Text

License Amendment Request - Change of EAL Scheme
	ML12359A060
Person / Time
Site:	Cook
Issue date:	12/03/2012
From:	Gebbie J; Indiana Michigan Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	AEP-NRC-2012-99, TAC ME5666, TAC ME5667
	Download: ML12359A060 (32)
	v • d • e

z INDIANA MICHIGAN Indiana Michigan Power PCR R One Cook Place Bridgman, MI 49106 A unitofAmerican Electric Power Indiana MichiganPower.com December 3, 2012 AEP-NRC-2012-99 10 CFR 50 Appendix E 10 CFR 50.90 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Docket Nos.: 50-315 50-316 Donald C. Cook Nuclear Plant Units 1 and 2 LICENSE AMENDMENT REQUEST - CHANGE TO EAL SCHEME

References:

1. Letter from J. P. Gebbie, Indiana Michigan Power Company (I&M), to U. S. Nuclear Regulatory Commission (NRC) Document Control Desk, "Donald C. Cook Nuclear Plant Units 1 and 2, Proposed Changes to Emergency Action Levels," AEP-NRC-2011-16, dated February 8, 2011.

2. Letter from J. P. Gebbie, I&M, to NRC Document Control Desk, "Donald C. Cook Nuclear Plant Units 1 and 2, Proposed Changes to Emergency Action Levels, Response to Request for Additional Information," AEP-NRC-2011-61, dated November 8, 2011.

3. Letter from E. J. Leeds, NRC, to L. J. Weber, I&M, "Donald C. Cook Nuclear Plant (CNP),

Units 1 and 2 - Approval of Emergency Action Level Scheme Change (TAC Nos. ME5666 and ME5667)," dated February 10, 2012.

4. Letter from J. P. Gebbie, I&M, to NRC Document Control Desk, "Donald C. Cook Nuclear Plant Units 1 and 2, Emergency Action Level Scheme Implementation Change,"

AEP-NRC-2011-97, dated October 26, 2012.

By Reference 1, as modified by Reference 2, I&M, the licensee for CNP Units 1 and 2, submitted proposed changes to Emergency Actions Levels (EAL) to the NRC for review and approval. By Reference 3, the NRC approved the EAL scheme and specified an implementation period. By Reference 4, I&M notified the NRC that the EAL Scheme approved by Reference 3 did not satisfy the requirements of 10 CFR Part 50 Appendix E and that I&M planned to submit a License Amendment Request (LAR) proposing changes to the EAL scheme, previously approved by Reference 3, that satisfies the requirements set forth in 10 CFR 50, Appendix E.

U. S. Nuclear Regulatory Commission AEP-NRC-2012-99 Page 2 Pursuant to 10 CFR 50.90, I&M, is submitting an LAR that supplements a previous request to change the EAL Scheme approved by Reference 3 for CNP, Units 1 and 2. The proposed change would modify the EAL set for Recognition Category "Systems Malfunctions - Cold" to be consistent with the capabilities of installed plant specific instrumentation, and consistent with the guidance provided in NEI 99-01, Revision 5, Methodology for Development of Emergency Action Levels. provides an affirmation. Enclosure 2 provides an evaluation of the proposed change. provides the current EAL Technical Basis Manual applicable pages marked up to show the proposed changes. Enclosure 4 provides a clean copy of the EAL Technical Basis Manual applicable pages reflecting the requested changes.

NRC review and approval is requested prior to June 30, 2013, with the amendment being implemented within 180 days of NRC approval.

There are no new regulatory commitments made in this letter.

In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Michigan state officials. Should you have any questions concerning this letter, or require additional information, please contact Mr. Michael K. Scarpello at (269) 466-2649.

Sincerely, Joel P. Gebbie Site Vice President JMT/kmh

Enclosures:

1. Affirmation

2. Evaluation of the Proposed Change

3. Proposed EAL Technical Basis Manual Pages (mark-up)

4. Proposed EAL Technical Basis Manual Pages (clean) c: C. A. Casto, NRC Region III J. T. King, MPSC S. M. Krawec, AEP Ft. Wayne, w/o enclosures MDEQ-RMD/RPS NRC Resident Inspector T. J. Wengert, NRC Washington DC

Enclosure 1 to AEP-NRC-2012-99 AFFIRMATION I, Joel P. Gebbie, being duly sworn, state that I am Site Vice President of Indiana Michigan Power Company (I&M), that I am authorized to sign and file this request with the Nuclear Regulatory Commission on behalf of I&M, and that the statements made and the matters set forth herein pertaining to I&M are true and correct to the best of my knowledge, information, and belief.

Indiana Michigan Power Company Joel P. Gebbie Site Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OFF.A* * .- , 2012

-Not*;ublic (

,My Commission Expires * *- -

DANIELLE BURG Notary Public, State 0 N MV Cmm~UflYof Of Michigan Acting th, Ision res 04-0 42- 01 ,

Enclosure 2 to AEP-NRC-2012-99 Evaluation of Proposed EAL Change to AEP-NRC-2012-99 Page 1 1.0

SUMMARY

DESCRIPTION This evaluation supports a license amendment request (LAR) that supplements a previous request to change the Emergency Actions Level (EAL) Scheme for Donald C. Cook Nuclear Plant (CNP) Units 1 and 2. The previous request (Reference 1 as modified by Reference 2) was submitted and subsequently approved (Reference 3) prior to the 10 CFR 50, Appendix E rule change on February 28, 2012. 10 CFR 50, Appendix E currently requires EAL scheme changes to be submitted as an LAR.

The proposed change would revise EALs CG7, CS7, and CA7, of the EAL Scheme, requested in Reference 1, as modified by Reference 2, to reflect the actual plant instrumentation available to determine whether conditions meet the EAL. The EALs for CG7, CS7, and CA7, contain, respectively, entry conditions for a General Emergency, a Site Area Emergency, and an Alert, based upon Reactor Coolant System (RCS) level indication that cannot be indicated by installed plant instrumentation. 10 CFR 50, Appendix E, Section B, Paragraph 1, states: "The emergency action levels shall be based on in-plant conditions and instrumentation..." The above EALs do not satisfy this regulatory requirement. Therefore this supplemental LAR is required to revise the EAL Scheme change that was requested in Reference 1, as modified by Reference 2.

By Reference 4, I&M previously notified the NRC of this discrepancy. The proposed change to correct this discrepancy is consistent with the guidance provided in NEI 99-01 (Reference 5) and satisfies regulatory requirements. Indiana Michigan Power (I&M), licensee for CNP Units 1 and 2, requests that the NRC approve the proposed supplemental amendment to the CNP EAL Scheme.

2.0 DETAILED DESCRIPTION The EALs for CA7, CS7, and CG7, as previously submitted by Reference 1 and modified by Reference 2, rely on a plant instrument that is not capable of indication of the RCS level values specified in the EALs.

The EAL scheme that was requested for approval by Reference 1, and modified by Reference 2, is based on NEI 99-01 (Reference 5). The proposed changes to CA7, CS7, and CG7 are detailed below and are consistent with the guidance provided in NEI 99-01 (Reference 5) for plants that do not have reactor vessel level indication which would allow the EAL value to be determined. The order in which the changes are described below is CS7 first, CA7 second, and CG7 third. CS7 is presented first, as it represents the most substantive change and provides the most detail in the technical evaluation of the requested change.

The CNP Mid-Loop Monitoring system intended to be utilized for the Initiating Conditions (IC) for CA7, CS7, and CG7 is the High Resolution RCS Full Range Level Indication, NLI-1000.

This instrument was previously understood to provide a range which would provide actual Reactor Pressure Vessel (RPV) levels and support the EAL values which were requested by Reference 1 as modified by Reference 2. The following provides a discussion of the actual measurement range capabilities of NLI-1000.

NLI-1000 has an Upper Transducer Assembly and a Lower Transducer Assembly. The Lower Transducer Assembly is connected to the bottom of a RCS cross under leg, and the Upper to AEP-NRC-2012-99 Page 2 Transducer Assembly is connected to a vent above the top of the pressurizer. NLI-1000 instrument range is from the top of the pressurizer at elevation 674 feet down to the 612 foot elevation. Note that the bottom of the RPV Cold Leg Nozzle is at elevation 612.9 feet. As such, indication on NLI-1000 that is below 612.9 feet is not indicative of water level in the RPV; it indicates level only in the cross under leg. CNP's Mid-Loop monitoring instrumentation is connected directly to the cross under piping and not directly connected to the RPV. Therefore, the midloop monitoring instrumentation, although capable of reading down to 612, can only read actual RPV level down to 612.9 which is the lowest point of the cold leg inlet. See Figure 1 of this enclosure for the NLI-1 000 arrangement within the RCS.

The EALs for Cold Shutdown System Malfunction (CA7, CS7, and CG7) in the CNP EAL Technical Basis Manual (requested by Reference 1, as modified by Reference 2 and approved by Reference 3) have been marked up with proposed changes and are included as Enclosure 3 to this letter.

CS7 Loss of RCS inventory affectinq core decay heat removal capability EAL 1 and 2 for CS7 relies on NLI-1000 to measure the EAL values. Since NLI-1000 can not indicate RPV level less than 612.9 feet, CS7 must be changed to meet the regulatory requirements of 10 CFR 50, Appendix E, and to be consistent with NEI 99-01 guidance (Reference 5).

The change being requested for CS7 is to remove the first two EALs in their entirety and to renumber the third EAL as Number 1. This requested change includes a change to the CS7 bases pages to reflect the deletion of EAL Numbers 1 and 2. This proposed change eliminates the use of NLI-1000 indication. As discussed above, NLI-1000 can not measure RPV level for the purposes of determining the values for EALs 1 and 2.

The proposed change is detailed in the marked up EAL Technical Basis Manual pages in to this letter. Enclosure 4 to this letter provides a clean copy of the proposed EAL Technical Basis Manual pages with the change incorporated.

CA7 Loss of RCS Inventory EAL 1 for CA7 relies on NLI-1000 to measure an EAL value. Since NLI-1000 can not indicate RPV level less than 612.9 feet, CA7 is required to be changed to meet the regulatory requirements of 10 CFR 50, Appendix E and to be consistent with NEI 99-01 guidance (Reference 5).

The change being requested for CA7 is to change the level indication value in EAL 1, from

"< 612.8 feet" to "< 612.9 feet." This requested change includes a change to the CA7 bases pages to reflect the revised RPV values for EAL 1 and to appropriately reflect that the RCS Full Range Level Indication indicates Cold Leg level.

The proposed change is detailed in the marked up EAL Technical Basis Manual pages in to this letter. Enclosure 4 to this letter provides a clean copy of the proposed EAL Technical Basis Manual pages with the change incorporated.

to AEP-NRC-2012-99 Page 3 CG7 Loss of RCS inventory affecting fuel clad integrity with containment challenged EAL 1 for CG7 relies on NLI-1000 to measure the EAL value. Since NLI-1000 can not indicate RPV level less than 612.9 feet, CG7 is required to be changed to meet the regulatory requirements of 10 CFR 50, Appendix E and to be consistent with NEI 99-01 guidance (Reference 5).

The change being requested for CG7 is to change the level indication value in EAL 1, from "<

612 feet" to "< 612.9 feet" and remove the words "(top of active fuel)." This requested change does not affect the CG7 bases pages; however, they are included for completeness.

The proposed change is detailed in the marked up EAL Technical Basis Manual pages in to this letter. Enclosure 4 to this letter provides a clean copy of the proposed EAL Technical Basis Manual pages with the change incorporated.

3.0 TECHNICAL EVALUATION

CS7 Loss of RCS inventory affecting core decay heat removal capability As written, the IC for CS7 (Loss of RCS inventory affecting core decay heat removal capability) closely follows the guidance of NEI 99-01, Revision 5, (Reference 5) in including 3 EALs.

EALs 1 and 2 evaluate based on Containment Closure status along with certain RPV water levels below the bottom inside diameter (ID) of the RPV loop. When a water level instrument is not available to determine the water level below the bottom ID of the RPV loop for 30 minutes, EAL 3 evaluates based on other indications of RPV inventory loss.

As written, EALs 1 and 2, for the IC for CS7, presume that instrumentation can monitor RPV level below the bottom of the RPV cold leg penetration. These two EALs are met and would require action when, along with considering containment closure status, RPV level is at certain points below the RPV loop penetration. NEI guidance (Reference 5) for the EAL developer for considering level in this IC provides the following:

6" below the bottom ID of the RCS Loop should be the level equal to 6" below the bottom of the RPV loop penetration (not the low point of the loop). Pressurized Water Reactors (PWRs) unable to measure this level should choose the first observable point below the bottom ID of the loop as the EAL value. If a water level instrument is not available such that the PWR EAL value cannot be determined, then EAL 3 should be used to determine if the IC has been met.

While NLI-1000 instrument range capability extends below the bottom of the RPV Cold Leg Nozzle (elevation 612.9 feet), instrument indication below 612.9 feet is not indicative of water level in the RPV as communication between the cross under leg and the RPV is lost below the bottom of the RPV Cold Leg nozzle (See Figure 1 of this enclosure for the NLI-1000 arrangement within the RCS). NLI-1000 indicates level only in the cross under leg below 612.9 feet, not the level in the RPV.

to AEP-NRC-2012-99 Page 4 Because the CNP RCS Full Range Level Indication (NLI-1000) instrumentation is not capable of reading below the RPV cold leg penetration, it is not possible to utilize NEI 99-01, Revision 5, (Reference 5), EALs 1 and 2 for CS7. Enclosure 3 of this letter provides a marked up copy of the affected EAL Technical Basis Manual pages, which reflect this change.

CA7 Loss of RCS Inventory As written, EAL 1 for the CA7 IC (Loss of RCS Inventory) presumes that instrumentation has the ability to monitor RPV level to the bottom of the RPV cold leg loop penetration. This EAL is met and would require action when RPV level is at the bottom of the RPV loop. NEI guidance (Reference 5) for the EAL developer for considering level in this IC provides the following:

The PWR bottom ID of the RCS Loop Setpoint was chosen because at this level the remote RCS level indication may be lost and loss of suction to decay heat removal systems has occurred. The bottom ID of the RCS Loop Setpoint should be the level equal to the bottom of the RPV loop penetration (not the low point of the loop).

The bottom ID of the RCS loop (Cold Leg) is 612.9 feet. Therefore, EAL 1 RCS full range level indication will be changed to be less than or equal to 612.9 feet. Enclosure 3 of this letter provides a marked up copy of the affected EAL Technical Basis Manual pages, which reflect this change.

CG7 Loss of RCS inventory affecting fuel clad integrity with containment challenged As written, EAL 1 for the CG7 IC presumes that instrumentation can monitor RPV level to the Top of Active Fuel (TOAF). This EAL is met and would require action when RPV level is at the TOAF.

NLI-1000 can measure down only to a level of 612.9 feet. Because NLI-1000 cannot measure down to the TOAF, the bottom of the RCS cold leg loop (612.9 feet) was chosen conservatively in order to begin monitoring for concurrent conditions which would meet the EAL 1 threshold.

The concurrent conditions are specified following the "AND" statement of CG7 EAL 1. of this letter provides a marked up copy of the affected EAL Technical Basis Manual pages, which reflect this change.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Reguirements/Criteria 10 CFR 50, Appendix E requires licensees to have an Emergency Plan and have emergency action levels as part of the content of the Emergency Plan. The CNP Emergency Plan is incorporated by reference into the Updated Final Safety Analysis Report and may be changed pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(q).

4.2 Precedent The NRC has previously approved similar EAL changes for other plants that have similar EALs in the EAL set for Recognition Category "Systems Malfunction-Cold," based on NEI 99-01, Revision 5 (Reference 5), in which RPV level indication was limited to the bottom of the Cold to AEP-NRC-2012-99 Page 5 Leg inlet. An example is the approval of EAL change for Hope Creek Generating Station and Salem Generating Station by NRC letter dated September 23, 2011, (ADAMS Accession No.

(ML112560428). This EAL change is similar to the CNP EAL scheme change requested for CS7, CA7, and CG7.

4.3 Sigqnificant Safety Hazards Consideration I&M is requesting an amendment to the CNP Facility Operating Licenses to revise the Emergency Plan EAL Scheme. This change includes a proposed change to EALs CS7, CA7, and CG7. Specifically, I&M proposes a change to the plant specific parameters and instrumentation used to assess and determine if conditions exist for a given emergency action level.

I&M 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 discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change to Emergency Actions Levels (EALs) CS7, CA7, and CG7 is to reference available plant indication to assess conditions for determination of entry into an emergency action level. The EALs for CG7, CS7, and CA7, contain, respectively, entry conditions for a General Emergency, a Site Area Emergency, and an Alert, based upon Reactor Coolant System (RCS) level indication that cannot be indicated by installed plant instrumentation. This change does not alter accident analysis assumptions, add any initiators, or affect the function of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected. There are no plant modifications associated with the proposed change. Therefore, there will be no effect on the performance capability of the structures, systems, and components relied upon to mitigate the consequences of postulated accidents and no impact on the probability or consequences of an accident previously evaluated due to plant modifications.

Therefore, the proposed change does not involve a sign~ificant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change to EALs for CS7, CA7, and CG7 is to reference available plant indication to assess conditions for determination of entry into an emergency action level.

This proposed change does not alter accident analysis assumptions, add any initiators, or affect the function of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected. There are no plant modifications associated to AEP-NRC-2012-99 Page 6 with the proposed change. Therefore, there will be no effect on the performance capability of the structures, systems, and components relied upon to mitigate the consequences of postulated accidents due to plant modifications. Also, the possibility of a new or different kind of accident from any accident previously evaluated will not be created because there are no plant modifications.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

Plant safety margins are established through limiting conditions for operation, limiting safety system settings, and safety limits specified in the technical specifications. The proposed change to EALs for CS7, CA7, and CG7 is to reference available plant indication to assess conditions for determination of entry into an emergency action level.

Because there is no change to these established safety margins as result of this change, the proposed change does not involve a significant reduction in a margin of safety.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, I&M concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusion 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.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment provides a change to the EALs approved by Reference 3. A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets 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 amendment.

to AEP-NRC-2012-99 Page 7

6.0 REFERENCES

1. Letter from J. P. Gebbie, Indiana Michigan Power Company (I&M), to U. S. Nuclear Regulatory Commission (NRC) Document Control Desk, "Donald C. Cook Nuclear Plant Units 1 and 2, Proposed Changes to Emergency Action Levels," AEP-NRC-2011-16, dated February 8, 2011.

2. Letter from J. P. Gebbie, I&M, to NRC Document Control Desk, "Donald C. Cook Nuclear Plant Units 1 and 2, Proposed Changes to Emergency Action Levels, Response to Request for Additional Information," AEP-NRC-2011-61, dated November 8, 2011.

3. Letter from E. J. Leeds, NRC, to L. J. Weber, I&M, "Donald C. Cook Nuclear Plant (CNP), Units 1 and 2 - Approval of Emergency Action Level Scheme Change (TAC Nos.

ME5666 and ME5667)," dated February 10, 2012.

4. Letter from J. P. Gebbie, I&M, to NRC Document Control Desk, "Donald C. Cook Nuclear Plant Units 1 and 2, Emergency Action Level Scheme Implementation Change,"

AEP-NRC-2011-97, dated October 26, 2012.

5. NEI 99-01, Methodology for Development of Emergency Action Levels, Revision 5, dated February 2008.

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Enclosure 3 to AEP-NRC-2012-99 Proposed CNP EAL Technical Basis Manual Changes (mark-up)

Pages 24, 145-152

D.C. Cook EAL Manual AEP RECOGNITION CATEGORY RADIOLOGICAL EFFLUENTS / ABNORMAL RADIATION LEVELS CG7 Initiating Condition: GENERAL EMERGENCY Loss of RCS inventory affecting fuel clad integrity with containment challenged.

Operating Mode Applicability:

5,6 EALs:

Note: The Eniergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

1. a. RCS level 61-2 :5 612.9 feet for 30 minutes or longer.

AND

b. ANY Table C-1 containment challenge indications.

OR

2. a. RCS level cannot be monitored for 30 minutes or longer.

AND

b. Core uncovery as indicated by ANY of the following:

Containment radiation monitor VRA 1310 (2310) > 32 R/hr

" Erratic source range monitor indication.

" UNPLANNED level rise in Containment sumps, Aux Building sumps, RWST or RCDT.

AND

c. ANY Table C-1 containment challenge indications.

Table C-1: Containment Challenge Indications

CONTAINMENT CLOSURE not established.

Hydrogen concentration > 4% inside containment.

UNPLANNED rise in containment pressure.

Page 145 Rev. 0

D.C. Cook EAL Manual AEP RECOGNITION CATEGORY RADIOLOGICAL EFFLUENTS / ABNORMAL RADIATION LEVELS CG7 (continued)

Basis:

Generic This IC represents the inability to restore and maintain RPV level to above the top of active fuel with containment challenged. Fuel damage is probable if RPV level cannot be restored, as available decay heat will cause boiling, further reducing the RPV level. With the containment breached or challenged then the potential for unmonitored fission product release to the environment is high. This represents a direct path for radioactive inventory to be released to the environment. This is consistent with the definition of a General Emergency. The General Emergency is declared on the occurrence of the loss or imminent loss of function of all three barriers.

These EALs are based on concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal, SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues, NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States, and, NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

A number of variables can have a significant impact on heat removal capability challenging the fuel clad barrier. Examples include; mid-loop, reduced level/flange level, head in place, cavity flooded, RCS venting strategy, decay heat removal system design, and vortexing pre-disposition.

Analysis indicates that core damage may occur within an hour following continued core uncovery therefore, 30 minutes was conservatively chosen.

If containment closure is re-established prior to exceeding the 30 minute core uncovery time limit then escalation to General Emergency would not occur.

Site shutdown contingency plans typically provide for re-establishing containment closure following a loss of heat removal or RCS inventory functions.

In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive mixture of dissolved gasses in containment. However, containment monitoring and/or sampling should be performed to verify this assumption and a General Emergency declared if it is determined that an explosive mixture exists.

EAL #2 Sump and tank level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage.

Page 146 Rev. 0

D.C. Cook EAL Manual AEP RECOGNITION CATEGORY RADIOLOGICAL EFFLUENTS / ABNORMAL RADIATION LEVELS CG7 (continued)

In the cold shutdown mode, normal RCS level and RPV level instrumentation systems will usually be available. In the refueling mode, normal means of RPV level indication may not be available. Redundant means of RPV level indication will usually be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted.

However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that RPV inventory loss was occurring by observing sump and tank level changes. Sump and tank level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage.

As water level in the RPV lowers, the dose rate above the core will increase. The dose rate due to this core shine should result in site specific monitor indication and possible alarm.

This EAL should conservatively estimate a site specific dose rate setpoint indicative of core uncovery (i.e., level at TOAF).

Post-TMI studies indicated that the installed nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations.

Site Specific Defined (Top of Active Fuel) as lowest reading on NLI-1000, High-Resolution - RCS Full Range Level Indication.

Cook Nuclear Plant elevations are expressed in Feet and Inches, RCS Level Indication reads out in Feet and Tenths of a Foot.

EAL #2.b bullet #1 The containment radiation monitor reading is based on calculation EP-EALCALC-0803.

EAL #2.b bullet #2 Erratic Source Range Monitors indication can be identified using:

Source Range startup rate channels for NI-31 or NI-32

Intermediate Range channels NI-35 or NI-36

Neutron flux wide range NI-21 or NI-23 Basis Reference(s):

1. NEI 99-01 Rev 5, CG1

2. EP-EALCALC-0803, Radiation Monitor Readings for Core Uncovery During Refueling (EALs CG7 and CS7).

Page 147 Rev. 0

D.C. Cook EAL Manual AEP RECOGNITION CATEGORY RADIOLOGICAL EFFLUENTS / ABNORMAL RADIATION LEVELS CS7 Initiating Condition: SITE AREA EMERGENCY Loss of RCS inventory affecting core decay heat removal capability.

Operating Mode Applicability:

5,6 EALs:

Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

I n CONITAINIRAPNIT C1 05ZI IRP nnt AND

b. Loss of RCS inventory' as indicated by RCS Full Range Level Indication (NLI 1000) 4 612.3 feet.

OR CONTlAIlNMENT CLOSURE established.

AND b.. RCS level 4 612 feet-.

0

&EII a. RCS level cannot be monitored for 30 minutes or longer.

AND

b. Loss of RCS inventory as indicated by ANY of the following:

Containment radiation monitor VRA 1310 (2310) > 32 R/hr

Erratic source range monitor indication.

UNPLANNED level rise in Containment sumps, Aux Building sumps, RWST or RCDT.

Page 148 Rev. 0

D.C. Cook EAL Manual AEP RECOGNITION CATEGORY RADIOLOGICAL EFFLUENTS / ABNORMAL RADIATION LEVELS CS7 (continued)

Basis:

Generic Under the conditions specified by this IC, continued decrease in RCS/RPV level is indicative of a loss of inventory control. Inventory loss may be due to an RCS breach, pressure boundary leakage, or continued boiling in the RPV. Thus, declaration of a Site Area Emergency is warranted.

EAL #1 6" below the bottom QD of the RCS Loop should be the level equal to 6" below the bottom oe the RPV loop penetration (not the loW point of the loop).

EAL-#3 In the cold shutdown mode, normal RCS level and RPV level instrumentation systems will usually be available. In the refueling mode, normal means of RPV level indication may not be available. Redundant means of RPV level indication will usually be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be interrupted.

However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that RPV inventory loss was occurring by observing sump and tank level changes. Sump and tank level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage.

The 30-minute duration allows sufficient time for actions to be performed to recover inventory control equipment.

As water level in the RPV lowers, the dose rate above the core will increase. The dose rate due to this core shine should result in site specific monitor indication and possible alarm.

This EAL should conservatively estimate a site specific dose rate setpoint indicative of core uncovery (i.e., level at TOAF).

Post-TMI studies indicated that the installed nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations.

Site Specific EALfr2 Page 149 Rev. 0

D.C. Cook EAL Manual AEP RECOGNITION CATEGORY RADIOLOGICAL EFFLUENTS / ABNORMAL RADIATION LEVELS CS7 (continued)

This EAL applies to conditions in which the loss of decay heat removal capability has caused a significant drop in RCS water level below the bottom of the RCS cold leg penetration and core uncovery may be challenged. RCS level indication capability does not support detection of RCS levels that low and, consequently, alternate means of assessing RCS inventory loss must be used.

EAL #3.b bu'Wt#! EAL #1.b bullet #1 1 The containment radiation monitor reading is based on calculation EP-EALCALC-0803.

EAL #3.b bullet #2 EAL #1.b bullet #2 1 Erratic Source Range Monitors indication can be identified using:

" Source Range startup rate channels for NI-31 or NI-32

" Intermediate Range channels NI-35 or NI-36

Neutron flux wide range NI-21 or NI-23 Basis Reference(s):

1. NEI 99-01 Rev 5, CS1

2. EP-EALCALC-0803, Radiation Monitor Readings for Core Uncovery During Refueling (EALs CG7 and CS7)

Page 150 Rev. 0

D.C. Cook EAL Manual AEP RECOGNITION CATEGORY RADIOLOGICAL EFFLUENTS / ABNORMAL RADIATION LEVELS CA7 Initiating Condition: ALERT Loss of RCS inventory.

Operating Mode Applicability:

5,6 EALs:

Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

1. Loss of RCS inventory as indicated by RCS Full Range Level Indication (NLI-1000) 64,2.8 feet.

OR

2. a. RCS level cannot be monitored for 15 minutes or longer.

AND

b. Loss of RCS inventory as indicated by UNPLANNED level rise in Containment sumps, Aux Building sumps, RWST or RCDT.

Basis:

Generic These EALs serve as precursors to a loss of ability to adequately cool the fuel. The magnitude of this loss of water indicates that makeup systems have not been effective and may not be capable of preventing further RPV level decrease and potential core uncovery. This condition will result in a minimum emergency classification level of an Alert.

EAL #1 The PWR Bottom ID of the RCS loop setpoint was chosen because at this level remote RCS level indication may be lost and loss of suction to decay heat removal systems has occurred.

The bottom ID of the RCS loop setpoint should be the level equal to the bottom of the RPV loop penetration (not the low point of the loop).

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D.C. Cook EAL Manual AEP RECOGNITION CATEGORY RADIOLOGICAL EFFLUENTS / ABNORMAL RADIATION LEVELS CA7 (continued)

The inability to restore and maintain level after reaching this setpoint would be indicative of a failure of the RCS barrier.

EAL #2 In the cold shutdown mode, normal RCS level and RPV level instrumentation systems will usually be available. In the refueling mode, normal means of RPV level indication may not be available. Redundant means of RPV level indication will usually be installed (including the ability to monitor level visually) to assure that the ability to monitor level will not be ;Interrupted.

However, if all level indication were to be lost during a loss of RCS inventory event, the operators would need to determine that RPV inventory loss was occurring by observing sump and tank level changes. Sump and tank level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of RCS leakage.

The 15-minute duration for the loss of level indication was chosen because it is half of the CS7 duration. Significant fuel damage is not expected to occur until the core has been uncovered for greater than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per the analysis referenced in the CG7 basis. Therefore this EAL meets the definition for an Alert.

Site Specific EAL #1 RCS level cannot be measured below 642 L612. feet on NLI-1000, High Resolution - RCS Full Range Level Indication, which is below the bottom ID of the hot ~l L leg inlet. Should RCS level drop below this point it is assumed water level cannot be monitored other than visually.

Basis Reference(s):

1. NEI 99-01 Rev 5, CA1 Page 152 Rev. 0

Enclosure 4 to AEP-NRC-2012-99 Proposed CNP EAL Technical Basis Manual Changes (clean)

Pages 24, 145-152

D.C. Cook EAL Manual AEP RECOGNITION CATEGORY RADIOLOGICAL EFFLUENTS / ABNORMAL RADIATION LEVELS Initiating Condition: GENERAL EMERGENCY CG7 Loss of RCS inventory affecting fuel clad integrity with containment challenged.

Operating Mode Applicability:

5,6 EALs:

Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

1. a. RCS level < 612.9 feet for 30 minutes or longer.

AND

b. ANY Table C-1 containment challenge indications.

OR

2. a. RCS level cannot be monitored for 30 minutes or longer.

AND

b. Core uncovery as indicated by ANY of the following:

Containment radiation monitor VRA 1310 (2310) > 32 R/hr

Erratic source range monitor indication.

" UNPLANNED level rise in Containment sumps, Aux Building sumps, RWST or RCDT.

AND

c. ANY Table C-1 containment challenge indications.

Table C-1: Containment Challenge Indications

" CONTAINMENT CLOSURE not established.

Hydrogen concentration > 4% inside containment.

UNPLANNED rise in containment pressure.

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D.C. Cook EAL Manual AEP RECOGNITION CATEGORY RADIOLOGICAL EFFLUENTS / ABNORMAL RADIATION LEVELS CG7 (continued)

Basis:

Generic This IC represents the inability to restore and maintain RPV level to above the top of active fuel with containment challenged. Fuel damage is probable if RPV level cannot be restored, as available decay heat will cause boiling, further reducing the RPV level. With the containment breached or challenged then the potential for unmonitored fission product release to the environment is high. This represents a direct path for radioactive Inventory to be released to the environment. This is consistent with the definition of a General Emergency. The General Emergency is declared on the occurrence of the loss or imminent loss of function of all three barriers.