, and be reviewed annually with State and local authorities. In addition,Section IV.B of Appendix E states in part, that an EAL revision must be approved by the NRC before implementation if it involves: (1) the changing from an EAL scheme based on NUREG-0654/FEMA-REP-1 to a scheme based on NUMARC/NESP-007 or Nuclear Energy Institute (NEI) 99-01; (2) the licensee is proposing an alternate method for complying with the regulations; or (3) the EAL revision has been evaluated by licensee as constituting a decrease in effectiveness.

2.2 Guidance Revision 4 to Regulatory Guide (RG) 1.101, Emergency Planning and Preparedness for Nuclear Power Reactors, issued in July 2003 (ML032020276), endorses the guidance contained in NEI 99-01, Methodology for Development of Emergency Action Levels, (Revision 4, January 2003), as acceptable to the NRC staff as an alternative method to that described in the following guidance for developing EALs required in Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4):

• Appendix 1 to NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (November 1980), and

• Nuclear Utilities Management Council (NUMARC) document, entitled NESP-007, Methodology for Development of Emergency Action Levels (Revision 2, January 1992).

Regulatory Issue Summary (RIS) 2003-18, Use of NEI 99-01, Methodology for Development of Emergency Action Levels, dated October 8, 2003, (as well as supplements 1 and 2, dated July 13, 2004, and December 12, 2005, respectively), provides guidance for developing or changing a standard emergency classification and action level scheme. In addition, the RIS provides recommendations to assist licensees, consistent with Section IV.B to Appendix E of Part 50, in determining whether to seek prior NRC approval of deviations from the new guidance.

3.0 TECHNICAL EVALUATION

The NRC staff has reviewed PPL's regulatory and technical analyses in support of its proposed EAL changes, which are described in PPLs application dated January 6, 2006, as supplemented by letter dated May 1, 2006. Since the proposed revision to the SSES 1 and 2 EALs was evaluated by PPL to be a potential decrease in effectiveness, the proposed changes were submitted to the NRC for approval prior to implementation by PPL, as required under Section IV.B to Appendix E of Part 50 and 10 CFR 50.54(q).

SSES 1 and 2 utilizes an EAL scheme based upon NEI 99-01, Revision 4, Methodology for Development of Emergency Action Levels, dated January 2003 (ML041470143). The current SSES EAL, EU1, was based upon utilization of the model 52B Dry Shielded canisters. The proposed changes to EAL EU1 are based upon utilization of the model 52B Dry Shielded canisters as well as the model 61BT Dry Shielded canisters. The 61BT Dry Shielded canisters comply with the conditions and requirements of the Certificate of Compliance for Dry Spent Fuel Storage Casks Number 1004, the Safety Analysis Report for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel (NUH-003) and the PPL 72.212 evaluation and were approved for use at SSES under the provisions of 10 CFR Part 72.

The calculated EAL entry condition for the current EAL EU1 is 1 Roentgen-per-hour (R/hour) at 1 foot and is derived from calculations utilizing the model 52B canisters only. The model 61BT canister is designed to contain a larger number of fuel assemblies and can contain fuel cooled for a shorter period of time. The normal dose rate during transport of 5-year cooled fuel to the model 61BT canister approaches the current EAL value of 1 R/hour at 1 foot. This could lead to unnecessary emergency declarations as the expected dose rate value under accident conditions is approximately 5-7 R/hour at 1 foot. PPL performed a calculation (EC-RADN-1024) and determined that an EAL entry condition of 2 R/hour at 1 foot would bound the credible accident scenarios associated with storing fuel in the 52B and 61BT canisters. The proposed EAL entry conditions are above normal operation dose rates but less than the dose rates associated with an accident and are, therefore, considered acceptable.

The current EAL does not specifically address dose rates near the surface of the roof bird screen of a horizontal storage module. PPL proposes a new EAL entry condition incorporating a calculated value for dose rates 1 foot from the roof bird screen. PPLs calculation, EC-RADN-1024, determined that a value of 4 R/hour at 1 foot from the roof bird screen would bound this event and is considered acceptable by the NRC staff.

Clarification of the wording in SSES EAL EU1 was proposed to ensure focus was maintained on the transfer cask used during materials transport and on the horizontal storage module which is used during storage post-transport. The unnecessary wording in EU1.1 that discussed the module, and in EU1.2 that discussed the transfer cask, was removed. This change is acceptable in that the intent of the EAL is maintained.

4.0 CONCLUSION

The NRC staff performed a review of the proposed changes to the SSES 1 and 2 EALs as submitted under application dated January 6, 2006. Based on the application and the supplemental letter dated May 1, 2006, the NRC staff finds that the proposed SSES 1 and 2 EAL revision is consistent with the guidance of NEI 99-01, Revision 4. As such, the proposed SSES 1 and 2 EAL changes meet the requirements of 10 CFR 50.47(b) and Section IV.B of Appendix E to 10 CFR Part 50, do not result in a decrease in effectiveness of the emergency plan, and are therefore acceptable.

Principal Contributor: D. Johnson Date: October 26, 2006