ML11069A001

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Approval of Change of Emergency Action Level Scheme from NUMARC/NESP-007, Revision 2, to NEI 99-01, Revision 5
ML11069A001
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 04/20/2011
From: Leeds E
Office of Nuclear Reactor Regulation
To:
FitzPatrick, Entergy Nuclear Operations
vaidya B, NRR/Dorl/lpl1-1, 415-3308
References
NEI 99-01, Rev. 5, NUMARC/NESP-007, Rev. 2, TAC ME3787
Download: ML11069A001 (21)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 20,2011 Vice President, Operations Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - APPROVAL OF CHANGE OF EMERGENCY ACTION LEVEL SCHEME FROM NUMARC/NESP-007, REVISION 2, TO NEI99-01, REVISION 5 (TAC NO. ME3787)

Dear Sir or Madam:

By letter dated April 8, 2010, as supplemented by letter dated February 4, and March 23, 2011, Entergy Nuclear Operations, Inc. (Entergy or the licensee), requested prior U.S. Nuclear Regulatory Commission (NRC) approval for proposed changes to the emergency action levels (EAL) scheme for the James A. FitzPatrick Nuclear Power Plant (JAFNPP). The requested changes to the EAL scheme support a conversion from their current EAL scheme to a scheme based on the Nuclear Energy Institute (NEI) 99-01, "Methodology for Development of Emergency Action Levels," Revision 5, dated February 2008.

The NRC staff has completed its review. Based on the information provided by the licensee, the NRC staff finds that the proposed JAFNPP EAL Scheme revision, provided in the licensee's letter, dated April 8, 2010, as supplemented by letter dated February 4, and March 23, 2011, is consistent with the guidance in NEI 99-01, Revision 5, which is an acceptable alternative for development of an EAL scheme and meets the standards in 10 CFR 50.47(b) and the requirements in 10 CFR Part 50, Appendix E, Section IV-B.

Therefore, the NRC staff approves the proposed change to the EAL scheme. A copy of the related Safety Evaluation is enclosed.

Sincerely, CL~

Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

Safety Evaluation cc: Ustserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO PROPOSED UPGRADE TO EMERGENCY ACTIONS LEVELS SCHEME USING NEI 99-01, REVISION 5 METHODOLOGY JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333

1.0 INTRODUCTION

By letter dated April 8, 2010 Agencywide Documents Access and Management System (ADAMS) Accession No. ML101100610), (Reference 1), as supplemented by letter dated February 4, and March 23,2011 (ADAMS Accession Nos. ML110350521 and ML110830901, respectively), (References 2 and 3)\ Entergy Nuclear Operations, Inc. (the licensee), requested prior U.S. Nuclear Regulatory Commission (NRC) approval for proposed changes to the emergency action levels (EAL) scheme for the James A. FitzPatrick Nuclear Power Plant (JAFNPP).

The requested changes to the EAL scheme support a conversion from their current EAL scheme to a scheme based on the Nuclear Energy Institute (NEI) 99-01, "Methodology for Development of Emergency Action Levels," Revision 5, dated February 2008 (Reference 4).

JAFNPP currently utilizes an EAL scheme that is site-specific yet developed in accordance with the guidance developed by National Environmental Studies Project (NESP) of the former Nuclear Management and Resources Council (NUMARC) and contained in NUMARC/NESP-007, "Methodology for Development of Emergency Action Levels," Revision 2 (Reference 5), approved for use by Safety Evaluation (SE) dated June 5, 1995 (Reference 6).

2.0 REGULATORY EVALUATION

The following explains the use of General Design Criteria (GDC) for JAFNPP. The construction permit for JAFNPP was issued by the Atomic Energy Commission (AEC) on May 20, 1970, and the operating license was issued on October 17, 1974. The plant design criteria for the construction phase are listed in the Updated Final Safety Analysis Report (UFSAR) Chapter 1.5, "Principal Design Criteria." The AEC published the final rule that added Appendix A to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, "General Design Criteria for Nuclear Power Plants," in the Federal Register (36 FR 3255) on February 20, 1971, with the rule effective on May 21, 1971. In accordance with an NRC staff requirements memorandum from 1 Prior to February 4, 2011! supplemental submission, by letter dated December 7, 2010 (ADAMS Accession No. ML103420337), the licensee withdrew its supplemental submission dated November 18, 2010 (ADAMS Package Accession No. ML103220221).

Enclosure

-2 S. J. Chilk to J. M. Taylor, "SECY-92-223 - Resolution of Deviations Identified During the Systematic Evaluation Program," dated September 18, 1992 (ADAMS Accession No. ML003763736), the Commission decided not to apply the final GDC to plants with construction permits issued prior to May 21, 1971, which includes JAFNPP. However, the JAFNPP UFSAR, Chapter 16.6, "Conformance to AEC Design Criteria," evaluates JAFNPP against the 10 CFR Part 50 Appendix A GDC. Also, the initial AEC SE of JAFNPP, dated November 20, 1972, Chapter 14.0, stated "Based on our evaluation of the design and design criteria for the James A. FitzPatrick Nuclear Power Plant, we conclude that there is reasonable assurance that the intent of the General Design Criteria for Nuclear Power Plants, published in the Federal Register on May 21, 1971 as Appendix A to 10 CFR Part 50, will be met." Therefore, the NRC staff reviews amendments to the JAFNPP license using the 10 CFR Part 50 Appendix A GDC unless there are specific criteria identified in the UFSAR.

The NRC staff reviewed the proposed revision against the following regulations and guidance described below.

2.1 Regulations Section 50.47, of 10 CFR, "Emergency plans," sets forth emergency plan requirements for nuclear power plant facilities. The regulations in 10 CFR 50.47(a)(1 )(i) state, in part, that " ... no initial operating license for a nuclear power reactor will be issued unless a finding is made by the NRC that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency."

Section 50.47(b) establishes the standards that the onsite and offsite emergency response plans must meet for NRC staff to make a positive finding that there is reasonable assurance that the licensee can and will take adequate protective measures in the event of a radiological emergency. Planning Standard (4) of this section requires that a licensee's emergency response plan contain: "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, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures."

Section IV.B of Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," to 10 CFR Part 50, states:

The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring.

These initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC.

Thereafter, emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis. A revision to an emergency action level must be approved by the NRC before implementation if:

-3 (1) The licensee is changing from one emergency action level scheme to another emergency action level scheme (e.g., a change from an emergency action level scheme based on NUREG-0654 to a scheme based upon NUMARC/NESP-007 or NEI 99-01);

(2) The licensee is proposing an alternate method for complying with the regulations; or (3) The emergency action level revision decreases the effectiveness of the emergency plan.

2.2 Guidance EAL development guidance was initially been established via Generic Letter (GL) 79-50 (Reference 7) and subsequently established in NUREG-0654/FEMA-REP-1 (Reference 8),

which was endorsed as an approach for the development of an EAL scheme via NRC Regulatory Guide (RG) 1.101, Revision 2. As industry and regulatory experience was gained with the implementation and use of the EAL scheme, the industry developed revised EAL scheme development guidance documents to gain the benefit of lessons learned. To date, NUMARC/NESP-007 (Reference 5), NEI 99-01 Revision 4 (Reference 9), and NEI 99-01 Revision 5 were provided to the NRC for review and endorsement as generic (non site-specific)

EAL development guidance. RG 1.101, Revisions 3 and 4 (Reference 10) endorsed NUMARC/NESP-007 and NEI 99-01 Revision 4 as acceptable alternatives for licensees to consider in the development of their site-specific EAL schemes, as well as allowing licensees to develop site-specific EALs based upon an alternative approach not endorsed by the NRC. NEI 99-01 Revision 5 was endorsed as generic (non site-specific) EAL development guidance via letter dated February 22, 2008 (Reference 11) and will be further endorsed in the next revision of RG 1.101.

GL 79-50, NUREG-0654/FEMA-REP-1, NUMARC/NESP-007, NEI 99-01 Revision 4, and NEI 99-01 Revision 5 are all considered generic EAL development guidance documents, as they are not site-specific and may not be entirely applicable for some reactor designs. However, the guidance contained in these documents bounds the most typical accident/event scenarios for which emergency response is necessary in a format that allows for industry standardization and consistent regulatory oversight. Most licensees choose to develop their site-specific EAL schemes using the latest endorsed EAL development guidance with appropriate site-specific alterations as applicable. A change in an EAL scheme to incorporate the improvements provided in NUMARC/NESP-007 or NEI 99-01 would not decrease the overall effectiveness of the emergency plan; however, due to the potential safety significance of the change, the change needs prior NRC review and approval.

The NRC considers the following methods acceptable for use in developing site-specific EALs that meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4}, with the understanding that licensees may need to develop EALs that differ from the applicable guidance document as allowed in RG 1.101 and in the letter dated February 22,2008:

-4

  • Appendix 1, "Emergency Action Level Guidelines for Nuclear Power Plants," to NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

dated November 1980;

  • NUMARC/NESP-007, Revision 2, "Methodology for Development of Emergency Action Levels," dated January 1992;
  • NEI 99-01, Revision 4, "Methodology for Development of Emergency Action Levels,"

dated January 2003; and

  • NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels,"

dated February 2008.

NRC Regulatory Issue Summary (RIS) 2003-18, with Supplements 1 and 2, "Use of NEI 99-01, Methodology for Development of Emergency Action Levels" (Reference 12), also provide guidance for developing or changing a standard emergency classification and action level scheme. In addition, this RIS and its Supplements provide recommendations to assist licensees, consistent with Section IV.S of Appendix E to Part 50, in determining whether to seek prior NRC approval of deviations from the guidance.

Regardless of the generic EAL scheme development guidance document used by a licensee to develop their EAL scheme, or if a licensee chose to develop their EAL scheme using an alternative approach not endorsed by the NRC, or a combination of the two (most typical), the NRC will review the EAL scheme to ensure it meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4).

3.0 TECHNICAL EVALUATION

10 CFR 50.47(b)(4) specifies a standard emergency classification and action level scheme, and as such, the NRC staff will ensure that implementation methods are relatively consistent throughout the industry for a given reactor and containment design while simultaneously providing an opportunity for a licensee to modify their EAL scheme as necessary to address site-specific design considerations or preferences.

The proposed changes were submitted to the NRC for a technical and regulatory review prior to implementation by the licensee, as required under Section IV.S of Appendix E to 10 CFR Part 50. This review is based upon a revision to the JAFNPP EAL scheme provided in the licensee's application letter and supplemented by the licensee's responses to the NRC's requests for additional information. Attachment 3 of the licensee's letter dated February 4, 2011 (Reference 2) contains the final version of the licensee's proposed site-specific EAL scheme and is, therefore, the final version reviewed by the NRC for acceptability.

The JAFNPP currently utilizes an EAL scheme primarily based on NUMARC/NESP-007 with site-specific modifications due to design issues and/or licensee preference. The NRC reviewed and approved EAL scheme by SE dated June 5, 1995. The licensee is converting to an EAL scheme using the development guidance from NEI 99-01 Revision 5 with site-specific modifications due to design issues and/or licensee preference.

- 5 In its application and supplemental letters, the licensee submitted the proposed EAL scheme for the JAFNPP, their technical basis, a comparison matrix, the EAL numbering scheme, and an explanation for any difference or deviation from NEI 99-01. The comparison matrix provided a cross reference relating the proposed EAL scheme to the EAL scheme in NEI99-01.

The NRC staff has reviewed the technical basis for the proposed EAL scheme, the modifications from NEI 99-01, and the licensee's evaluation of the proposed changes to ensure the proposed EAL scheme continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4) and is consistent with the NEI 99-01 guidance.

The NRC staff reviewed the proposed EAL scheme to ensure the following key characteristics of an effective EAL scheme are in place:

  • Consistency (Le., the EALs would lead to similar decisions under similar circumstances at different plants), up to and including standardization in intent, if not in actual wording;
  • Human engineering and user friendliness;
  • Potential for classification upgrade only when there is an increasing threat to public health and safety;
  • Ease of upgrading and downgrading;
  • Thoroughness in addressing and disposing of the issues of completeness and accuracy raised regarding Appendix 1 to NUREG-0654;
  • Technical completeness for each classification level;
  • Logical progression in classification for multiple events; and
  • Objective and observable values.

The NRC staff's review has determined that the proposed EAL scheme is consistent with EAL schemes implemented at similarly designed plants, that they use objective and observable values, and that they are consistent with the guidance in NEI 99-01 in these areas.

The NRC staff's review has determined that the proposed EAL scheme is worded in a manner that addresses human engineering and user friendliness concerns. The proposed EAL scheme uses procedure language, including specific tag numbers for instrument readings and alarms, and flow charts, critical safety function status-trees, check lists, and combinations of the above.

Based on this review, the staff has concluded that the proposed EAL scheme is consistent with the guidance in NEI 99-01 in these areas.

-6 The NRC staff's review has determined that the proposed EAL scheme is technical complete and that classification upgrades are based upon an increasing threat to public health and safety, can effectively support upgrading and downgrading, and follow a logical progression for multiple events. Based on this review, the NRC staff concludes that the EAL scheme is consistent with the guidance in NEI 99-01 in these areas.

The NRC staff review has also determined that the proposed EAL scheme is technical complete and accuracy for each classification level. The proposed EAL scheme is based on risk assessment to set the boundaries of the emergency classification levels and assure that all EALs that trigger emergency classification are in the same range of relative risk. Precursor conditions of more serious emergencies also represent a potential risk to the public and are appropriately classified. The staff has determined that the proposed EAL scheme is consistent with the guidance in NEI 99-01 in these areas.

The NRC staff reviewed EALs in each category. and each EAL set within that category. and has determined that the proposed EAL scheme meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4). as well as consistent with the NEI 99-01 guidance to the extent possible. Note that the licensee chose to modify their EAL scheme from NEI 99-01 to adopt a format more in alignment with how they currently implement their EALs, as well as alignment with JAFNPP specific writer's guides and licensee preferences. The NRC staff determined that many of these modifications are administrative and/or minor in nature and do not alter the intent of any specific EAL within an EAL set, EAL category. or within the entire EAL scheme.

To aid in understanding the nomenclature used in this SE, for each category of EALs reviewed the following naming/numbering convention is used: the first letter signifies the category; the second letter signifies the classification level (G = General Emergency, S= Site Area Emergency, A = Alert, U = Notification of Unusual Event); and the number is the applicable number from the site-specific EAL scheme. For ease of use, this SE will use the numbering system from the site-specific EAL scheme rather than from the generic EAL development guidance. The staff has reviewed the site-specific scheme to ensure all EALs from the generic EAL development guidance are addressed in their proposed EAL scheme.

3.1 CATEGORY 'A' - ABNORMAL RADIOLOGICAL RELEASE/RADIOLOGICAL EFFLUENT 3.1.1 EAL Set AG1/AS1/AA1/AU1 The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. In addition, the licensee chose to use mathematical symbols instead of their noun equivalent where applicable. The numbering, sequencing, and format of this EAL set is consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided. and is considered part of a standard EAL scheme.

The instrumentation and set points derived for this EAL set are consistent with the overall EAL scheme development guidance, address the site-specific implementation strategies provided, and are considered part of a standard EAL scheme.

-7 The licensee-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.1.2 EAL Set AA2/AU2 The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. In addition, the licensee chose to use mathematical symbols instead of their noun [name]-equivalent where applicable. The numbering, sequencing, and format of this EAL set is consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is considered part of a standard EAL scheme.

The instrumentation and set points derived for this EAL set are consistent with the overall EAL scheme development guidance, address the site-specific implementation strategies provided, and are considered part of a standard EAL scheme. In addition, the license had to modify this EAL set from the generic development guidance to account for site-specific limitations with available area radiation monitoring instrumentation. The use of survey readings when available instrumentation is off scale high is acceptable if the survey readings are determined within the 15-minute classification time as noted in the licensee's EAL.

The licensee-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.1.3 EAL AA3 This EAL does not require an EAL set within the overall EAL scheme as the EAL's intent is to prompt the activation of the licensee's emergency response organization (ERO) in support of the Control Room.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. In addition, the licensee chose to use mathematical symbols instead of their noun equivalent where applicable. The numbering and format of this EAL is consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is considered part of a standard EAL scheme.

The licensee-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

-8 3.2 CATEGORY 'C' - COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTION 3.2.1 EAL Set CA1/CU1 The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. In addition, the licensee chose to use mathematical symbols instead of their noun equivalent where applicable. The numbering, sequencing, and format of this EAL set is consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is considered part of a standard EAL scheme.

The instrumentation, values, and listing of applicable power sources derived for this EAL set are consistent with the overall EAL scheme development guidance, address the site-specific implementation strategies provided, and are considered part of a standard EAL scheme.

The licensee-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.2.2 EAL Set CG2/CS2/CA2/CU2 The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. In addition, the licensee chose to use mathematical symbols instead of their noun equivalent where applicable. The numbering, sequencing, and format of this EAL set is consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is considered part of a standard EAL scheme.

The instrumentation and set points derived for this EAL set are consistent with the overall EAL scheme development guidance, address the site-specific implementation strategies provided, and are considered part of a standard EAL scheme.

The licensee-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.2.3 EAL Set CA3/CU3 The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. In addition, the licensee chose to use mathematical symbols instead of their noun equivalent where applicable. The numbering, sequencing, and format of this EAL set is consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is considered part of a standard EAL scheme.

-9 The instrumentation and set points derived for this EAL set are consistent with the overall EAL scheme development guidance, address the site-specific implementation strategies provided, and are considered part of a standard EAL scheme.

The licensee-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.2.4 EAL CU4 This EAL does not require an EAL set within the overall EAL scheme as the EAL's intent is to highlight the importance of emergency communications by ensuring an EAL is declared if normal communication methods for onsite and offsite personnel, or for offsite response organizations including the NRC, are lost.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is considered part of a standard EAL scheme.

The communication methods derived for this EAL are consistent with the overall EAL scheme development guidance, address the site-specific implementation strategies provided, and are considered part of a standard EAL scheme.

The licensee-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b}(4}, and therefore, is acceptable for implementation.

3.2.5 EAL CU5 This EAL does not require an EAL set within the overall EAL scheme as the EAL's intent is to highlight the significance of inadvertent criticality events by ensuring an EAL is declared if unplanned positive and sustained period is observed on nuclear instrumentation.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is considered part of a standard EAL scheme.

The licensee-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

-10 3.2.6 EAL CU6 This EAL does not require an EAL set within the overall EAL scheme as the EAL's intent is to ensure an EAL is declared when a loss of direct current (DC) power event occurs as it compromises the ability of the licensee to monitor and control the removal of decay heat during Cold Shutdown or Refueling modes of operation.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is considered part of a standard EAL scheme.

The licensee-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.3 CATEGORY 'E' -INDEPENDENT SPENT FUEL STORAGE INSTALLATION (lSFSI) 3.3.1 EAL EU1 This EAL does not require an EAL set within the overall EAL scheme as the EAL's intent is limited to radiological events at the ISFSI. While security-related events at the ISFSI are also of concern, they are bounded by the licensee's EAL HA4.1.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The numbering, sequencing, and format of this EAL are consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is considered part of a standard EAL scheme.

The licensee-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.4 CATEGORY 'H' - HAZARDS 3.4.1 EAL Set HA 1/HU 1 The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. In addition, the licensee chose to use mathematical symbols instead of their noun equivalent where applicable. The numbering, sequencing, and format of this EAL set is consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is considered part of a standard EAL scheme.

- 11 The instrumentation and set points derived for this EAL set are consistent with the overall EAL scheme development guidance, address the site-specific implementation strategies provided, and are considered part of a standard EAL scheme.

The method of determining seismic events is consistent with the development strategies stated in the generic EAL development guidance but it is different than the wording in the guidance due to seismic equipment limitations at JAFNPP. Seismic event classification criteria, for both the Notification of Unusual Event and Alert classification levels, are appropriate, considered part of a standard EAL scheme, and meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, are acceptable for implementation.

High wind and tornado events, as well as the development of site-specific areas considered in these EALs, are consistent with the development strategies stated in the generic EAL development guidance, even though the actual wording used is different. However, these EALs are considered part of a standard EAL scheme and meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4). Therefore, these EALs are acceptable for implementation.

Rotating equipment failures from the main turbine are appropriately developed using the generic EAL development guidance with site-specific terminology and site-specific areas of consideration determined for these EALs. While consistent with the development strategies stated in the generic EAL development guidance, the actual wording used is different.

However, these EALs are considered part of a standard EAL scheme and meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4).

Therefore, these EALs are acceptable for implementation.

Internal flooding events are appropriately developed using the generic EAL development guidance with site-specific terminology and site-specific areas of consideration determined for these EALs. While consistent with the development strategies stated in the generic EAL development guidance, the actual wording used is different. However, these EALs are considered part of a standard EAL scheme and meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4). Therefore, these EALs are acceptable for implementation.

The licensee developed additional EALs related to lake level and emergency service water (ESW) intake bay water level for the Notification of Unusual Event and Alert classification levels.

The instrumentation and set points developed for these EALs are appropriate and applicable for this licensee. The generic EAL scheme development guidance, as well as NUREG 0654/FEMA-REP-1, has the licensee consider unique hazard events applicable to their specific site and to develop site-specific EALs to address these hazards. These EALs are considered part of a standard EAL scheme and meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4). Therefore, these EALs are acceptable for im plementation.

Events based upon vehicle crashes within the protected area or vital area has typically been difficult to differentiate between the Notification of Unusual Event and Alert classification levels.

GL 79-50, NUREG-0654/FEMA-REP-1, and NUMARC/NESP-007 used language equating vehicles to aircraft, trains, and barges. NEI 99-01 Revision 4 used language equating vehicles to that large enough to cause damage. With the issuance of NRC Bulletin 2005-02 (Reference

- 12 13), the need for EALs related to airborne, waterborne, or land-based security events have been resolved with the development of security-specific EALs. In addition, the intended basis for a Notification of Unusual Event EAL is, among other considerations, the resultant degradation in the level of safety of the plant. Eliminating the Notification of Unusual Event EAL due to vehicle crashes is consistent with the intent of the Notification of Unusual Event classification and removes any misunderstanding with the remaining Alert classification. The Alert classification is based upon indications of degraded performance or visible damage to a specific list of areas considered applicable to this EAL. Removing the Notification of Unusual Event EAL based upon vehicle crashes, and revising the wording of the remaining Alert EAL, continues to be considered part of a standard EAL scheme and meets the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4). Therefore, these EALs are acceptable for implementation.

The licensee-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.4.2 EAL Set HA2/HU2 The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The numbering, sequencing, and format of this EAL set is consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is considered part of a standard EAL scheme.

The development of site-specific areas considered in these EALs is consistent with the development strategies stated in the generic EAL development guidance even though the actual wording used is different, and is considered part of a standard EAL scheme.

The licensee-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.4.3 EAL Set HA3/HU3 The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The numbering, sequencing, and format of this EAL set is consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is considered part of a standard EAL scheme.

The development of site-specific areas considered in these EALs, is consistent with the development strategies stated in the generic EAL development guidance even though the actual wording used is different, and is considered part of a standard EAL scheme.

The licensee-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic

- 13 EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.4.4 EAL Set HG4/HS4/HA4/HU4 The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence than that provided in the generic EAL scheme development guidance. The numbering, sequencing, and format of this EAL set is consistent with the overall EAL scheme development guidance, is consistent with the site specific implementation strategies provided, and is considered part of a standard EAL scheme.

This EAL set is based upon security-related events originally developed via the guidance from NRC Bulletin 2005-02 (Reference 13) or RIS 2006-12 (Reference 14) for licensees to implement regardless of the specific version of the generic EAL scheme development guidance used, or if the particular licensee developed their EAL scheme using an alternative approach. Based upon lessons learned from implementation and use of this EAL set, particularly from when licensees performed combined security and emergency preparedness drills, the NRC staff and the industry worked to enhance the language of these EALs so as to eliminate any confusion without changing the intent of the EAL set as set forth in NRC Bulletin 2005-02 and RIS 2006-12. The NRC staff generated EAL Frequently Asked Question (EALFAQ) 2009-48 (Reference 15) to address the changes made to the generic EAL scheme development guidance document.

The development of this EAL set is consistent with the guidance provided in NRC Bulletin 2005-02 and RIS 2006-12, as further enhanced by the lessons learned from implementation and drills, and revised in NEI 99-01 Revision 5 and evaluated in EALFAQ 2009-48.

The licensee-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.4.5 EAL Set HS5/HA5 The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence than that provided in the generic EAL scheme development guidance. The numbering, sequencing, and format of this EAL set is consistent with the overall EAL scheme development guidance, is consistent with the site specific implementation strategies provided, and is considered part of a standard EAL scheme.

The licensee-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

- 14 3.4.6 EAL Set HG6/HS6/HA6/HU6 The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence than that provided in the generic EAL scheme development guidance. The numbering, sequencing, and format of this EAL set is consistent with the overall EAL scheme development guidance, is consistent with the site specific implementation strategies provided, and is considered part of a standard EAL scheme.

The licensee-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.5 CATEGORY'S' - SYSTEM MALFUNCTION 3.5.1 EAL Set SG1/SS1/SA1/SU1 The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. In addition, the licensee chose to use mathematical symbols instead of their noun equivalent where applicable. The numbering, sequencing, and format of this EAL set is consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is considered part of a standard EAL scheme.

The instrumentation, values, and listing of applicable power sources derived for this EAL set are consistent with the overall EAL scheme development guidance, address the site-specific implementation strategies provided, and are considered part of a standard EAL scheme.

The licensee-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.5.2 EAL Set SG2/SS2/SA2/SU2 The licensee chose to modify this EAL set by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance, as well as incorporating SU2 into this EAL set as the generic EAL scheme development guidance has it as a stand-alone EAL. In addition, the licensee chose to use mathematical symbols instead of their noun equivalent where applicable.

The numbering, sequencing, and format of this EAL set is consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is considered part of a standard EAL scheme.

The instrumentation and set pOints derived for this EAL set are consistent with the overall EAL scheme development guidance, address the site-specific implementation strategies provided, and are considered part of a standard EAL scheme.

- 15 The licensee-specific implementation method for this EAL set is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.5.3 EAL SU3 This EAL does not require an EAL set within the overall EAL scheme as the EAL's intent is to ensure an EAL is declared when the plant is not brought into the required operating mode within the time allowed via their Technical Specifications Limiting Condition for Operation (LCO) action statement completion time.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. In addition, the licensee chose to use mathematical symbols instead of their noun equivalent where applicable. The numbering and format of this EAL is consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is considered part of a standard EAL scheme.

The licensee-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.5.4 EAL Set SS4/SA4/SU4 The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format other than that provided in the generic EAL scheme development guidance. The licensee also chose to incorporate the loss of communication methods EAL into this EAL set, rather than as a stand-alone EAL as reflected in the generiC EAL scheme development guidance. In addition, the licensee chose to use mathematical symbols instead of their noun equivalent where applicable. The numbering, sequencing, and format of this EAL set is consistent with the overall EAL scheme development guidance and with the site-specific implementation strategies provided, and is considered part of a standard EAL scheme. This includes incorporating the loss of communication methods EAL into the EAL set.

The communication methods derived for this EAL are consistent with the overall EAL scheme development guidance, address the site-specific implementation strategies provided, and are considered part of a standard EAL scheme.

The instrumentation and set points derived for this EAL set are consistent with the overall EAL scheme development guidance, address the site-specific implementation strategies provided, and are considered part of a standard EAL scheme.

The licensee-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

- 16 3.5.5 EAL SU5 This EAL does not require an EAL set within the overall EAL scheme as the EAL's intent is to ensure an EAL is declared when the plant has indications of fuel clad degradation. By design, this EAL is redundant with corresponding indicators from a loss or potential loss of fission barriers, as well as radiation monitoring, to ensure reactor and/or fission barrier events are recognized regardless of the particular EAL table a licensee may be referring to.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The numbering, sequencing, and format of this EAL is consistent with the overall EAL scheme development guidance, is consistent with the site specific implementation strategies provided, and is considered part of a standard EAL scheme.

The licensee-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.5.6 EAL SU6 This EAL does not require an EAL set within the overall EAL scheme as the EAL's intent is to ensure an EAL is declared when the plant has indications of reactor coolant system (RCS) leakage. By design, this EAL is redundant with corresponding indicators from a loss or potential loss of fission barriers, as well as radiation monitoring, to ensure reactor and/or fission barrier events are recognized regardless of the particular EAL table a licensee may be referring to.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The numbering, sequencing, and format of this EAL is consistent with the overall EAL scheme development guidance, is consistent with the site specific implementation strategies provided, and is considered part of a standard EAL scheme.

The licensee-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.5.7 EAL SU7 This EAL does not require an EAL set within the overall EAL scheme as the EAL's intent is to ensure an EAL is declared when a loss of DC power event occurs as it compromises the ability of the licensee to monitor and control the removal of decay heat.

The licensee chose to modify this EAL by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The numbering, sequencing, and format of this EAL is consistent with the overall EAL scheme development guidance, is consistent with the site specific implementation strategies provided, and is considered part of a standard EAL scheme.

- 17 The licensee-specific implementation method for this EAL is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4), and therefore, is acceptable for implementation.

3.6 CATEGORY 'F' - FISSION BARRIER MATRIX This category is unique in the overall EAL scheme as the thresholds are not intended to be stand alone indicators of a particular event occurring at the site. Rather, they are to be used as triggers within the particular logic configuration needed to reflect a loss or potential loss of a fission barrier. Each licensee has three fission barriers: fuel cladding, the RCS, and the primary containment. Licensees are to develop thresholds that provide EAL decision-makers input into making an event declaration based upon degradation of one or more of these fission barrier barriers.

While there are only four EALs within this set (FG1JFS1/FA1/FU1), there are numerous triggers used as logic inputs to decide on the appropriate classification based upon the number of loss and/or potential loss indicators that are triggered for each barrier. By design, these indicators are redundant with other similar indicators in the Category 'A' and Category'S' EAL sets due to importance of licensees being able to recognize reactor and/or fission barrier events as timely as possible using the best available indicators from several different perspectives.

The NRC staff verified that the logic used to determine the appropriate emergency classification is consistent with the generic EAL scheme development guidance, as well as being consistent with what the licensee had already been approved by SE dated June 5, 1995.

The instrumentation and set points derived for this EAL category are consistent with the overall EAL scheme development guidance, address the site-specific implementation strategies provided, and are considered part of a standard EAL scheme.

The licensee chose to modify this EAL category by using a site-specific implementation method that uses a modified numbering format and EAL sequence other than that provided in the generic EAL scheme development guidance. The numbering, sequencing, and format of this EAL is consistent with the overall EAL scheme development guidance, is consistent with the site-specific implementation strategies provided, and is considered part of a standard EAL scheme The licensee-specific implementation method for this EAL category is in alignment with the key characteristics of an effective EAL scheme, and while different than that provided in the generic EAL development guidance, it continues to meet the requirements of Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b}(4), and therefore, is acceptable for implementation.

4.0 CONCLUSION

The technical and regulatory review of the proposed changes to the JAFNPP EAL scheme performed by NRC staff has determined that the proposed changes meet the guidance in NEI 99-01, which is an acceptable alternative for development of an EAL scheme. This determination considered the many site-specific modifications reviewed by the NRC staff.

Based on this determination, the staff concludes that the proposed EAL scheme meets the

- 18 standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, and provide reasonable assurance that the licensee can and will take adequate protective measures in a radiological emergency. Therefore, the NRC staff approves the proposed change to the EAL scheme.

5.0 REFERENCES

1. Entergy Nuclear Northeast, letter dated April 8, 2010, to U.S. Nuclear Regulatory Commission, "Change of Emergency Action Level Scheme from NUMARC/NESP-007, Revision 2, to NE199-01 Revision 5," (ADAMS Accession No. ML101100621 [packageD.
2. Entergy Nuclear Northeast, letter dated February 4, 2011, to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Re: James A. FitzPatrick Nuclear Power Plant Emergency Action Level Scheme Changes - Request for NRC review and approval," (ADAMS Accession No. ML110350536 [packageD.
3. Entergy Nuclear Northeast, letter dated March 23, 2011, to U.S. Nuclear Regulatory Commission, "EAL Upgrade to NEI 99-01 R5, Implementation Date and Justification (ME3787)" (ADAMS Accession No. ML110830901).
4. Nuclear Energy Institute (NEI) 99-01, Revision 5, "Methodology for Development of Emergency Action Levels," February 2008 (ADAMS Accession No. ML080450149).
5. Nuclear Management and Resources Council I National Environmental Studies Project (NUMARC I NESP) - 007,"Methodology for Development of Emergency Action Levels,"

Revision 2, dated January 1992 (ADAMS Accession No ML041120174).

6. NRC Safety Evaluation dated June 5,1995, (ADAMS Legacy Library 10# 9506220192).
7. Generic letter 79-50 dated October 10,1979 (ADAMS Accession No. ML031320278).
8. U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," NUREG-0654/FEMA-REP-1, November 1980 (ADAMS Accession No. ML040420012).
9. NEI 99-01 Revision 4, "Methodology for Development of Emergency Action Levels,"

dated January 2003 (ADAMS Accession No. ML041470143).

10. U.S. Nuclear Regulatory Commission, "Emergency Planning and Preparedness for Nuclear Power Reactors," Regulatory Guide 1.101, Revision 3, dated August 1992 (ADAMS Accession No. ML003740302) and Revision 4, dated July 2003 (ADAMS Accession No. ML032020276).
11. Miller, C. G., U.S. Nuclear Regulatory Commission, Letter to Alan Nelson, Nuclear Energy Institute, "U.S. Nuclear Regulatory Commission Review and Endorsement of NEI-99-01, Revision 5, dated February 2008," dated February 22, 2008 (ADAMS Accession No. ML080430535).

- 19

12. U.S. Nuclear Regulatory Commission, Regulatory Issue Summary 2003-18, with Supplements 1 and 2, "Use of NEI-99-01, 'Methodology for Development of Emergency Action Levels,' dated January 2003," dated October 8,2003 (ADAMS Accession Nos.

ML032580518, ML041550395, and ML051450482).

13. NRC Bulletin 2005-02, "Emergency Preparedness and Response Actions for Security Based Events," dated July 18, 2005 (ADAMS Accession No. ML051740058).
14. NRC Regulatory Issue Summary 2006-12, "Endorsement of Nuclear Energy Institute Guidance "Enhancements to Emergency Preparedness Programs for Hostile Action",

(ADAMS Accession No. ML072670421).

15. Emergency Action Level Frequently Asked Question 2009-48, (ADAMS Accession No. ML100710728).

Principal Contributor: D. A. Johnson, I\JSIR/DPR Date: April 20, 2011

April 20, 2011 Vice President, Operations Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093 SUB~IECT: JAMES A. FITZPATRICK NUCLEAR POWER PLANT - APPROVAL OF CHANGE OF EMERGENCY ACTION LEVEL SCHEME FROM NUMARC/NESP-007, REVISION 2, TO NEI 99-01, REVISION 5 (TAC NO. ME3787)

Dear Sir or Madam:

By letter dated April 8, 2010, as supplemented by letter dated February 4, and March 23, 2011, Entergy Nuclear Operations, Inc. (Entergy or the licensee), requested prior U.S. Nuclear Regulatory Commission (NRC) approval for proposed changes to the emergency action levels (EAL) scheme for the James A. FitzPatrick Nuclear Power Plant (JAFNPP). The requested changes to the EAL scheme support a conversion from their current EAL scheme to a scheme based on the Nuclear Energy Institute (NEI) 99-01, "Methodology for Development of Emergency Action Levels," Revision 5, dated February 2008.

The NRC staff has completed its review. Based on the information provided by the licensee, the NRC staff finds that the proposed JAFNPP EAL Scheme revision, provided in the licensee's letter, dated April 8, 2010, as supplemented by letter dated February 4, and March 23, 2011, is consistent with the guidance in NEI 99-01, Revision 5, which is an acceptable alternative for development of an EAL scheme and meets the standards in 10 CFR 50.47(b) and the requirements in 10 CFR Part 50, Appendix E, Section IV-B.

Therefore, the NRC staff approves the proposed change to the EAL scheme. A copy of the related Safety Evaluation is enclosed.

Sincerely, lraJ Eric J.Leeds, Director Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosures:

Safety Evaluation cc: Listserv DISTRIBUTION:

PUBLIC LPL1-1 R/F RidsNrrDorlLPL1-1 RidsOGCMailCenter RidsNrrDirsltsb RidsAcrsAcnwMailCenter RidsNrrPMFitzPatrick MGray, R1 RidsNsirDprOrlob RidsNrrDd DJohnson, NSIR/ORLOB RidsNrrLASLittle (paper copy) JAnderson, NSIR/ORLOB ADAMS Accession No.: ML11069AOO1 (*) No su bstantla

. I change to SE Input Memo OFFICE LPL 1-1\PM LPL 1-1\LA NSIR/DPR/ORLOB/BC(*) LPL 1-1\BC NRR/DORUD NRR/D NAME BVaidya SLittie JAnderson NSalgado JGiitter ELeeds DATE 04/11/11 04/11/11 03/30/11 04/11/11 04/12/11 04/20/11 Official Record Copy

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