ML080370034

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Request for Additional Information Proposed Revisions to Emergency Action Levels
ML080370034
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 02/12/2008
From: Markley M
NRC/NRR/ADRO/DORL/LPLIV
To: Bannister D
Omaha Public Power District
Markley, M T, NRR/DORL/LP4, 301-415-5723
References
TAC MD5431
Download: ML080370034 (8)


Text

February 12, 2008 Mr. David J. Bannister Site Director Omaha Public Power District Fort Calhoun Station FC-2-4 Post Office Box 550 Fort Calhoun, NE 68023-0550

SUBJECT:

FORT CALHOUN STATION, UNIT NO. 1 - REQUEST FOR ADDITIONAL INFORMATION RE: REQUEST FOR REVISION TO THE EMERGENCY ACTION LEVEL SCHEME (TAC NO. MD5431)

Dear Mr. Bannister:

By letter dated April 30, 2007, and supplemented in a letter dated October 9, 2007, the Omaha Public Power District (OPPD) submitted a request for approval to change the existing Emergency Action Level (EAL) scheme for the Fort Calhoun Station, Unit 1, Renewed Facility Operating License No. DPR-40, to that described in Nuclear Energy Institute 99-01, Revision 4, Methodology for Development of Emergency Action Levels (Agencywide Documents Access and Management System Accession No. ML030230250).

The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided and determined that additional information is required in order to complete the evaluation. The enclosed request for additional information was discussed with Mr. Thomas Matthews and others of your staff on January 14, 2008. As agreed upon, the NRC staff is expecting a response within 90 days of the date of this letter.

If you have any questions, please contact me at 301-415-5723.

Sincerely,

/RA/

Michael T. Markley, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-285

Enclosure:

Request for Additional Information cc w/encl: See next page

(s).: ML080370034 OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC NAME MMarkley JBurkhardt THiltz DATE 2/8/08 2/7/08 2/12/08

Ft. Calhoun Station, Unit 1 cc:

Winston & Strawn ATTN: James R. Curtiss, Esq.

1700 K Street, N.W.

Washington, DC 20006-3817 Chairman Washington County Board of Supervisors P.O. Box 466 Blair, NE 68008 Mr. John Hanna, Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 310 Fort Calhoun, NE 68023 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Ms. Julia Schmitt, Manager Radiation Control Program Nebraska Health & Human Services R & L Public Health Assurance 301 Centennial Mall, South P.O. Box 95007 Lincoln, NE 68509-5007 Mr. Joe L. McManis Manager - Nuclear Licensing Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.

P.O. Box 550 Fort Calhoun, NE 68023-0550 Ms. Melanie Rasmussen Radiation Control Program Officer Bureau of Radiological Health Iowa Department of Public Health Lucas State Office Building, 5th Floor 321 East 12th Street Des Moines, IA 50319

REQUEST FOR ADDITIONAL INFORMATION OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION, UNIT NO. 1 DOCKET NO. 50-285 By letter dated April 30, 2007, and supplemented in a letter dated October 9, 2007, the Omaha Public Power District (OPPD) submitted a request for approval to change the existing Emergency Action Level (EAL) scheme for the Fort Calhoun Station, Unit 1, Renewed Facility Operating License No. DPR-40, to that described in Nuclear Energy Institute (NEI) 99-01, Revision 4, Methodology for Development of Emergency Action Levels (Agencywide Documents Access and Management System Accession No. ML030230250).

The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided and determined that additional information is required in order to complete the evaluation. The additional information requested was discussed with Mr. Thomas Matthews and others of your staff on January 14, 2008. As agreed upon, OPPD will consider possible enhancements in the Revision 5 version of NEI 99-01.

RAI #

Fort Calhoun EAL #

Information Requested 1

General, Front Sections Please explain the extent to which NEI 99-01, Rev. 5, will be incorporated or explain why not. Please note any other sections in the updated NEI guidance that may add value to the EALs for your site:

3.9 Emergency Action Levels 3.10 Treatment of Multiple Events and Classification Level Upgrading 3.11 Emergency Classification Level Downgrading 3.12 Classifying Transient Events 3.13 Operating Mode Applicability 2

Section 3.2 Please explain the basis for choosing to adopt new Operating Mode definitions for implementation of NEI 99-01 EALs. Specifically, explain why having Operating Modes 1 (power), 2 (hot standby), 3 (hot shutdown), 4 (cold shutdown), 5 (refuel), and D (defueled) would not work for your EALs. Normally, EAL Operating Modes are reserved for Operating Modes as stated in the approved Technical Specifications (TS), with the addition of D (defueled).

3 Section 3.3 Please explain the extent to which NEI 99-01 Rev. 5, definitions will be adopted and identify any variances that OPPD proposes to take from those definitions. Explain the basis for any differences.

Normally, definitions in a scheme change are adopted uniformly with the exception of definitions specific to plant type (i.e., PWR or BWR).

4 Procedure Note 5 Please explain the basis for this note varying from the guidance from NEI 99-01 Rev. 5.

RAI #

Fort Calhoun EAL #

Information Requested 5

EAL Table EAL AU3 is on the table but is not in the text. Please explain.

6 AU1 AA1 AA3 AS1 AG1 Please explain the extent to which NEI 99-01 Rev. 5, wording and intent will be adopted.

7 AA3 Please explain how your list of areas was determined.

8 CU1 CU2 CU3 CU4 CU6 CU7 CU8 CA1 CA3 CA4 CS1 CG1 Please explain the extent to which NEI 99-01 Rev. 5, wording and intent will be adopted.

9 CA1/CA2 CS1/CS2 Please evaluate the combination of CA1 (CS1) with CA2 (CS2) from NEI 99-01 Rev. 5 and advise the NRC if you plan to implement the EAL(s) as stated in NEI 99-01 Rev. 5.

10 E-HU1 Please explain the extent to which NEI 99-01 Rev. 5, wording and intent will be adopted.

11 FB Section Please explain the extent to which the logic table from NEI 99-01, Rev. 5 will be adopted.

12 FC Barrier Loss 2 Please explain the basis for this value.

RAI #

Fort Calhoun EAL #

Information Requested 13 HU1 HU2 HU3 HU4 HU5 HA1 HA3 HA4 HA6 HA7 HA8 HS1 HS3 HS4 HG1 HG2 Please explain the extent to which NEI 99-01 Rev. 5, wording and intent will be adopted.

14 HA4 Wording from the Security Contingency Plan should not be placed in EALs. They are subject to the differing document control processes used for each document.

15 SU1 SU3 SU5 SU6 SA2 SA4 SA5 SS1 SS2 SS3 SS4 SS6 SG2 Follow NEI 99-01 R5, dated January 2008, from NEI. This has the wording and intent clarified to align with NRC expectations.

16 SU2 Please remove or plant condition from IC and EAL or explain the basis for the necessity.

17 SU4 Please explain why Operating Mode 3 is not applicable.

18 SU8 Please explain why two or more channels... was added to the EAL. Refer to NEI definition of valid and explain the addition.