0CAN031801, Unit 2 - License Amendment Request - Adoption of Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6
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Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
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0CAN031801 March 29, 2018
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555
License Amendment Request Adoption of Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6 Arkansas Nuclear One, Unit 1 and Unit 2 Docket Nos. 50-313, 50-368 and 72-13 License Nos. DPR-51 and NPF-6
Specifically, the proposed change involves revising the Emergency Plan for ANO to adopt the
Nuclear Energy Institute's (NEI's) revised Emergency Action Level (EAL) scheme described in
NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors,"
which has been endorsed by the Nuclear Regulatory Commission (NRC) as documented in the referenced letter. ANO currently uses an EAL scheme based on NEI 99-01, Revision 5. The proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and no significant environmental impacts are associated with the proposed changes.
10 CFR Part 50, Appendix E, Section IV.B.2, stipulates that a licensee desiring to change its entire EAL scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. In its endorsement of the guidance, the NRC notes that NEI 99-01, Revision 6, is considered a significant change to the EAL scheme development methodology, and licensees seeking to use this guidance in the development of EAL schemes must adhere to the requirements of 10 CFR Part 50, Appendix E, Section IV.B.2. Therefore, pursuant to 10 CFR 50.90, Entergy requests NRC review and approval of a revision to the Emergency Plan EALs for ANO.
0CAN031801 Page 2 of 3
Enclosure 1 provides an evaluation of the proposed changes. Enclosure 2 provides the NEI 99-01, Revision 6, EAL Technical Basis marked to illustrate the proposed changes. provides the revised (clean) EAL Technical Basis document.
provides a deviation-difference document comparing NEI 99-01, Revision 6, with the proposed changes to the ANO EAL schemes. Enclosure 5 includes an EAL matrix chart and review table (for information only), which is a quick-reference tool developed to support timely Emergency Response Organization personnel EAL determinations. Finally, Enclosure 6 provides specific reference documents or excerpts which support related ANO Emergency Plan proposed changes.
Approval of the proposed amendment is requested by April 1, 2019. Once approved, the amendment shall be implemented by October 30, 2019.
No new regulatory commitments are included in this amendment request.
The proposed Initiating Conditions and EALs have been reviewed by the ANO Onsite Safety Review Committee. In addition, the proposed changes associated with adoption of NEI 99-01, Revision 6, were discussed with state and county officials on December 5, 2017, during a meeting conducted at the Pope County Courthouse. Representatives from the Arkansas Department of Health, Conway County, Johnson County, Logan County, Pope County, and Yell County were present. In accordance with 10 CFR 50.91, Entergy is notifying the State of Arkansas of this amendment request by transmitting a copy of this letter and enclosure to the designated State Official.
If there are any questions or if additional information is needed, please contact Stephenie Pyle at 479-858-4704.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on March 29, 2018.
Sincerely, ORIGINAL SIGNED BY RICHARD L. ANDERSON RLA/dbb
- 1. Evaluation of Proposed Changes 2. Proposed EAL Technical Basis Document (Markup) 3. Proposed EAL Technical Basis Document (Clean) 4. NEI 99-01, Rev. 6, Deviations and Differences, ANO Units 1 and 2
- 5. Proposed EAL Matrix Chart and Review Table (for information only)
- 6. Supporting Referenced Document Pages
0CAN031801 Page 3 of 3
cc: Mr. Kriss Kennedy Regional Administrator U. S. Nuclear Regulatory Commission RGN-IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310
One White Flint North 11555 Rockville Pike
Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street
Slot #30 Little Rock, AR 72205
Enclosure 1 to 0CAN031801 Evaluation of the Proposed Changes to 0CAN031801
Page 1 of 8 EVALUATION OF THE PROPOSED CHANGEs 1.0
DESCRIPTION Entergy Operations, Inc. (Entergy) proposes to revise the Arkansas Nuclear One, Units 1 and 2 (ANO-1 and ANO-2, collectively referred to as ANO) currently approved Emergency Plan (EP) Emergency Action Level (EAL) scheme, which is based on the Nuclear Energy Institute's (NEI's) guidance established in NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels" (Reference 1). Entergy is proposing to adopt the EAL schemes based on the guidance provided in NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," which has been endorsed by the NRC (Reference 2)
Clarification of numerous EALs that have been typically misinterpreted by the industry in the development of their site-specific EAL scheme, Clarification of the intent of EALs that have been historically misclassified, Providing additional guidance for the development of EALs for current non-passive reactor designs as well as possible future reactor designs that are non-passive, Incorporating lessons learned from industry events (i.e., Fukushima and others) and NUREG/CR-7154, "Risk Informing Emergency Preparedness Oversight: Evaluation of Emergency Action Levels - A Pilot Study of Peach Bottom, Surry and Sequoyah," and A detailed review of the guidance to re-validate that the EALs are appropriate and are at the necessary emergency classification level based upon 32 years of industry and NRC experience with EAL scheme development and implementation.
, "Proposed EAL Technical Basis Document (Markup)," provides a markup of the current ANO EAL scheme basis illustrating changes incorporating the guidance of NEI 99-01, Revision 6. Enclosure 3 provides a clean copy of ANO EAL Technical Basis document.
2.2 Deviations and Differences Enclosure 4 contains a matrix that provides a comparison of the ICs and EALs in NEI 99-01 to the ICs and EALs proposed for ANO. The comparison evaluates differences and deviations consistent with the similar exercise performed during the ANO EP upgrade to NEI 99-01, Revision 5 (Reference 3). The NRC approved ANO's EP upgrade to NEI 99-01, Revision 5, on November 9, 2012 (Reference 4).
Page 2 of 8 A difference is an EAL change where the basis scheme guidance differs in wording, but agrees in meaning and intent, such that classification of an event would be the same, whether using the basis scheme guidance or the site-specific proposed EAL. Examples of differences include the use of site-specific terminology or administrative re-formatting of site-specific EALs.
A deviation is an EAL change where the basis scheme guidance differs in wording and is altered in meaning or intent, such that classification of the event could be different between the basis scheme guidance and the site-specific proposed EAL. Examples of deviations include the use of altered mode applicability, altering key words or time limits, or changing words of physical reference (protected area, safety-related equipment, etc.).
A number of differences are the result of adding plant-specific information to the EALs. In these cases, Enclosure 4 may refer the reader to an associated document in Enclosure 6, "Supporting Referenced Document Pages," which provides the technical basis for plant-specific information.
2.3 Generic Differences
The differences below apply throughout the set of EALs and are not specifically identified in each instance in the comparison matrix as a difference.
NEI 99-01, Rev 6 EALs ANO Station EALs References BWRs Deleted BWR references as appropriate Uses E-HU for ISFSI ICs Uses EU for ISFSI ICs Designates ICs and EALs as Example: (IC)HU1 EAL 2 Designates ICs and EALs as Example: HU1.2 Emergency Classification ICs are presented together by Emergency Classification level (all NOUEs grouped together, then all Alerts, etc.) for each category (A, C, H, etc.), in ascending order (UE - GE) Emergency Classification ICs are presented by Emergency Classification "family" (A-1, A-2, A-3, etc.) for each category, in ascending order (UE - GE) to 0CAN031801
The following tables provide the operating modes for both ANO units as defined by the respective Technical Specifications (TSs).
ANO-1 MODE TITLE REACTIVITY CONDITION (K eff) % RATED THERMAL POWER (a) AVERAGE REACTOR COOLANT TEMPERATURE (°F) 1 2 3 4 5 6 Power Operation Startup Hot Standby Hot Shutdown (b) Cold Shutdown (b) Refueling (c) 0.99 0.99 < 0.99 < 0.99 < 0.99 NA > 5 5 NA NA NA NA NA NA 280 280 > Tavg > 200 200 NA (a) Excluding decay heat. (b) All reactor vessel head closure bolts fully tensioned. (c) One or more reactor vessel head closure bolts less than fully tensioned.
ANO-2 MODE REACTIVITY CONDITION, K eff %RATED THERMAL POWER*
- 1. POWER OPERATION 0.99 > 5% 300 °F 2. STARTUP 0.99 5% 300 °F 3. HOT STANDBY < 0.99 0 300 °F 4. HOT SHUTDOWN < 0.99 0 300 °F > T avg > 200 °F 5. COLD SHUTDOWN < 0.99 0 200 °F 6. REFUELING** 0.95 0 140 °F
- Excluding decay heat. ** Reactor vessel head unbolted or removed and fuel in the vessel.
Page 4 of 8 In addition to the TS defined operational modes, NEI 99-01, Revision 6, defines the following additional mode:
Defueled: All reactor fuel removed from the reactor vessel (i.e., full core off load during refueling or extended outage).
ANO procedures recognize and are consistent with the definition of a defueled condition.
2.6 Background Technical Information Enclosure 2 provides the existing EAL Technical Basis document marked to illustrate the proposed changes. Enclosure 3 provides the revised (clean) EAL Technical Basis document. Enclosure 4 provides a deviation-difference document comparing NEI 99-01, Revision 6, with the proposed changes to the ANO EAL schemes. Enclosure 5 includes an EAL matrix chart and review table (for information only), which is a quick-reference tool developed to support timely Emergency Response Organization personnel EAL determinations. Enclosure 6 provides specific reference documents or excerpts which support related ANO Emergency Plan proposed changes.
3.0 TECHNICAL EVALUATION
Entergy has evaluated the proposed changes to determine whether applicable regulations and requirements have been met. NEI 99-01 guidance methodology includes many years of development, along with use and implementati on. The guidance has been subject to NRC reviews and approval. The ANO EAL scheme currently in place is based on the methodology in NEI 99-01, Revision 5. NEI 99-01, Revision 6, is the latest version endorsed by the NRC and provides guidance to nuclear power plant operators for the development of a site-specific emergency action level scheme.
10 CFR 50.47(b)(4) requires that emergency plans include a standard emergency classification and action level scheme. This scheme is a fundamental component of an EP in that it provides the defined thresholds that will allow site personnel to rapidly implement a range of pre-planned emergency response measures. An emergency classification scheme also facilitates timely decision-making by an offsite response organization concerning the implementation of precautionary or protective actions for the public NEI 99-01, Revision 6, contains a generic set of ICs, EALs, and fission product barrier status thresholds. The guidance also includes supporting technical basis information, developer notes, and recommended classification instructions for users. The methodology described in this document is consistent with NRC requirements and guidance. In particular, this methodology was specifically endorsed by the NRC in a March 28, 2013, letter from NRC to NEI (Reference 2) and determined to provide an acceptable approach in meeting requirements of 10 CFR 50.47(b)(4), applicable requirements of 10 CFR 50, Appendix E, and the associated to 0CAN031801
Page 5 of 8 planning standard evaluation elements contained in NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980.
10 CFR 50, Appendix E, Section IV.B.2, requires that a licensee desiring to change its entire EAL scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. The proposed change to the ANO EAL scheme from NEI 99-01, Revision 5, to NEI 99-01, Revision 6, guidance does not reduce the capability to meet the applicable emergency planning standards and requirements in 10 CFR 50.47(b) and 10 CFR 50, Appendix E. Accordingly, pursuant to the requirements of 10 CFR 50, Appendix E, Section IV.B.2, Entergy requests NRC review and approval of the proposed changes to the EAL scheme as a license amendment request in accordance with 10 CFR 50.90.
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria
The regulations in 10 CFR 50.54(q) provide direction to licensees seeking to revise emergency plans. The requirements related to nuclear power plant emergency plans are contained in the standards in 10 CFR 50.47, "Emergency Plans," and the requirements of Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities."
Paragraph 10 CFR 50.47(a)(1) states that no 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) contains standards that onsite and offsite emergency response plans must
meet for the 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, 10 CFR 50.47(b)(4), requires that emergency plans include a standard emergency classification and action level scheme.
10 CFR 50, Appendix E, Section IV.B, "Assessment Actions,"
requires that emergency plans include emergency action levels (EALs) that are to be used as criteria for determining the need for notification and participation of local and state agencies, and for determining when and what type of protective measures should be considered to protect the health and safety of individuals both onsite and offsite. EALs are to be based on plant conditions and instrumentation, as well as onsite and offsite radiological monitoring. Section IV.B provides that initial EALs shall be discussed and agreed on by the applicant and state and local authorities, be approved by the NRC, and reviewed annually thereafter with state and local authorities. Therefore, a revision to EALs will require NRC approval prior to implementation, if it involves (1) changing from one EAL
scheme to another (e.g., NEI 99-01, Revision 4 to NEI 99-01, Revision 6), (2) proposing an alternate method to comply with the regulations, or (3) the EAL revision proposed by the licensee decreases the effectiveness of the emergency plan.
NRC Regulatory Issue Summary (RIS) 2005-02, Revision 1, "Clarifying the Process for Making Emergency Plan Changes", issued April 19, 2011, says that 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, but due to the potential safety significance of the change, the change needs prior NRC review and approval. to 0CAN031801
Page 6 of 8 The proposed changes meet the above regulatory requirements.
Callaway - Amendment 212 (Reference 5) Fermi 2 - Amendment 202 (Reference 6) South Texas - Amendments 206 and 194 (Reference 7)
Summer 1 - Amendment 200 (Reference 8)
4.3 No Significant Hazards Consideration Analysis
Entergy Operations, Inc. (Entergy) proposes to revise the currently approved Emergency Plan (EP) Emergency Action Level (EAL) scheme for Arkansas Nuclear One, Units 1 and 2 (collectively referred to as ANO), which is based on the Nuclear Energy Institute's (NEI's) guidance established in NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels." Entergy is proposing to adopt the EAL schemes based on the guidance provided in NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," which has been endorsed by the NRC.
Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment." As required by 10 CFR 50.91(a), Entergy analysis of the issue of no significant hazards consideration is presented below.
- 1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed changes to the ANO EALs do not involve any physical changes to plant equipment or systems and do not alter the assumptions of any accident analyses. The proposed changes do not adversely affect accident initiators or precursors and do not alter design assumptions, plant configuration, or the manner in which the plant is operated and maintained. The proposed changes do not adversely affect the ability of structures, systems or components (SSCs) to perform intended safety functions in mitigating the consequences of an initiating event within the assumed acceptance limits.
Therefore, the changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
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- 2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No No new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of the proposed changes. The changes do not challenge the integrity or
performance of any safety-related systems. No plant equipment is installed or removed, and the changes do not alter the design, physical configuration, or method of operation of any plant SSC. Because EALs are not accident initiators and no physical changes are made to the plant, no new causal mechanisms are introduced.
Therefore, the changes do not create the possibility of a new or different kind of accident
from an accident previously evaluated.
- 3. Do the proposed changes involve a significant reduction in a margin of safety?
Response: No Margin of safety is associated with the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed changes do not impact operation of the plant and no accident analyses are affected by the proposed changes. The changes do not affect the Technical Specifications or the method of operating the plant. Additionally, the proposed changes will not relax any criteria used to establish safety limits and will not relax any safety system settings. The safety analysis acceptance criteria are not affected by these changes. The proposed changes will not result in plant operation in a configuration outside the design basis. The proposed changes do not adversely affect systems that respond to safely shut down the plant and to maintain the plant in a safe shutdown condition.
Therefore, the changes do not involve a significant reduction in a margin of safety.
Based upon the reasoning presented above, Entergy concludes that the requested change involves no significant hazards consideration, as set forth in 10 CFR 50.92(c), "Issuance of Amendment."
In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
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5.0 ENVIRONMENTAL CONSIDERATION
The proposed changes are applicable to emergency planning requirements involving the proposed adoption of the NRC-endorsed EAL guidance as described in NEI 99-01, Revision 6, and do not reduce the capability to meet the emergency planning standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E. The proposed changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed changes.
- 1. NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels" February 2008 (ML080450149)
- 2. NRC letter "U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, Dated November, 2012 (TAC No. D92368)," March 28, 2013 (ML12346A463)
- 3. Entergy letter dated December 1, 2011, "Proposed Emergency Action Levels Using NEI 99-01, Revision 5 Scheme," (ML113350317) (0CAN121102)
- 4. NRC Safety Evaluation dated November 9, 2012, "Arkansas Nuclear One, Units 1 and 2 - Approval of Conversion of the Emergency Action Level Scheme to a Scheme Based on Nuclear Energy Institute (NEI) 99-01, Revision 5," (TAC Nos. ME7661 and ME7662) (ML12269A455) (0CNA111201)
- 5. NRC letter "Callaway Plant, Unit 1 - Issuance of Amendment Re: Upgrade to Emergency Action Level Scheme (CAC No. MF4945)," October 7, 2015 (ML15251A493)
- 6. NRC letter "Fermi 2 - Issuance of Amendment to Revise the Emergency Action Level Scheme for the FERMI 2 Emergency Plan (TAC No. MF5048)," September 29, 2015 (ML15233A084)
- 7. NRC letter "South Texas Project, Units 1 and 2 - Re: Upgrade to Emergency Action Level Scheme (TAC Nos. MF4195 and MF4196)," August 20, 2015 (ML15201A195)
- 8. NRC letter "Virgil C. Summer Nuclear Station, Unit 1 - Issuance of Amendment to Revise Emergency Action Levels to a Scheme Based on NEI 99-01, Revision 6 (TAC No. MF3927)," (ML15063A55)
- 9. NRC letter "Seabrook Station, Unit No. 1 - Issuance of Amendment RE: Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6 (CAC No. MF7439),"
February 10, 2017 (ML16358A411)