ML052020125
| ML052020125 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 07/27/2005 |
| From: | Terao D NRC/NRR/DLPM/LPD4 |
| To: | Gerald Williams Entergy Operations |
| vaidya B, NRR/DLPM, 415-3308 | |
| References | |
| TAC MC1630 NEI 99-01, Rev 4 | |
| Download: ML052020125 (7) | |
Text
July 27, 2005 Mr. George A. Williams Site Vice President Grand Gulf Nuclear Station Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150
SUBJECT:
GRAND GULF NUCLEAR STATION, UNIT 1 - RE: PROPOSED UPGRADED EMERGENCY ACTIONS LEVELS (EALs) USING NEI 99-01, REVISION 4, METHODOLOGY (TAC NO. MC1630)
Dear Mr. Williams:
By letter dated December 16, 2003, as supplemented by letters dated November 19, 2004, June 3, and July 6, 2005, you submitted proposed emergency actions levels (EALs) and EAL Bases using the methodology outlined in Nuclear Energy Institute (NEI) 99-01, Revision 4, "Methodology for Development of Emergency Action Levels." The November 19, 2004, letter was a "complete revision" of the initial submission dated December 16, 2003. The letter dated July 6, 2005, provided the complete revised version, reflecting the changes made in the supplemental letters to the EAL Matrix, initiating conditions, EAL threshold values, and the EAL Bases.
The Nuclear Regulatory Commission (NRC) staff has completed its review. The NRC staff finds that the proposed Grand Gulf Nuclear Station, Unit 1, EAL revision, provided in the licensees letter dated July 6, 2005, is consistent with the guidance in NEI 99-01, Revision 4, or provides an acceptable alternative, and meets the requirements of Paragraph 50.47(b) of Title 10 of the Code of Federal Regulations (10 CFR) and 10 CFR Part 50, Appendix E, Section IV.B. Therefore, the proposed upgrades to EALs and EAL Bases are acceptable.
The NRC staff's related safety evaluation is enclosed.
Sincerely,
/RA/
David Terao, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-416
Enclosure:
Safety Evaluation cc w/encl: See next page
July 27, 2005 Mr. George A. Williams Site Vice President Grand Gulf Nuclear Station Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150
SUBJECT:
GRAND GULF NUCLEAR STATION, UNIT 1 - RE: PROPOSED UPGRADED EMERGENCY ACTIONS LEVELS (EALs) USING NEI 99-01, REVISION 4, METHODOLOGY (TAC NO. MC1630)
Dear Mr. Williams:
By letter dated December 16, 2003, as supplemented by letters dated November 19, 2004, June 3, and July 6, 2005, you submitted proposed emergency actions levels (EALs) and EAL Bases using the methodology outlined in Nuclear Energy Institute (NEI) 99-01, Revision 4, "Methodology for Development of Emergency Action Levels." The November 19, 2004, letter was a "complete revision" of the initial submission dated December 16, 2003. The letter dated July 6, 2005, provided the complete revised version, reflecting the changes made in the supplemental letters to the EAL Matrix, initiating conditions, EAL threshold values, and the EAL Bases.
The Nuclear Regulatory Commission (NRC) staff has completed its review. The NRC staff finds that the proposed Grand Gulf Nuclear Station, Unit 1, EAL revision, provided in the licensees letter dated July 6, 2005, is consistent with the guidance in NEI 99-01, Revision 4, or provides an acceptable alternative, and meets the requirements of Paragraph 50.47(b) of Title 10 of the Code of Federal Regulations (10 CFR) and 10 CFR Part 50, Appendix E, Section IV.B. Therefore, the proposed upgrades to EALs and EAL Bases are acceptable.
The NRC staff's related safety evaluation is enclosed.
Sincerely,
/RA/
David Terao, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-416 DISTRIBUTION:
PUBLIC PDIV-1 Reading RidsOgcRp
Enclosure:
Safety Evaluation EWeiss JAnderson RidsNrrDlpmLpdiv (HBerkow) RidsNrrPMBVaidya cc w/encl: See next page RidsNrrDlpmLpdiv1(DTerao) RidsNrrLALFeizollahi RidsRgn4MailCenter (KKennedy)
RidsAcrsAcnwMailCenter Accession No.: ML052020125
- No substantial change from SE Input OFFICE PDIV-1/PM PDIV-2/LA NSIR/SC* PDIV-1/SC NAME BVaidya LFeizollahi EWeiss DTerao DATE 07/27/2005 07/27/2005 07/13/2005 07/27/2005 OFFICIAL RECORD COPY
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO PROPOSED UPGRADED EMERGENCY ACTIONS LEVELS (EALs)
USING NEI 99-01, REVISION 4, METHODOLOGY FOR GRAND GULF NUCLEAR STATION, UNIT 1 ENTERGY OPERATIONS, INC., ET AL.
DOCKET NO. 50-416
1.0 INTRODUCTION
By letter dated December 16, 2003 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML040050635), as supplemented by letters dated November 19, 2004 (ADAMS Accession No. ML043280559), June 3 (ADAMS Accession No. ML051580391), and July 6, 2005 (ML051920191), Entergy Operations, Inc. (the licensee) requested changes to the emergency action levels (EALs) for Grand Gulf Nuclear Station, Unit 1 (GGNS). The November 19, 2004, letter was a complete revision of the initial submission dated December 16, 2003. The letter dated July 6, 2005, provided the complete revised version, reflecting the changes made in the supplemental letters to the EAL Matrix, initiating conditions, EAL threshold values, and the EAL Bases.
The proposed changes revise the GGNS EALs using the guidance provided in Nuclear Energy Institute (NEI) document, NEI 99-01, Revision 4, Methodology for Development of Emergency Action Levels, (NEI 99-01) which was endorsed by the Nuclear Regulatory Commission (NRC) in Regulatory Guide (RG) 1.101, Revision 4, Emergency Planning and Preparedness for Nuclear Power Reactors.
2.0 REGULATORY EVALUATION
The applicable regulations and guidance that the NRC staff used to review the licensees submission, are discussed in the following sections:
2.1 Regulations Part 50 of Title 10 of the Code of Federal Regulations (10 CFR Part 50), Section 50.47, Emergency plans, states 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 of 10 CFR also establishes requirements that must be met by the onsite and offsite emergency response plans 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. Paragraph 50.47(b)(4) of 10 CFR stipulates that emergency plans include a standard emergency classification and action level scheme.
Part 50 of 10 CFR, Appendix E,Section IV.B, 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 health and safety. EALs are to be based on in-plant conditions and instrumentation, and on onsite and offsite monitoring.
Section IV.B of Appendix E 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. In addition, 10 CFR Part 50, Appendix E, Section IV.B states that an EAL revision must be approved by the NRC before implementation if: (1) The licensee is changing from one EAL scheme to another EAL scheme (e.g., a change from an EAL 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 EAL revision decreases the effectiveness of the emergency plan.
2.2 Guidance As stated in Section 1.0, for developing EALs required by 10 CFR Part 50, Appendix E, Section IV.B and 10 CFR Paragraph 50.47(b)(4), NRC RG 1.101, Revision 4, endorsed the guidance provided in NEI 99-01, Revision 4, as acceptable alternative methods to those described in the following documents:
- Appendix 1 to NUREG-0654/Federal Emergency Management Agency (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, provides guidance for developing or changing a standard emergency classification and action level scheme. In addition, this RIS provided recommendations to assist licensees, consistent with Part 50, Appendix E,Section IV.B, in determining whether to seek prior NRC approval of deviations from the new guidance.
3.0 TECHNICAL EVALUATION
3.1 Scope The proposed revision to the GGNS EALs involves a scheme conversion from Appendix I of NUREG-0654/FEMA-REP-1 to the NEI 99-01, Revision 4. Therefore, the proposed changes were submitted by the licensee to the NRC for approval prior to implementation, as required in Section IV.B to 10 CFR Part 50, Appendix E.
The NRC staffs evaluation of the proposed revisions to initiating conditions (ICs) and EAL threshold values is based on the licensees letter dated November 19, 2004, as supplemented by letters dated June 3 and July 6, 2005. The NRC staffs review did not consider ICs and EAL
threshold values proposed in the December 16, 2003 letter, since the revisions in the November 19, 2004, letter provided a complete revision to the licensees initial application.
ICs, entitled, Defueled Station Malfunctions, and listed under Category D in NEI 99-01 (Revision 4), are not applicable since GGNS has a current operating license, and therefore, were not considered during this technical evaluation. In addition, the licensee did not request approval of ICs, entitled, Events Related to Independent Spent Fuel Storage Installation (ISFSI), as listed under Category E in NEI 99-01, Revision 4.
Proposed deviations or differences from the guidance in NEI 99-01 (Revision 4), other than minor differences, such as station-specific terminology, system and component names, or formatting, were identified in the licensees letter dated November 19, 2004, Attachment 5, which provided a specific evaluation for each.
A complete revised version of the EAL Bases document, including EAL Matrix, ICs, and associated EAL threshold values, is provided in the licensees letter dated July 6, 2005. This EAL Bases document reflects the changes made to EAL Matrix, ICs, EAL threshold values, and Bases provided by letter dated November 19, 2004, as supplemented by letters dated June 3 and July 6, 2005.
3.2 Approval by State and Local Authorities As stated in Section 2.1, 10 CFR Part 50, Section IV.B of Appendix E states 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. In addition, 10 CFR Part 50, Appendix E, Section IV.B states that an EAL revision must be approved by the NRC before implementation if: (1) The licensee is changing from one EAL scheme to another EAL scheme (e.g., a change from an EAL 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 EAL revision decreases the effectiveness of the emergency plan.
In the Attachment 1 to the licensees letter dated November 19, 2004, the licensee provided documentation signifying agreement on implementation of the proposed EAL changes by the following offsite agencies:
- Mississippi Emergency Management Agency
- Mississippi State Department of Health
- Claiborne County Civil Defense
- Tensas Parish Office of Homeland Security & Emergency Preparedness
- Louisiana Office of Homeland Security & Emergency Preparedness The licensee also indicated in Attachment 3 to the letter dated June 3, 2005, that future changes to the EALs would be discussed and agreed upon with State and local authorities as required by 10 CFR Part 50, Appendix E, Section IV.B.
3.3 List of Commitments
The licensee has made the following commitments in Attachment 3 to the letter dated June 3, 2005:
Commitment Scheduled Completion (1) Information contained in this submittal Upon implementation of upgraded EALs.
will be included in the Emergency Plan or Basis as applicable.
(2) Approved changes will be discussed Upon implementation of upgraded EALs.
and agreed upon with State authorities as required.
3.4 Evaluation Based on the review of the information provided in the licensees submissions dated November 19, 2004, and as supplemented by letters dated June 3 and July 6, 2005, the NRC staff finds that the proposed ICs, EAL threshold values, EALs and EALs Bases are consistent with the regulatory requirements of 10 CFR 50, Appendix E, Section IV.B, 10 CFR 50.47(b)(4),
RG 1.101, Revision 4, and NEI 99-01, Revision 4, or provide acceptable alternatives, and hence the proposed GGNS EAL revisions, as reflected in the licensees letter dated July 6, 2005, are acceptable.
4.0 CONCLUSION
S The NRC staff has performed a review of the proposed GGNS EALs and EAL Bases conversion from the NUREG-0654 scheme to that using the guidance in the NEI 99-01, Revision 4, submitted by letter dated November 19, 2004, as supplemented by letters dated June 3 and July 6, 2005. The licensees letter dated July 6, 2005, provided the complete revised version of the EAL Bases document, including EAL Matrix, ICs, and associated EAL threshold values. The NRC staff finds that the proposed GGNS EAL revisions, provided in the licensees letter dated July 6, 2005, is consistent with the guidance in NEI 99-01, Revision 4, or provide an acceptable alternative as discussed in Section 3.0 above.
The NRC staff also finds that the proposed EAL changes meet the requirements of 10 CFR Paragraph 50.47(b) and 10 CFR Part 50, Appendix E, Section IV.B. Therefore, the NRC staff, based on the above discussion, concludes that: (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 Commissions regulations, and (3) the approval of the proposed emergency plan changes will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: Joseph Anderson Date: July 27, 2005
Grand Gulf Nuclear Station cc:
Executive Vice President Attorney General
& Chief Operating Officer Department of Justice Entergy Operations, Inc. State of Louisiana P. O. Box 31995 P. O. Box 94005 Jackson, MS 39286-1995 Baton Rouge, LA 70804-9005 Wise, Carter, Child & Caraway State Health Officer P. O. Box 651 State Board of Health Jackson, MS 39205 P. O. Box 1700 Jackson, MS 39205 Winston & Strawn 1700 K Street, N.W. Office of the Governor Washington, DC 20006-3817 State of Mississippi Jackson, MS 39201 Chief Energy and Transportation Branch Attorney General Environmental Compliance and Asst. Attorney General Enforcement Division State of Mississippi Mississippi Department of Environmental P. O. Box 22947 Quality Jackson, MS 39225-2947 P. O. Box 10385 Jackson, MS 39289-0385 Vice President, Operations Support Entergy Operations, Inc.
President P.O. Box 31995 Claiborne County Jackson, MS 39286-1995 Board of Supervisors P. O. Box 339 Director Port Gibson, MS 39150 Nuclear Safety Assurance Entergy Operations, Inc.
Regional Administrator, Region IV P. O. Box 756 U.S. Nuclear Regulatory Commission Port Gibson, MS 39150 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Director Nuclear Safety & Licensing Senior Resident Inspector Entergy Operations, Inc.
U. S. Nuclear Regulatory Commission 1340 Echelon Parkway P. O. Box 399 Jackson, MS 39213-8298 Port Gibson, MS 39150 General Manager, GGNS Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150 May 2005