ML042430210
| ML042430210 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, River Bend, Waterford  |
| Issue date: | 06/01/2004 |
| From: | Alexion T NRC/NRR/DLPM/LPD4 |
| To: | Entergy Nuclear |
| Alexion T W, NRR/DLPM, 415-1326 | |
| Shared Package | |
| ML042450085 | List: |
| References | |
| Download: ML042430210 (120) | |
Text
-homas Alexion - Fwd: Updated Entergy NEI 99-01 EALs Page 1 From:
Thomas Alexion To:
LENGLAN~entergy.com Date:
6/1/04 11:18AM
Subject:
Fwd: Updated Entergy NEI 99-01 EALs
- Les, Joe reformatted the information to facilitate the call tomorrow.
See the attached to the attached.
Tom
'A:\\WINDOWS\\TEMP\\GWO00001.TMP Page 1 Mail Envelope Properties (40BC9E45.58F: 0: 20628)
Subject:
Creation Date:
From:
Created By:
Fwd: Updated Entergy NEI 99-01 EALs 6/1/04 11:18AM Thomas Alexion TWA@nrc.gov Recipients entergy.com LENGLAN (LENGLAN@entergy.com)
Action Transferred Date & Time 06/01/04 11:18AM Post Office Delivered Route entergy.com Files Mail MESSAGE Options Auto Delete:
Expiration Date:
Notify Recipients:
Priority:
Reply Requested:
Return Notification:
Concealed
Subject:
Security:
To Be Delivered:
Status Tracking:
Size 841 No None Yes Standard No None No Standard Immediate Delivered & Openec Date & Time 06/01/04 11:18AM
rhornas Alexion - Updated Entergy NEI 99-01 EALs Page 1 From:
Joseph Anderson To:
Thomas Alexion Date:
6/1/04 10:54AM
Subject:
Updated Entergy NEI 99-01 EALs Joseph D. Anderson Emergency Preparedness Specialist U.S. NRC (NRR / EPPO)
(301) 415-4114 jdal @nrc.gov
GENERAL COMMENT
S 1 of 5 GEEA COMNS1o ANO GRAND GULF RIVER BEND WATERFORD 3
-4 1
I
I (FSAR Table 4-2) There appear to be changes to the DBA listing of accidents and associated classifications under the proposed EAL scheme. Provide a description of the review of these accidents to ensure that the classifications are correct as listed.
-i I
I I
10 CFR 50, Appendix E -- Section IV.B (Assessment Actions) states,
"...emergency action levels shall be discussed and agreed on by the applicant [licensee] and State and local governmental authorities, and approved by NRC." Please provide documentation indicating that these discussion have occurred and that there is agreement with State and local governmental authorities on the implementation of the proposed EAL changes based on NEI 99-01, Revision 4.
10 CFR 50, Appendix E -- Section IV.B (Assessment Actions) states,
"...emergency action levels shall be discussed and agreed on by the applicant [licensee] and State and local governmental authorities, and approved by NRC." In its submittal cover letter, the licensee states that "[t]hese changes have been reviewed and approved by...the State of Louisiana and local governmental authorities.'
Please provide documentation indicating that these discussion have occurred and that there Is agreement with State and local governmental authorities on the implementation of the proposed EAL changes based on NEI 99-01, Revision 4. (W3 will provide PvIdp-nrvp nf rpvlpw X
GENERAL COMMENT
S 2 of 5
GENERAL COMMENT
S 2 of 5 ANO GRAND GULF RIVER BEND WATERFORD 3 I ____________________________________
1 4
Referenced changes to the Grand Gulf FSAR, included in the proposed change package, do not include an evaluation and justification for the appropriateness for the proposed changes. As specific examples, old sections of the FSAR are deleted for a replaced section with NEI 99001 methodology, but no documentation for the review and justification for the change is included.
Similarly, Table 402 of the FSAR contains minor changes, but documentation of the review of the design bases accidents and corresponding classification levels is not included. (Why Is 50.54q required?)
In review of other Entergy submittals, an expected level of consistency (format, policy, exposure limits, etc.) does not appear evident. While exact consistency between sites is not a specific requirement for submittal, it was the intent of NEI, and the NRC endorsement of 99-01, that a standard methodology in emergency classification would result. In consideration for making changes as a result of these questions / comments, a common Entergy approach In response may expedite review by the NRC staff.
(Can this question be removed from list? Appears to be subjective?)
-4 4
4 t
Specific definitions for differences and deviations do not appear to be consistently applied. Numerous examples, identified below, indicate that areas labeled differences" appear to be Udeviations". It is intended that NEI 99-01 is consistently used by licensees with a high degree of similarity in order to provide an industry-wide similarity in classifications of emergencies.
Additionally, the endorsement by NRC In RG 1.101 of NEI 99-01 and the application of the methodology by the industry was intended (by NRC) to be at a high level of similarity. Differences for site-specific applications were identified within NEI 99001. Any alteration of the initiating conditions, EALs, or basis was permitted, but expected to be identified as a deviation, with detailed evaluation of the alteration and justification to sufficiently support a "stand alone" determination for the change.
4
.5.
.5.
J
GENERAL COMMENT
S 3 of 5
GENERAL COMMENT
S 3 of 5 ANO GRAND GULF RIVER BEND WATERFORD 3
-I
- 4.
1-1
This was discussed with Entergy and other EAL change packages (for other Entergy plants) were included (but not Grand Gulf, the first Entergy submittal).
It is recommended that *differences*
and "deviations* be specifically defined within the change package (as was done for the ANO EAL submittal) and followed.
Referenced changes to the Grand Gulf Emergency Plan, included in the proposed change package, do not include an evaluation and justification for the appropriateness for the proposed changes. It is expected that all changes included in the package contain appropriate detailed evaluations and justifications for changes.
4 Provide copy of calculations used to Provide copy of calculations used to determine effluent monitor thresholds determine effluent monitor thresholds under AG1, AS1, AA1 and AU1, and under AGI, AS1, M1 and AU1, and specify any deviations from guidance in specify any deviations from guidance in Appendix A to NEI 99-01 (Basis for NEI 99-01 (Basis for Radiological Radiological Effluent Initiating Effluent Initiating Conditions) and Conditions). (ANO will provide Appendix A. In addition, provide ranges additional information.)
for effluent monitor Instrumentation referenced. (W3 will provide additional information.)
Provide a simplified drawing or Provide a simplified drawing or schematic illustrating unit auxiliary and schematic illustrating unit auxiliary and start-up transformers and describe Inter-start-up transformers and describe inter-relationship regarding conditions relationship regarding conditions 8 needed for a loss of off-site power and needed for a loss of off-site power and the ability of emergency diesel the ability of emergency diesel generators to supply on essential generators to supply on essential busses. (ANO will provide additional busses. (W3 will provide additional In formation.)
Information.)
GENERAL COMMENT
S 4of 5
GENERAL COMMENT
S 4 of 5 ANO GRAND GULF RIVER BEND
-I 4
- 4.
4.
Describe whether temporary RCS water level instrumentation is installed In Modes 5 and 6, and if installed, whether ANO-1 and ANO-2 instrumentation capabilities in Modes 5 and 6 would monitor water level at or below the bottom ID of the RCS loop and at the top of active fuel (TOAF) for either unit.
WATERFORD 3 Licensee Basis (under CU3) states that
"[t]emporary instrumentation and jumpers are maintained in service such that the operators are able to monitor RCS temperature and reactor vessel level...Redundant means of reactor vessel level indication are procedurally installed to assure that the ability to monitor level will not be interrupted."
Describe instrument range of RPV water level indication in Modes 5 and 6, specifically ability to monitor level at the top of active fuel and the bottom ID of the RCS loop. In addition, identify any periods during mode transition when indication would not be available. In addition, provide reference to specific procedural requirements for installing temporary instrumentation, and describe means in place to preclude modification of this procedural requirement without concurrent evaluation and revision of EALs.
Clarify "deviation" example provided in (ANO NEI EAL Deviations and Differences) to Identify any deletions to NEI 99-01 Initiating Condition (IC) statements or example emergency action levels (EALs) criterion, or significant changes (other than nomenclature, simple terminology or system names, etc.) that may impact intent or thresholds established or guidance provided In NEI 99-01. In addition, evaluate changes proposed to NEI 99-01 guidance in submittal, reclassify appropriately as a deviations or differences and provide specific technical justification for any deviations and differences, as appropriate.
(Specific examples listed under uC~nnp-fjf! ^rnmMe~nfe" Evaluate changes proposed to NEI 99-01 guidance in submittal to ensure that any deletions to NEI 99-01 Initiating Condition (IC) statements or example EALs criterion, or significant changes (other than nomenclature, simple terminology or system names, etc.) that may impact intent or thresholds established or guidance provided in NEI 99-01, are listed as deviations. In addition, provide specific technical justification for any deviations, as appropriate. (Specific examples listed under 'Specific Comments".) (W3 will clarify difference and deviations.)
I l
GENERAL COMMENT
S 5 of 5
GENERAL COMMENT
S 5 of 5 ANO GRAND GULF RIVER BEND WATERFORD 3
-I 4
- 4.
4.
Discuss application of differences in design between systems, setpoints, instrumentation, etc. on ANO-1 (Babcock & Wilcox) and ANO-2 (Combustion Engineering), as they appropriately apply to EALs. Has any effort been made to coordinate EALs revision for ANO-2 with Entergy's Waterford 3 for consistency in application within Entergy and among Combustion Engineering designs?
(What Is needed?)
Provide rational for the inconsistent use of unit nomenclature !ANO-1 / ANO-2" 12 versus "Unit 1 / Unit 2", or revise accordingly to ensure consistency in terminology. (ANO will correct
_ documentation.)
Section 6.2.1 (Downgrading the Emergency Classification) appears to allow for downgrading regardless of event class severity. Describe how the recommendation in NEI 99-01, Section 3.11 (Emergency Class Downgrading) 13 is being addressed, which states in part that "[a] combination approach involving recovery from General Emergencies and some Site Area Emergencies and termination from NOUEs, Alerts and certain Site Area Emergencies causing no long-term plant damage..."
CATEGORY A: ABNORMAL RADIOLOGICAL CONDITIONS 1 of 2 AU Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition Licensee under AUl Basis does not 99-01 EAL #1 applies to any effluent EAL Basis (Attachment 4) provides a address NEI 99-01, AUW Basis monitor. RBS applied #1 only to listing of applicable effluent radiation guidance, which states "... if an liquid releases (effluent monitors monitors. However, listing is not ongoing release Is detected and the addressed in #2). Application for provided in EAL matrix (Attachment starting time for that release is contamination in line causing monitor 3) for event classification purposes.
unknown, the Emergency Director to continue to read high Is Clarify justification for inconsistency should, in the absence of data to the acceptable. By applying to liquid between attachments, or provide contrary, assume the release has only, does this disturb the logic for listing of applicable effluent radiation exceeded 60 minutes." Statement is other EALs (see #2)? Explain why monitors in EAL matrix. (ACTION:
EAL 1 included under licensee AA1 Basis.
credit not applied for samples which W3 to establish list.)
Address deletion of Basis statement correct monitor readings (as in #2 as either a deviation or difference basis)?
under Attachment 3, and provide justification for deletion of Basis guidance and how EAL will be interpreted without guidance.
(ACTION: ANO will modify wording.)
Licensee inserted the statement Basis states that '[g]rab sample
"...during a discharge", which is not analysis of the circulation water addressed under NEI 99-01, AUM -
discharge, lAW EAL#3, would be Example EAL 2. However, statement necessary to determine the was not used in licensee M1, EAL 2.
appropriate action." Clarify, per NEI EAL 2 Address Insertion of statement as 99-01 guidance, that a grab sample either deviation or difference under is not required to declare an event, and provide per AUl / EAL 2, based on effluent justification for change and monitor threshold being exceeded for inconsistency with M1, EAL 2.
> 60 minutes.
(ACTION: ANO will resolve wording.)
CATEGORY A: ABNORMAL RADIOLOGICAL CONDITIONS 2 of 2 AU Arkansas Nuclear One Grand Gulf River Bend Waterford (EAL4) Licensee modified NEI 99-01, AUl - Example EAL 5, under AU1, EAL 4 to reflect URDAC data indicating NUE." Identify in EAL 4 the site-specific value, as required under NEI 99-01, AUl - Example EAL EAL 5, for event classification 5
consistent with initiating condition criteria of two times the radiological ODCM limits. In addition, clarify that actual meteorology Is used for RDAC calculations per guidance in NEI 99-01, AUl Basis for Example EAL 5.
CATEGORY A: ABNORMAL RADIOLOGICAL CONDITIONS 1 of 1 AU2 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition Licensee does not address the "fuel This EAL specifically applies to areas Address site-specific indication of transfer canal", which is identified around spent fuel. The value of uncontrolled water level decrease in under NEI 99-01, AU2 - Example (1000) is not intended to apply here EAL per NEI 99-01 guidance.
EAL 1. Identify deletion as either and could result in very high radiation (ACTION: W3 does not have fuel deviation or difference under areas. Explain this deviation. NEI 99 pool levi indication.)
EAL 1 and provide justification 01 IC does not apply X1 000 for change, or provide proposed throughout EALs for this IC.
changes to comply with NEI 99-01 (ACTION: RBS to align with fleet.)
guidance. (ACTION: ANO will clarify terminology.)
This EAL is acceptable except for the omission of "unplanned", but the IC is changed, and Is a deviation from 99-EAL 2
- 01. Explain the omission of this deviation, and why this Is not identified. Explain use of valid versus unplanned. (ACTION: RBS to clarify wording.)
CATEGORY A: ABNORMAL RADIOLOGICAL CONDITIONS 1 of 3 AA1 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition Deviation, appears acceptable (Is TRM & ODCM limit the same? If so, shouldn't this be 400X if 50% of TRM limit?) Compare to other Entergy EAL submittals.
Same issue as in AU1. #1 addresses liquid only, #2 effluent and not radiation Monitors.
EAL Basis (Attachment 4) provides a listing of applicable effluent radiation monitors. However, listing Is not provided in EAL matrix (Attachment
- 3) for event classification purposes.
Clarify Justification for inconsistency between attachments, or provide listing of applicable effluent radiation monitors in EAL matrix. (ACTION:
W3 to establish list.)
EAL 1 Basis states that [flor this IC
[initiating condition], it is expected that PIG monitors on the release pathway will be over-ranged."
Identify the specific monitors in question, and clarify whether designated monitor thresholds will be on-scale. If off-scale, provide further justification for use of designated monitor threshold vs. off-scale high.
(ACTION: W3 will Identify monitors and designated thresholds.)
Basis states, "...effluent radiation monitor readings that exceed 200 times the Technical Specification limit..." This is inconsistent with licensee EAL criterion and NEI 99-01 guidance, which specifies "...effluent radiation monitor readings that exceed 200 times the alarm setpoint established by the radioactivity discharge permit." Provide justification for inconsistency, or provide the proposed change to comply with NEI 99-01 guidance.
(ACTION: W3 will resolve Inconnistenrv. I I__
_ +/-_
_I
CATEGORY A: ABNORMAL RADIOLOGICAL CONDITIONS 2of 3 AA1 Arkansas Nuclear One Grand Gulf River Bend Waterford 99-01 EAL #2 applies to radiation Basis states that '[g]rab sample monitors, effluent monitors were analysis of the circulation water addressed in #1. Why did you discharge, IAW EAL#3, would be separate liquid from effluent (#1 and necessary to determine the
- 2) monitors? Are there conditions appropriate action." Clarify, per NEI where gaseous effluent Monitors can 99-01 guidance, that a grab sample continue to read following term of is not required to declare an event releases as in #1 ? Explain why rad per AU1 / EAL 2, based on effluent EAL 2 monitors are not included in EALs monitor threshold being exceeded for and why this deviation was not
> 15 minutes.
identified.
Same Issue as in AU1. #1 addresses Correct inconsistency in instrument liquid only, #2 effluent and not number between EAL matrix and radiation Monitors.
Basis for the Fuel Handling Building Exhaust ERGM (e.g., PRM-1RE-3032). (ACTION: W3 to correct Instrument numbering.)
Explain why wording differs from 99-Provide listing of applicable, site-
- 01. (ACTION: RBS will revise specific technical specification wording.)
references for gaseous and liquid releases per NEI 99-01 guidance.
EAL 3 (ACTION: W3 will provide list.)
Explain difference between use of confirmed versus unplanned. Explain difference in wording, in general.
(ACTION: RBS to modify wording.)
Basis lists the deletion of EAL 4 as a difference. While deletion is technically justified, provide further clarification why change does not EAL 4 constitute a deviation, based on the elimination of specific NEI 99-01 example EAL criteria, or provide change listing deletion as a deviation.
CATEGORY A: ABNORMAL RADIOLOGICAL CONDITIONS 3 of 3 AA1 Arkansas Nuclear One Grand Gulf River Bend Waterford (EAL4) Licensee modified NEI 99-01, Basis lists the deletion of EAL 5 as a AA1 - Example EAL 5, under AA1, difference. While deletion Is EAL 4 to reflect "RDAC data technically justified, provide further indicating Alert." Identify in EAL 4 the clarification why change does not site-specific value, as required under constitute a deviation, based on the NEI 99-01, AA1 - Example EAL 5, for elimination of specific NEI 99-01 EAL 5 event classification consistent with example EAL criteria, or provide initiating condition criteria of two change listing deletion as a deviation.
times the radiological ODCM limits.
In addition, clarify that actual meteorology is used for RDAC calculations per guidance in NEI 99-01, AA1 Basis for Example EAL 5.
CATEGORY A: ABNORMAL RADIOLOGICAL CONDITIONS 1 of 2 AA2 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (IC) statement (BASIS) Licensee inserted the under Index of EALs, contained in qualifier: "...for this IC to apply the to EAL classification event must have radiological procedure, does not contain consequences - high radiation statement "outside the reactor monitor alarm for this classification to vessel", as reflected in NEI 99-01, apply." This statement is applicable AA2 and Attachments 2 and 3 of the to EAL 1 only, and not EAL 2 per NEI Initiating proposed EAL classification guidance, which is declared based on Condition procedure. Provide change to reflect the actual or likely uncovery of NEI 99-01, AA2 guidance or justify irradiated fuel outside the reactor difference from guidance and AA2 IC vessel. Provide further justification statement in remainder of procedure.
for Basis qualification statement, or (ACTION: ANO to provide provide changes to comply with NEI clarification.)
99-01, AA2 / EAL 2 guidance.
(ACTION: W3 will modify to match NEI 99-01.)
Provide a correlation between site-specific radiation monitors designated licensee EAL 1 and those listed in NEI 99-01, AA2 / EAL 1. In EAL 1 addition, specifically address the lack of Refuel Bridge Area Radiation Monitor per NEI 99-01 guidance.
(ACTION: W3 to provide correlation.)
Licensee does not address the 'fuel transfer canal", which is identified under NEI 99-01, AA2 - Example EAL 2. Identify deletion as either deviation or difference under and provide justification for change, or provide proposed changes to comply with NEI 99-01 guidance. (ACTION: ANO will clarify terminology.)
Provide more detailed justification that 80 R/hr is procedurally referenced in 050SO01 OEPO4 as the dose rate limit for unrestricted (normal occupational limits) dose controls. Typically, the limit in this EAL is the dose rate where additional dose authorization is necessary to permit entry into a high radiation area. (ACTION: W3 has lead; RP to provide fleet value.)
Licensee lists the deletion of site-specific water level indication as a difference, rather than a deviation.
While deletion is technically justified, provide further clarification why change does not constitute a deviation, based on the elimination of specific NEI 99-01 example EAL criteria, or provide change listing deletion as a deviation. (ACTION:
W3 to provide additional justification.)
CATEGORY A: ABNORMAL RADIOLOGICAL CONDITIONS 2of 2 AA2 Arkansas Nuclear One Grand Gulf River Bend Waterford EAL 2 Typo under difference explanation.
Licensee inserted the qualifier: 'For Look for comparison with other this event, by definition, the loss of Entergy plants for reference to a site water inventory would have to exceed specific level for cavity. Typically, a makeup capacity.' This statement method is available in refueling may be misleading, since EAL is outages where level can be applicable if irradiated fuel is monitored, even with alarm capability.
uncovered, regardless of make-up (ACTION: GGNS does not have capacity. For example, sufficient water level instrumentation.)
make-up capacity may have been available, but not Initiated in a timely manner to prevent the uncovery of irradiated fuel. Provide further clarification of basis qualifying statement. (ACTION: W3 does not
.have level Instrumentation.)
Combining EALs 99-01 AA2 #1 and
- 2 appears to result in two different conditions being combined and causing deviations in EALs. Explain rationale for 9500 mr/hr before declaring Alert (explanation is in basis, and used distance from TOF for spent fuel). Explain why deviating from #2 by use of AND /OR and not including pool level value. (ACTION:
RBS will break out Into 2 EALs; W3 has lead on developing common fleet RP values.)
A.
A.
CATEGORY A: ABNORMAL RADIOLOGICAL CONDITIONS 1 of 3 AA3 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition Differences listed in Attachment 4 state that "[flor EAL #1...of the ANO's EALs, a site-specific list is not provided since the possible plant conditions and configurations are very diverse." However, the licensee does provide a listing of site-specific areas under AA3-EAL 1, contrary to the statement made in Attachment 4.
In addition, the site-specific listing under AA3, EAL 1 in Attachment 2 (EAL Matrix) states "Control Room, TSC...", while Attachment 3 (EAL Basis) states "Control Room/TSC...".
Clarify the use of a site-specific listing under AA3, EAL 1. Also, clarify the inconsistency between the EAL Matrix and Basis regarding whether the TSC from the Control Room, and whether the TSC is a continuously occupied area as specified in Basis.
(ACTION: ANO will provide site-specific list.)
Licensee deviates from NEI 99-01 guidance by using "radiation survey" vs. site-specific radiation monitor reading. Licensee's justification is that Control Room radiation monitor is not safety-qualified, and therefore, would be validated by survey. Per NEI 99-01 guidance, the term "VALID" is used in conjunction with radiation monitor to address this contingency. The radiation monitor is used to provide prompt assessment of accident conditions, and considered VALID unless proven otherwise per definition. If radiation monitor is unavailable or determined to be invalid, then the use of direct survey readings would apply under EALs, in lieu of specific radiation monitors. This interpretation is consistent with licensee Basis, which states that "[tjhe radiation levels in the EALs for this IC may be identified by a radiation monitor value or direct survey. Revise EAL 1 to address NEI 99-01, AA3 / EAL 1 criterion and inconsistency between proposed EAL 1 and Basis statement.
In addition, provide further clarification, if not restored to NEI 99-01 EAL 1 criterion, why change does not constitute a deviation, based on the revision of specific NEI 99-01 example EAL criterion, or provide change listing deletion as a deviation.
i EAL 1
CATEGORY A: ABNORMAL RADIOLOGICAL CONDITIONS 2of 3 AA3 Arkansas Nuclear One Grand Gulf River Bend Waterford NEI 99-01, AA3 / EAL 1 requires licensee to Identify site-specific areas requiring continuous occupancy to maintain plant safety functions, and specifically references under Basis the Control Room, Radwaste Control Room and Central Alarm Station (CAS). Licensee only addresses the Control Room, and does not reflect changes as deviations from NEI 99-01 EAL 1 criterion. Describe evaluation performed for determining areas requiring continuous occupancy to maintain plant safety functions and basis for elimination of the Radwaste Control Room and CAS from consideration. In addition, provide justification for any deviations from NEI 99-01, AA3 / EAL 1 guidance. (ACTION: W3 will Identify site-specific areas.)
Licensee states in Attachment 4 that
"[flor EAL...#2 of the ANO's EALs, a site-specific list is not provided since the possible plant conditions and configurations are very diverse."
However, the licensee states In Basis (last paragraph) that "[a]pplicable areas requiring infrequent access are identified in the site's Abnormal Operating Procedures, Emergency Operating Procedures, the 10 CFR 50 Appendix R analysis, and/or analyses performed In response to Section 2.1.6b of NUREG-0578..."
Provide further justification why the referenced documents cannot be used to Identify areas containing safe shutdown equipment, or proposed changes to comply with NEI 99-01 guidance. (ACTION: ANO to provide site-specific list.)
Licensee has expanded EAL 2 criteria to add qualifier: "and access is required for safe plant operation, but is impeded due to radiation dose rates." As revised, criteria establishes that dose exceeds 20 R/hr and access is impeded due to an undefined radiation dose rate.
Clarify EAL 2 criteria to specifically address that reaching > 20 R/hr in areas requiring access, per Basis guidance, is threshold for impeding area access, and provide justification for any deviations from NEI 99-01, AA3 / EAL 2 guidance. In addition, do common Entergy radiation protection procedures exist that would provide for a consistent dose rate threshold among Entergy plants?
(ACTION: W3 has lead to determine fleet value.)
CATEGORY A: ABNORMAL RADIOLOGICAL CONDITIONS 3of3 AA3 I
Arkansas Nuclear One Grand Gulf I
River Bend I
Waterford EAL 2 Licensee inserted the qualifier: "and access is required for safe plant operation, but Is impeded due to radiation dose rates", which is not part of criterion in NEI 99-01 AA3 -
Example EAL 2. Identify change asC deviation or difference under, and provide justification for proposed change based on NEI 99-01 example EAL criterion and basis. (ACTION: W3 has lead to determine fleet value.)
Describe Max safe ops values in more detail. Does this apply to equip.
or personnel? (ACTION: W3 has lead; develop fleet wording.)
a Licensee specifies a threshold of 5000 mR/hr. Describe whether the station's normal occupational exposure guidelines and limits would impede (delay) access to areas, i.e.,
the need for administrative approvals and briefings prior to entry, as discussed in NEI 99-01, AA3 Basis.
If so, provide further justification or proposed change to dose rate threshold that would ensure unimpeded access during an emergency. (ACTION: W3 has lead to determine fleet value.)
CATEGORY A: ABNORMAL RADIOLOGICAL CONDITIONS 1 of 3 AS1 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition EAL I Provide additional discussion on the deviation (correctly listed) for not listing default monitor set points for NEI 99-01 AS1. Other Entergy plants have included (ex. River Bend) monitor readings. Additional discussion to justify the provision for prompt dose assessment in the control room (in less than 15 minutes) and the procedurallcommitment related hooks in place to prevent this capability from being removed in the future are not discussed. Specifically discuss the locations where dose asmt. Computers are located, which have back up battery power or EDG backup power. In AS1 EALs #1 and
- 2, explain the deviation from the NEI 99-01 AS1 IC reference to "for more than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />". (ACTION: GGNS to provide list of monitors.)
4 Explain deviation for using dose/hr values versus the 99-01 total dose criteria. (ACTION: RBS will eliminate table and place values within EALs.)
EAL 2 (EALs 2 & 3) Licensee proposes to consolidate dose assessment and filed survey data EAL criteria under a common EAL for TEDE (whole body) and thyroid CDE. However, while identifying the threshold dose at or beyond the site boundary, the proposed AS1 / EALs 2 and 3 do not address specific NEI 99-01 EAL criteria for interpreting field survey data. NEI 99-01 EAL 4 criteria states that "[flield survey results Indicate closed window dose rates exceeding 100 mR/hr expected to continue for more than one hour; or analysis of field survey samples Indicate thyroid CDE of 500 mR for one hour of inhalation, at or beyond the site boundary." Provide further justification for the deletion of criteria from EAL statements, or provide' change to comply with NEI 99-01 guidance. (ACTION: NEI wording EAL 3 EAL 4
CATEGORY A: ABNORMAL RADIOLOGICAL CONDITIONS 2 of 3 AS1 I
Arkansas Nuclear One I
Grand Gulf I
River Bend I
Waterford in NEI EAL Differences Document, under General Comments, the licensee states that "...the Emergency Plan Exclusion Area Boundary is the site boundary."
However, the term Exclusion Area Boundary Is not defined for user reference In EAL matrix or EAL Basis definitions. Define term "Exclusion Area Boundary" in EAL AG1/AS1 Bases or under Definitions consistent with that provided under General Comments in the NEI EAL Differences Document. (ACTION:
W3 will add definition.)
CATEGORY A: ABNORMAL RADIOLOGICAL CONDITIONS 3of 3 AS1 Arkansas Nuclear One Grand Gulf River Bend Waterford NEI 99-01 AS1/AG1 Bases guidance states that the meteorology and source term used should be the same as those used for determining the monitor reading EALs in ICs AUl and AA1. However, the licensee's Basis states that a methodology consistent with AUW and AA1 was not used for AS1/AG1. Rather, licensee appears to determine AS1/AG1 thresholds based on a ratio from AUl dose rates. NEI 99-01 Basis and Appendix A state that thresholds for AUl and AA1 are developed using ODCM methodology, and AS1 and AG1 using dose assessment method.
Provide calculations for AS1 EAL 1 monitor readings based on meteorology and source term used in AU1 and AA1 using station dose assessment model, versus ODCM calculational methodology, for comparison with proposed licensee AS1/AG1 EAL monitor readings. In addition, provide justification under NEI EAL Differences Document for deviation from NEI 99-01 guidance.
(ACTION: W3 to modify wording.)
CATEGORY A: ABNORMAL RADIOLOGICAL CONDITIONS I of I AG1 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition EAL 1 Under NEI 99-01, example typo (100 mR/hr). Same as AS1 EALs #1 and
- 2, explain the deviation from the NEI 99-01 AS1 IC reference to "for more than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />".
EAL Basis (Attachment 4) provides a listing of applicable effluent radiation monitors. However, listing is not provided in EAL matrix (Attachment
- 3) for event classification purposes.
Clarify justification for inconsistency between attachments, or provide listing of applicable effluent radiation monitors In EAL matrix. (ACTION:
W3 to establish list.)
Explain use of dose/hr values for field team readings, which may be higher than total dose values.
EAL 2 (EALs 2 & 3) Licensee proposes to consolidate dose assessment and filed survey data EAL criteria under a common EAL for TEDE (whole body) and thyroid CDE. However, while identifying the threshold dose at or beyond the site boundary, the proposed ASI I EALs 2 and 3 do not address specific NEI 99-01 EAL criteria for interpreting field survey data. NEI 99-01 EAL 4 criteria states that "[f]ield survey results indicate closed window dose rates exceeding 100 mR/hr expected to continue for more than one hour; or analysis of field survey samples indicate thyroid CDE of 500 mR for one hour of inhalation, at or beyond the site boundary." Provide further justification for the deletion of criteria from EAL statements, or provide change to comply with NEI 99-01 guidance. (ACTION: NEI wording la connfusainn???)
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Initating Condition (IC) Statements ARKANSAS NUCLEAR ONE WATERFORD 3 Licensee Basis states that 'Waterford 3 uses Safety Function Status Checks developed by the Combustion Engineering Owners Group (CEOG) which are based on the logic similar to that used for CSFSTs [Critical Safety Function Status Trees] developed for Westinghouse PWR [Pressurized Water ReactorJ.
Clarify whether technical equivalency can be identified related to the following critical safety function statuses identified in NEI 99-01, Table 5-F-4: Core Cooling
- Red; Core Cooling - Orange; RCS Integrity - Red; Heat Sink - Red; Containment - Red. (ACTION: W3 to provide copy of CEOG document.)
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Fuel Clad Barrier #1 - Critical Safety Function Status ARKANSAS NUCLEAR ONE WATERFORD 3
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Fuel Clad Barrier #2-Primary Coolant Activity Level ARKANSAS NUCLEAR ONE WATERFORD 3 I
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Fuel Clad Barrier #3 - Core Exit Thermocouple Reading ARKANSAS NUCLEAR ONE I
WATERFORD 3
+
4.
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Fuel Clad Barrier #4-Reactor Vessel Water Level ARKANSAS NUCLEAR ONE WATERFORD 3 l
l I
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Fuel Clad Barrier #5-Containment Radiation Monitoring ARKANSAS NUCLEAR ONE WATERFORD 3
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Fuel Clad Barrier #6 - Other (Slte-Svecific) Indications ARKANSAS NUCLEAR ONE WATERFORD 3 Provide evaluation of other site-specific indications of a loss or potential loss of the Fuel Clad Barrier per NEI 99-01 guidance, including indications from containment air monitors or other site-specific instrumentation. (ACTION: W3 I will provide additional lustificatlon.)
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Fuel Clad Barrier # 7-Emergency Director Judment ARKANSAS NUCLEAR ONE WATERFORD 3
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Reactor Coolant System Barrier #1 - Critical Safety Function Status ARKANSAS NUCLEAR ONE I
WATERFORD 3 i
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Reactor Coolant System Barrier #2 - RCS Leak Rate ARKANSAS NUCLEAR ONE WATERFORD 3 (RCB2/Potential Loss) Provide justification for establishing a specific RCS leak rate versus NEI 99-01 guidance criterion statement of "...exceeding the capacity of one charging pump In the normal charging mode", since pump discharge rate may vary based on plant conditions, or provide change to comply with NEI 99-01 Table 5-F-4 criterion. (ACTION: W3 will provide additional Information - has positive displacement pump.)
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Reactor Coolant System Barrier #3-SG Tube Rupture ARKANSAS NUCLEAR ONE I
WATERFORD 3
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Reactor Coolant System Barrier #4 - Containment Radiation Monitoring ARKANSAS NUCLEAR ONE WATERFORD 3 (RCB4) Provide basis for 60 uCVgm dose equivalent 1-131, consistent with NEI 99-01 guidance.
(RCB4) Indications for an RCS Barrier LOSS, based on Containment Radiation Monitoring, were omitted from EAL Matrix in Attachment 2. Revise EAL Matrix to reflect RCB4 indications as outlined In EAL Basis (Attachment 3). (ACTION:
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Reactor Coolant System Barrier #5-Other (Site-Specific) Indications ARKANSAS NUCLEAR ONE I
WATERFORD3
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Reactor Coolant System Barrier #6 - Emergency Director Judgment ARKANSAS NUCLEAR ONE WATERFORD 3
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Containment Barrier #1 - Critical Safety Function Status ARKANSAS NUCLEAR ONE WATERFORD3 l
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Containment Barrier #2-Containment Pressure ARKANSAS NUCLEAR ONE WATERFORD 3 (CNB1/2nd Loss) Licensee states "Containment pressure not consistent with (CNB1 / Potential Loss) Clarify whether safety analysis report or other site-event response". This is inconsistent with NEI 99-01 criterion, which states specific accident analyses identify a site-specific explosive mixture that would "Containment pressure or sump level not consistent with LOCA conditions".
represent a challenge to containment, equivalent to at least the lower deflagration Change was not identified by licensee as a deviation or difference under limit. If not, discuss why explosive mixture, equivalent to at least the lower. Identify as a deviation or difference and provide technical deflagration limit, could not be determined based on Industry and owners group justification, or provide proposed change to comply with NEI 99-01 guidance.
guidance. In addition, discuss basis for Containment hydrogen threshold under (ACTION: ANO will provide clarification.)
Basis for CNBI1.
(CNB1/1st Potential Loss) EAL criteria statement in Attachment 4 is worded, "Design pressure and increasing hydrogen concentration > 4%". This is inconsistent with NEI 99-01 guidance, which states "(Site-specific) PSIG and increasing OR Explosive mixture exists". Revise POTENTIAL LOSS criteria in to reflect consistency with NEI 99-01 guidance.
(CNB1/2nd Potential Loss) NEI 99-01 guidance establishes criterion, 'Explosive mixture exists", which per the NEI 99-01 Basis means a hydrogen and oxygen concentration of at least the lower deflagration limit curve exists. The licensee's criterion only states "Containment Hydrogen Concentration greater than 4%", and does not address oxygen component. Provide hydrogen and oxygen concentrations reflective of the lower deflagration limit for AN01 and ANO 2 containment structures, or provide further justification why oxygen concentration is not applicable to ANOI and 2. In addition, revise criteria identified for an "explosive mixture inside containment" under CG1 - EAL 3 to ensure consistency with threshold in CNBI1. (ACTION: ANO to provide additional discussion on 4d0l rt-nnssnfr.dInn I
CATEGORY F: FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Containment Barrier #3-Core Exit Thermocouple Reading ARKANSAS NUCLEAR ONE WATERFORD 3 (CNB2/Potentlal Loss) NEI 99-01 guidance defines a POTENTIAL LOSS as 'core exist thermocouples in excess of 1200 degrees and restoration procedures not effective within 15 minutes." Licensee has revised NEI 99-01 statement for ANO-1 to state, 'Significant ICC exists as evidenced by CETs indicating superheated conditions...", but does Identify change as a deviation or difference. Identify as deviation or difference and provide Justification, as applicable to ANO-1, for or provide proposed change to comply with NEI 99-01 guidance. (ACTION: ANO to provide additionallustification.)
(CNB2/Potential Loss) NEI 99-01 guidance also defines a POTENTIAL LOSS as "core exit thermocouples in excess of 700 degrees with reactor vessel level below top of active fuel and restoration procedures not effective within 15 minutes." Licensee states that this criterion is not considered since RVLMS Is used as an indication of potential core uncovery only if core exit thermocouple (CET) indication is unavailable. Provide further technical justification for deviation consistent with response to Specific Comment #23.
(ACTION: ANO to provide additional justification.)
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Containment Barrier #4-SG Secondary Side Release with Primary-to-Secondary Leakage ARKANSAS NUCLEAR ONE WATERFORD 3 (CNB3/Loss) Licensee considers NEI 99-01 criterion, 'RUPTURED SIG is also faulted outside of containment", as redundant, and therefore, does not address or provide further justification. NEI 99-01 Basis (3rd paragraph) acknowledges that
"(ulsers should realize that the two "loss" EALs described above could be considered redundant." Per NEI 99-01 Section 5.4, this criteria is defines as preliminary-to-secondary leakage of sufficient leakage to require or cause a scram and safety injection (RUPTURED) AND results in uncontrolled S/G pressure or S/G being drained comDletelv. This differs from Containment Barrier Example EAL 4 (2nd criterion) which reflects a non-isolable (prolonged) release path to the environment from the affected S/G. Provide further technical justification for deviation or proposed change to comply with NEI 99-01 guidance.
(CNB3/Loss) Provide EAL corresponding to NEI 99-01 criterion for a "RUPTURED S/G [steam generator] is also FAULTED outside the containment,"
per Basis definitions, or provide specific technical justification for deviation from NEI 99-01 guidance.
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Containment Barrier #5 - CNTMT Isolation Valves Status After CNTMT Isolation ARKANSAS NUCLEAR ONE WATERFORD 3 (CNB4/Loss) Licensee criterion states, Unisolable breach of containment with a (CNB4/Loss) Provide justification for addition of qualifier, '...following direct release path to the environment following containment isolation actuation." containment isolation actuation." (ACTION: W3 Is considering modifying This is inconsistent with NEI guidance, which states "Valve(s) not closed AND wording.)
downstream pathway to the environment exists." In addition, licensee chose not to incorporate NEI 99-01 Basis discussion into CNB4 Basis. Identify changes as deviation or difference, and provide justification for change in EAL wording. Also, provide rational for the failure to address NEI 99-01 Basis guidance. (ACTION:
ANO to evaluate addition of new wording.)
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Containment Barrier #6-Significant Radioactive Inventory In Containment ARKANSAS NUCLEAR ONE WATERFORD 3 (CNB5/Potential Loss) Clarify In licensee Basis that Containment high range radiation monitor reading of 4,000 R/hr corresponds to 20% fuel clad damage, or other site-specific analysis value, per the guidance in NEI 99-01 Basis.
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Containment Barrier #7-Other (Site-Specific) Indications ARKANSAS NUCLEAR ONE WATERFORD 3 (CNB6) NEI 99-01 Basis states this EAL should cover other site-specific Provide evaluation of other site-specific indications of a loss or potential loss of indications, including: area or ventilation monitors in containment annulus or other the Containment Barrier per NEI 99-01 guidance, including indications from area contiguous buildings that may unambiguously Indicate a loss or potential loss of or ventilation monitors in containment annulus or other contiguous buildings, or the containment barrier, or venting of containment per site emergency operating the intentional venting of containment per emergency operating procedures to procedures. Provide rational in licensee Basis why these criteria are not prevent a catastrophic failure.
considered applicable to ANO-1 and/or ANO-2 Containment structures, or proposed wording to comply with NEI 99-01 Basis guidance. (ACTION: W3 has lead to contact NEI In advance of NRC meeting.)
(CNB6) Licensee chose to include "at least 20% fuel damage failure as determined from core damage assessment" as a POTENTIAL LOSS of containment, based on basis for CNB5 (Significant Radioactive Inventory in Containment). In CNB6 Basis, licensee Justifies EAL by stating that "[r]regardless of whether containment is challenged, this amount of activity In containment, if released, could have such severe consequences that it is prudent to treat this as a potential loss of containment." Describe why the licensee believes that this concern is not adequately address under CNB5, based on containment radiation monitor readings, since this is intent as outlined in NEI 99-01 Table 5-F-4, Containment Barrier Example EAL 6 Basis. (ACTION: ANO willprovide additinal justification of approach.)
CATEGORY F: PWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-4: Containment Barrier #8-Emergency Director Judgment ARKANSAS NUCLEAR ONE WATERFORD 3
CATEGORY F: BWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-2: Initating Condition (IC) Statements GRAND GULF (GGNS)
RIVER BEND (RBS)
(FAl) Typo for font in IC "reactor pressure boundary" (ACTION: GGNS to correct typo.)_
CATEGORY F: BWR FISSION PRODUCT BARRIERS I of 1 TABLE 5-F-2: Fuel Clad Barrier #1 - Primary Coolant Activity Level GRAND GULF (GGNS)
RIVER BEND (RBS)
Provide justification that compares the listed 5% clad failure with "300 uci/ml Explain use of 300 uc/gm, versus the use of 4 ucVgm for this EAL at other value In NEI 99-01. To be consistent with 99-01, the EAL for clad failure should Entergy BWRs. In justification, provide evidence that the 300 ucilgm activity be 300 ucVmi.
would correspond to less than 5% fuel failure, as referenced in NEI 99-01.
_(ACTION: 4 uclfgm?)
CATEGORY F: BWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-2: Fuel Clad Barrier #2 - Reactor Vessel Water Level GRAND GULF (GGNS)
RIVER BEND (RBS)
Is the use of "-1 92 in" a typo in the difference explanation? Provide more detailed discussion on the use of either level indication justification (as referenced in 99-01, TOAF or 2/3 coverage of active fuel) and Identify which value Is used for this EAL. (ACTION: GGNS to provide additional clarification.)
CATEGORY F: BWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-2: Fuel Clad Barrier #3-Drywell Radiation Monitoring GRAND GULF (GGNS)
RIVER BEND (RBS)
CATEFORY F: BWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-2: Fuel Clad Barrier #4-Other (Site-Specific) Indications GRAND GULF (GGNS) l RIVER BEND (RBS)
CATEGORY F: BWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-2: Fuel Clad Barrier #5-Emerqencv Director Judment GRAND GULF (GGNS)
RIVER BEND (RBS)
CATEGORY F: BWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-2: Reactor Coolant System Barrier #1 - Drywell Pressure GRAND GULF (GGNS)
RIVER BEND (RBS)
[
I I
CATEGORY F: BWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-2: Reactor Coolant System Barrier #2-Reactor Vessel Water Level GRAND GULF (GGNS)
RIVER BEND (RBS)
[
I I
CATEGORY F: BWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-2: Reactor Coolant System Barrier #3 - RCS Leak Rate GRAND GULF (GGNS)
RIVER BEND (RBS)
NEI 99-01 EAL #2 (potential loss outside drywell) is missing. Discuss the deviation and provide justification for omitting or include in EAL scheme.
(ACTION: GGNS will change to agree with RBS.)
Justify the omission of 'inside the drywell' for the potential loss for greater than 50gpm RPB leakage. (ACTION: GGNS will change to agree with RBS.)
CATEGORY F: BWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-2: Reactor Coolant System Barrier #4 - Drywell Radiation Monitoring GRAND GULF (GGNS)
RIVER BEND (RBS)
This EAL is omitted form the GG EALs. This is listed as a difference due to NEI 99-01 discusses the inclusion of shine dose in this EAL, and expects that a location of monitors. The explanation Is not sufficient to Justify the omission.
differentiation be applied to determine the presence of either a single barrier of 2 Provide more justification why this EAL should be omitted or add NEI 99001 EAL barriers (clad and RCS) lost. It does not appear that the deviation is acceptable to the scheme. (ACTION: GGNS will align with RBS.)
justification to omit this EAL. Provide specific information for this EAL, consistent with other Entergy sites if possible, to Include within this scheme. (ACTION:
_RBS and GGNS should have common approach.)
CATEGORY F: BWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-2: Reactor Coolant System Barrier #5-Other (Site-Specific) Indications GRAND GULF (GGNS)
RIVER BEND (RBS)
Additional information may be warranted for this EAL, beyond simply a stuck open relief valve. As example, also Increases in suppression pool bulk temperature greater than TS limit.
CATEGORY F: BWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-2: Reactor Coolant System Barrier #6-Emergency Director Judgment GRAND GULF (GGNS)
I RIVER BEND (RBS)
I.
CATEGORY F: BWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-2: Containment Barrier #1 -
Drywell Pressure GRAND GULF (GGNS)
RIVER BEND (RBS)
NEI 99-01 also discusses 02 levels, which are omitted in the GG EAL. Justify your omission of the oxygen concentration and comparison to the lower deflagration limit.
CATEGORY F: BWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-2: Containment Barrier #2-Reactor Vessel Water Level GRAND GULF (GGNS)
RIVER BEND (RBS)
CATEGORY F: BWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-2: Containment Barrier #3-CNTMT Isolation Failure or Bypass GRAND GULF (GGNS)
RIVER BEND (RBS)
Define SAPs". Justify the deviation from declaring a loss from CTMT venting per EOPs, which Is referenced in NEI 99-01. (This is incorrectly listed as a difference.)
CATEGORY F: BWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-2: Containment Barrier #4-Significant Radioactive Inventory In Containment GRAND GULF (GGNS)
RIVER BEND (RBS)
Justify the value (> 11,500 R/hr) in regard to being representative of 20% fuel (PC#3) Explain use of 9500 mr/hr justification for id of CTMT leakage. Value clad damage. (ACTION: GGNS to evaluate use of RBS approach.)
appears quite high to be associated with leak path (in that there would have to also be some core damage). (ACTION: RBS to coordinate response with GGNS.)
CATEGORY F: BWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-2: Containment Barrier #5-Other (Site-Specific) Indications GRAND GULF (GGNS)
RIVER BEND (RBS)
- Look at other sites for comparison. Appears to be some additional conditions l___
lthat should be referenced here.
CATEGORY F: BWR FISSION PRODUCT BARRIERS 1 of 1 TABLE 5-F-2: Containment Barrier #6-Emergency Director Judgment GRAND GULF (GGNS)
RIVER BEND (RBS)
CATEGORY S: SYSTEM MALFUNCTIONS SU2 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition EAL 1 1
1 I
1 of 1
CATYEGORY S: SYSTEM MALFUNCTIONS 1 of 1 SU3 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition Provide description In Basis, and technical justification as a deviation to NEI 99-01 guidance, for the use of "50% of Control Room annunciators for Unit 1, versus the definition of "most" as 75% per NEI 99-01 SU3 Basis. (ACTION: ANOwillprovide additional information.)
Describe logic for referencing Reg.
Guide 1.97, rather than listing specific Control Room Indicator panels containing safety system Instrumentation per Table 3 to Reg.
Guide 1.97. In addition, clarify how operators are trained to promptly recognize and quantify a loss of Reg.
Guide 1.97 Instrumentation or if specific measures are In place to label instrumentation to allow for the prompt classification of event.
(ACTION: W3 to research In more detail and add additional Information as applicable.)
EAL 1 Provide a description of the number of Control Room annunciator panels in Unit 2 (ANO-2) and what systems /
functions (in general terms) are provided on each panel. In addition, describe how the loss of 9 panels in Units 2 (ANO-2) constitutes a loss of most (75%) of annunciators.
(ACTION: ANO will provide additional Information.)
Licensee has chosen to insert the qualifier 'Loss of AC and DC' as reason for annunciator loss.
Describe what percentage of annunciators are powered by either an AC or DC power source, or combination of both. In addition, describe any credible scenarios, other the loss of AC and DC power, that would resulting a significant loss of Control Room annunciators.
(ACTION: ANO will provide additional Information.)
I I
.1
CATEGORY S: SYSTEM MALFUNCTIONS SU4 Arkansas Nuclear One Grand Gulf River Bend Waterford (SU10) Justify the deviation (not Inltating difference) for including modes 1, 2, Condition and 3 in this IC. (ACTION: GGNS to separate cold shutdown EALs.)
(SU9) i censee states that "ANO uses the letdown radiation monitor (if available) as a qualitative measure of potential fuel clad degradation", but does not provide monitor per NEI 99-01, CU5 - EAL 1. Provide the alarm setpoint(s) for the letdown radiation monitor In ANO-1 and ANO-2, and EAL 1 describe how the setpoint(s) correlate to Technical Specification allowable limits. If alarm setpolnt does correspond to Technical Specification allowable limits, provide further technical justification for deviation from NEI 99-01 guidance.
EAL 2 1 of 1
CATEGORY S: SYSTEM MALFUNCTIONS SU5 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition Deviation appears justified, however, NEI 99001 still lists the 10 gpm limit In the EAL, which could be observed In some situations using remotely Installed equipment (as in refueling outages). Recommend that the 10 gpm be left In, and the inclusion of EAL 1 level also included. Additional justification is necessary for the omission of the 10 gpm.
Identification of A0 A Is missing from the discussion. Is 0 at the reactor head flange? Compare to other Entergy plant EALs. (ACTION: No practical way to measure.)
NEI 99001 lists 25gpm as the EAL (SU2 / EAI-2) Explain why 35 gpm Is (SU7) Provide justification for Basis for Identified leakage. In the GG used instead of 30, which is the TS statement, "[alt Waterford 3, steam basis, 35 gpm Is discussed as the limit at RBS. Site the specific TS generator leakage is considered to minimum limit for detection for references to justify this deviation be identified leakage." In addition, unidentified leakage, but Is the (and classify in section correctly.)
clarify why this statement would also identified leak rate limit in the EAL not be applicable during cold 10 gpm Is the unidentified limit.
shutdown mode per CU1. (ACTION:
EAL 2 Correct the references In the basis, W3 to modify statement.)
and justify the deviation for using 35 gpm as the Identified leak rate, versus 25 gpm in 99001. This Is listed as a difference instead of a deviation. (ACTION: GGNS willadd additional Information.)
1 of I
CATEGORY S: SYSTEM MALFUNCTIONS SU6 Arkansas Nuclear One Grand Gulf River Bend Waterford (SU9 Dev.Diff. document) Justify the deviation (not difference) for including Initiating modes 1, 2, and 3 In this IC.
Condition(ACTION:
GGNS to separate cold shutdown EALs.)
EALl (SUB / Tables Ml & M2) Ucensee (SU8 / Tables Ml & M2) Licensee includes portable cellular telephones includes cellular telephones under under onsite and offsite onsite and offsite communications communications capability. Clarify capability. Clarify whether whether implementing procedures implementing procedures address the address the use of cellular phones as use of cellular phones as a means of a means of onsite communications offsite communications for EALs 1 & 2 and offsite notification for consideration under these EALs, and consideration under these EALs, and that cellular phones will function that cellular phone will function effectively within or in close proximity effectively within or In close proximity to plant structures to be considered a to plant structures. (ACTION: ANO means of onsite and/or offsite clarify.)
communications. (ACTION: W3 clarify.)
(SUB / Table M2) Licensee includes (SU8 I Table M2) Ucensee lists civil the Station Radio System under defense radios under offsite offsite communications capability.
communications equipment, but NEI Clarify whether Implementing 99-01 CU6 Basis lists radio procedures address the use of the transmissions as an extraordinary Station Radio System as a means of means of offsite communications.
EAL 2 offsite notification purpose for Clarify whether Implementing consideration under these EALs.
procedures address the use of civil (ACTION: ANO clarify.)
defense radios as a back-up means of offsite communications.
(ACTION: W3 procedure Includes civil defense radios - Plan?)
1 of 1
CATEGORY S: SYSTEM MALFUNCTIONS SU8 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (Sul0) Clarify use of terms "extended" vs. "sustained" for consistency with EAL thresholds and EAL I
.use of terms In licensee SU10 and CU7 Bases. (ACTION: W3 to clarify wording.)
Describe in Basis the rational for Unit 1 (ANO-1) and Unit 2 (ANO-2) EAL thresholds established by licensee, and Justification for Inclusion of site-EAL 2 specific thresholds for Inadvertent criticality In SUB (Modes 3/ 4), but not under CUB (Modes 5/ 6).
(ACTION: ANO to add additional Information.)
1 of 1
CATEGORY S: SYSTEM MALFUNCTIONS SA2 Arkansas Nuclear One Grand Gulf River Bend Waterford Clarify whether rod withdrawal would occur in hot standby (Mode 3), as part of a plant start-up, prior to entering Mode 2. If rod withdrawal Initiating would Initiate In hot standby, prior to Condition entering Mode 2 (Start-up), then address Mode 3 applicability per NEI 99-01 guidance. (ACTION: W3 to clarify wording.)
Licensee has revised EAL wording in EAL Basis (Attachment 3) to include qualifier "...and a successful manual trip or DSS trio Occurred. This change is not consistent with NEI 99-01 guidance, nor the wording EAL 1 contained In EAL Matrix (Attachment 2). Resolve Inconsistency between EAL Matrix and Basis, and If retained, Identify change as a deviation and provide Justification to support revision to NEI 99-01 guidance. (ACTION: ANO to add udtrfiltnnl Infnt rrnnn I Under examples of what constitutes a In the basis, the allowance for ARI as Intent of the NEI 99-01 IC is to "manual tri, licensee Inserted one of the successful means for a address the failure of an automatic example: 'de-energizing rod drive manual scram is referenced. Discuss shutdown, whenever an automatic mechanism". Clarify that, based on the ability (in terms of time and reactor trip is initiated. While steam NEI 99-01 guidance, the rod drive operator actions (le. Manual actions generator high level per the mechanism can be de-energized or control room actions) to use ARI Waterford 3 Technical Specifications from main control rod panels, and as a means to A rapidly@ manually does not correspond to a safety limit, does not require action In other shut down the reactor.
its functional capability at the adjacent Control Room auxiliary (side specified trip setting is required to or back) panels (i.e., pulling fuses) or enhance the overall reliability of the actions outside of control room, which Reactor Protection System (RPS),
Basis are not to be considered under a and therefore, should be applicable manual scram. (ACTION: ANO to to this IC. This is also applicable to provide additional Information.)
RCS flow-low. Provide further justification why not to address the failure to initiate or complete a reactor trip whenever any automatic reactor trip signal Is Initiated which would potentially create an Anticipated Transient Without Scram (ATWS) event, or provide change to comply with intent of NEI 99-01 I juidance. (ACTION: W3 to modify 1 of 1
CATEGORY S: SYSTEM MALFUNCTIONS 1 of 1 SA4 l
Arkansas Nuclear One l
Grand Gulf River Bend Waterford Initiating Condition _
Define what constitutes a loss of most or all Indicators, consistent with licensee's SU3-EAL 2, or identify as a deviation and provide Justification from NEI 99-01 guidance. (ACTION:
ANO to provide additional Information.)
Describe logic for referencing Reg.
Guide 1.97, rather than listing specific Control Room Indicator panels containing safety system Instrumentation per Table 3 to Reg.
Guide 1.97. In addition, clarify how operators are trained to promptly recognize and quantify a loss of Reg.
Guide 1.97 instrumentation or If specific measures are In place to label instrumentation to allow for the prompt classification of event.
(ACTION: W3 to research In more detail and add additional information as applicable.)
EAL I Ucensee uses term 'Plant Translent",
which is defined differently than a
'Significant Translenr per Sections 4.34 and 4.39, and NEI 99-01, Section 5.4. Please Identify as deviation or difference, as appropriate, and provide technical justification supporting change from NEI 99-01 guidance regarding a "Significant Transient, or provide proposed change to comply with NEI 99-01 guidance. (ACTION: ANO to provide additional Information.)
CATEGORY S: SYSTEM MALFUNCTIONS 1 of 1 SA5 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition EAL 1 Licensee Basis takes credit for temporary emergency diesels that may be used to supplement onsite AC power in the event emergency diesels are lost. Provide technical justification for deviation from NEI 99-01 CA3 / EAL 1.b criterion, which requires licensee to list site-specific Basis emergency diesel generators that are part of plant design and safety analysis, or provide change to comply with NEI 99-01 guidance. In addition, clarify specific reference to where credit is taken for temporary diesel generators in safety analysis report accident analyses or station blackout coping analysis. (ACTION: W3 to provide additional Information.)
CATEGORY S: SYSTEM MALFUNCTIONS SS1 Arkansas Nuclear One Grand Gulf River Bend Waterford ICs for NEI 99-01 for CA3 and SS1 states, "Loss of All Offsite Power and Loss of All Onsite Power to Essential Busses." Licensee defines "essential busses as "required 4.16 KV busses under CA3 IC and "vital 4.16 busses" under SS1 IC. Licensee also uses term "emergency busses" in CA1 EAL criterion, which Is consistent with NEI 99-01 guidance, but uses the term 'vital busses" in SS1 EAL criterion. In addition, NEI 99-01 example EAL criterion for CA3 and SS1 are Identical, with the Initiating exception of mode applicability, but Condition licensee criteria under CA3 and SS1 are not consistent. Licensee criterion under SS1 would not allow credit for the restoration of offsite power to an essential bus, but only from an emergency diesel generator. Provide justification for deviation In term definition and Interpretation of EAL criterion between licensee CA3 and SS1, and the apparent failure to address a restoration of offsite power to an essential bus within 15 minutes under SS1.
EAL for status of EDGs is missing from this IC. Provide EAL consistent with 99-01 or justify why this EAL Is EAL 1 omitted. (ACTION: RBS to provide additional reference to diesel generator.)
1 of 2
CATEGORY S: SYSTEM MALFUNCTIONS SS1 Arkansas Nuclear One Grand Gulf River Bend Waterford Licensee Basis takes credit for temporary emergency diesels that may be used to supplement onsite AC power In the event emergency diesels are lost. Provide technical justification for deviation from NEI 99-01 CA3 / EAL 1.b criterion, which requires licensee to list site-specific Basis emergency diesel generators that are part of plant design and safety analysis, or provide change to comply with NEI 99-01 guidance. In addition, clarify specific reference to where credit Is taken for temporary diesel generators in safety analysis report accident analyses or station blackout coping analysis. (ACTION: W3 to provide additional Information.)
2 of 2
CATEGORY S: SYSTEM MALFUNCTIONS SS2 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition EAL 1 In NEI 99D01 Basis discussion of SS2, there is a specific reference to operator actions away from the reactor control console which define a NOT SUCCESSFUL manual shutdown. That specific caution Is Basis missing from the GG Basis. Justify the omission of the caution, or correct the Basis to specifically Include the caution. As In Item 32, justify the use of ARI as a rapid Insertion of rods.
(ACTION: GGNS to provide additional wording In basis 1 of 1
CATEGORY S: SYSTEM MALFUNCTIONS 1 of 1 SS3 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition Describe rational for listing of unit-Modes are different than in 99-01.
specific busses in SS3 (Modes 1_4),
Explain this deviation from 99-01.
but not in CU7 (Modes 5 / 6). In (ACTION: RBS to provide addition, confirm that nomenclature JustIfIcatIon for hot shutdown In EAL 1 for Unit 1 (ANO-1) DC busses is D01 deviation document.)
and D02, versus use of unit designator 1 D01 and 2D02.
(ACTION: ANO will provide additional Information.)
CATEGORY S: SYSTEM MALFUNCTIONS 1 of 1 SS4 Arkansas Nuclear One Grand Gulf River Bend Waterford (SS5) Licensee inserted qualifier,
"...necessary to reach Hot Shutdown", in IC statement.
However, per NEI 99-01 Basis and Initiating licensee criteria provided, this IC Condition reflects capabilities to reach or maintain hot shutdown. Revise licensee proposed IC statement to reflect intent of NEI 99-01 guidance.
(ACTION: ANO will modify the
____________~~
_u nr dlrn rf I While not required per NEI 99-01 guidance, licensee has chosen to insert specific system availability to provide core cooling and heat sink.
EAL 1 Describe in Basis rational for the selection of Criteria 1.a, 1.b and 1.c.
(ACTION: ANO will provide additional Information.)
CATEGORY S: SYSTEM MALFUNCTIONS 1 of 1 SS6 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition.
Licensee uses term "Transient" in IC and EAL 1.d, which is not consistent with the use of "Plant Transient" by licensee in SA4 or the use of term "Significant Transient" under NEI 99-01 guidance. Identify as deviation or difference, as appropriate, and provide technical justification supporting change from NEI 99-01 guidance and Inconsistency with SA4, or provide proposed change to comply with NEI 99-01 guidance.
(ACTION: Ano to clarify wording.)
Use of word "unplanned" appears to indicate that if planned, this would be acceptable. Provide detailed justification why this deviation is acceptable, as written. (ACTION:
GGNS will modify wording.)
Describe logic for referencing Reg.
Guide 1.97, rather than listing specific Control Room indicator panels containing safety system Instrumentation per Table 3 to Reg.
Guide 1.97. In addition, clarify how operators are trained to promptly recognize and quantify a loss of Reg.
Guide 1.97 instrumentation or if specific measures are in place to label instrumentation to allow for the prompt classification of event.
(ACTION: W3 to research In more detail and add additional Information as applicable.)
- 1.
1 EAL 1 NEI 99-01 criterion states, "Indications needed to monitor (site-specific) safety functions are unavailable". However, licensee has established a threshold of a "loss of 75% of Indicators associated with safety systems." This is not consistent with NEI 99-01 guidance, which is intended to reflect that indication is not available to monitor a listing of site-specific safety functions.
Identify as a deviation or difference, as appropriate, and provide justification supporting changes and listing of site-specific safety functions, or provide proposed changes to comply with NEI 99-01 guidance.
(ACTION: ANO to provide further evaluation.)
NEI 99-01 does not require that all Reg. Guide 1.97 indication be lost as reflected in licensee EAL criteria, but rather that indication is not available to monitor a required safety function(s). Provide further justification or change to comply with NEI 99-01 guidance. (ACTION: W3 to modify wording and coordinate with ANO.)
CATEGORY S: SYSTEM MALFUNCTIONS SG1 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition NEI 99-01 guidance states, 'Site-No reference for EDGs. If EDGs are specific) indication of continuing operable, then busses would be degradation of core cooling based on powered. Provide Justification using Fission Product Barrier monitoring."
site drawings and electrical logic Licensee has designated criterion, diagrams to discuss the power-EAL 1
'FA1 entry conditions met."
related EALs. (ACTION: RBS to Designate Fuel Clad Barrier criteria add reference to diesel generator.)
from Fission Product Barrier Matrix, contained In Attachment 2, which specifically Indicate a continuing degradation of core cooling.
Ucensee Basis takes credit for temporary emergency diesels that may be used to supplement onsite AC power In the event emergency diesels are lost. Provide technical justification for deviation from NEI 99-01 CA3 / EAL 1.b criterion, which requires licensee to list site-specific Basis emergency diesel generators that are part of plant design and safety analysis, or provide change to comply with NEI 99-01 guidance. In addition, clarify specific reference to where credit Is taken for temporary diesel generators in safety analysis report accident analyses or station blackout coping analysis. (ACTION: W3 to provide additional Information.)
1 of 1
CATEGORY S: SYSTEM MALFUNCTIONS 1 of 1 SG2 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (1.a) Describe the correlation and technical basis between the unit-specific thresholds indicating core cooling is extremely challenged (EAL 1.a), with the NEI 99-01 Basis guidance of "core exit temperatures are at or approaching 1200 degrees or that the reactor vessel water level is below the top of active fuel."
(ACTION: ANO to evaluate further and provide consistency.)
Justify the use of ARI as "rapid' insertion of rods. -- Also in deviation/differences document.
(EAL2) NEI 99-01 Basis guidance and that provided in licensee Basis state that an indication that heat removal is extremely challenged is "if emergency feedwater flow is insufficient to remove the amount of heat required by design from at least one steam generator." However, licensee EAL criterion 2 states that "heat removal is extremely challenges by BOTH steam generators < 50% Wide Range and not feedwater available." Clarify inconsistency between licensee EAL criterion andJustification in NEI 99-01 and licensee Bases, or provide changes to EAL criterion to comply with NEI 99-01 guidance.
EAL 1 (1.b) Describe the correlation and technical basis between the thresholds indicating heat removal is extremely challenged (EAL 1.b), with the NEI 99-0 1 Basis guidance of "emergency feedwater flow is insufficient to remove the amount of heat required by design from at least one steam generator."
CATEGORY C: SHUTDOWN CONDITIONS CUl Arkansas Nuclear One Grand Gulf River Bend Waterford Provide further technical Justification for proposed modification to Mode 6 applicability by adding qualifier "Vith reactor vessel water level below the Condition reactor vessel flange," which deviates from NEI 99-01 mode definitions, criteria guidance. (ACTION: W3 will revise to match NEI 99-01.)
(CU1 I EALU) In deviation justification, explain relevance on 9.7 EAL 1 in. in relation to vessel level.
(Action: RBS to provide more justification In Basis)
Provide justification for Basis statement, "[alt Waterford 3, steam generator leakage is considered to be identified leakage." In addition, EAL 2 clarify why this statement would also not be applicable during cold shutdown mode per CU1. (ACTION:
W3 to modify statement.)
1 of 1
CATEGORY C: SHUTDOWN CONDITIONS CU2 Arkansas Nuclear One Grand Gulf River Bend Waterford Licensee IC statement in Attachment (CUi) Initiating condition (IC) title
Document does not reflect IC Initiatin (EAL Matrix) and under statement reflected under NEI 99-01 initian NEI 99-01 CU2. Correct CU2. Provide justification for inconsistency between IC difference, or provide change to statements. (ACTION: ANO to comply with NEI 99-01 IC statement correct Inconsistency.)
wording. (ACTION: W3 to correct
~Inconsistencv)
EAL 1 Combined with CUI (CU2 / EALI )Llcensee states (CU2 / EAL2) Why reverse order of Combined with CUl
'UNPLANNED RCS level drop below EALs? (ACTION: RBS will reverse the reactor vessel flange greater than EALs to match NEI 99-01.)
15 minutes," rather than NEI 99-01, CU2 - Example EAL 1 criterion of EAL 2
"[greater than or equal to] 2 15 minutes.' Provide justification for deviation, or proposed changes to comply with NEI 99-01 guidance.
(ACTION: ANO to change to match NEI 99-01.)
1 of 1
CATEGORY C: SHUTDOWN CONDITIONS CU3 Arkansas Nuclear One Grand Gulf River Bend Waterford Licensee has chosen to make IC (CU4 / EAL1) Explain why condition applicable for modes 5 (Cold of EDGs Is not Included. Discussion Shutdown), 6 (Refueling) and D says 'Implied that EDGs are (Defueled). NEI 99-01 CU3 guidance operable" but not In EAL.
lists applicability to Cold Shutdown Recommend Including as in 99-01.
and Refueling only. Basis merely Difference does not appear to be Initiating states that licensee chose to add correct In logic on loss of EDGs as Condition Defueling to mode applicability.
well as offsite power. (Implies that Provide technical justification for UE for 15 min. then higher deviation regarding applicability to classification, which is incorrect.)
Defueled mode, or proposed change to comply with NEI 99-01 guidance.
(ACTION: ANO to modify to comply with NEI 99.01.)
(CU3 / EAL1) NEI 99-01 IC statements and Example EALs for both CU3 and SUM, with the exception of mode applicability, are identical. However, listing of offsite power sources and criteria use for threshold 1.b, "At least (site-specific) emergency generators are supplying EAL 1 power to emergency busses," are inconsistent between licensee CU3 and SUI, EAL 1. Provide justification for inconsistencies between criteria In CU3 and SUI based on common NEI 99-01 guidance, or proposed changes to eliminate Inconsistency.
(ACTION: ANO to eliminate Inconsistency.)
1 of 1
CATEGORY C: SHUTDOWN CONDITIONS CU4 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (CU4 / EALI) Licensee has chosen (CU4 / EALl) Licensee has chosen to Insert "2000"F, in lieu of NEI 99-01 to insert "2000F, in lieu of NEI 99-01 guidance statement of "Technical guidance statement of 'Technical Specification cold shutdown limit."
Specification cold shutdown limit.'
Per guidance established by Per guidance established by licensee, this difference should be licensee, this difference should be EAL 1 listed and justified as equivalent to listed and justified as equivalent to the Technical Specification cold the Technical Specification cold shutdown limit In Attachment 4.
shutdown limit. Please Identify Identify difference, and provide difference, and provide Justification justification as equivalent to the as equivalent to the Technical Technical Specification cold Specification cold shutdown limit per shutdown limit per NEI 99-01 NEI 99-01 guidance.
_uidance.
EAL 2 1 of 1
CATEGORY C: SHUTDOWN CONDITIONS CU5 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (CU5 / EALU) Ucensee states that (CU5 / EALl) Explain why RBS does (CU4) Clarify whether letdown "ANO uses the letdown radiation not provide a consistent method for monitor Is currently disabled, and monitor (if available) as a qualitative detecting this IC, similar to other identify whether other radiation measure of potential fuel clad Entergy plants (such as GG use of monitors would be available to degradation", but does not provide offgas monitor readings resulting in monitor fuel clad degradation based monitor per NEI 99-01, CU5 - EAL 1.
Isolation). Further justification for on Technical Specification allowable Provide the alarm setpoint(s) for the deviating from this EAL Is necessary. limits. In addition, provide letdown radiation monitor In ANO-1 justification for identifying elimination EAL 1 and ANO-2, and describe how the of radiation monitor criterion as a setpoint(s) correlate to Technical difference versus a deviation, since Specification allowable limits. If proposed change eliminates a alarm setpolnt does correspond to specific EAL criterion listed In NEI 99-Technical Specification allowable 01 guidance.
limits, provide further technical justification for deviation from NEI 99-01 guidance. (ACTION: ANO to provide alarmn set point.)
Explain why RBS does not provide a consistent method for detecting this IC, similar to other Entergy plants EAL 2 (such as GG use of offgas monitor readings resulting In Isolation).
Further justification for deviating from this EAL Is necessary.
1 of 1
CATEGORY C: SHUTDOWN CONDITIONS CU6 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (CU6 / Tables C1 & C2) Licensee (CU6 / EALI) Compare wI GG, why (CU5 / EALs1&2) Licensee includes includes portable cellular telephones did GG include mode 3-typo?
cellular telephones under onsite and EAL 1 under onsite and offsite (ACTION: GGNS will break out offsite communications capability.
communications capability. Clarify cold shutdown EALs.)
Clarify whether implementing whether Implementing procedures procedures address the use of address the use of cellular phones as cellular phones as a means of offsite a means of onsite communications communications for consideration and offsite notification for under these EALs, and that cellular consideration under these EALs, and phones will function effectively within that cellular phone will function or In close proximity to plant effectively within or in close proximity structures to be considered a means to plant structures. (ACTION: ANO of onsite and/or offsite clarify.)
communications. (ACTION: W3 clarify.J (CU6 / Table C2) Licensee Includes (CU6 / EAL2) Possible typo: offsite (CU5 / Table C2) Licensee lists civil EAL 2 the Station Radio System under Instead of onsite? (ACTION: RBS defense radios under offsite offsite communications capability.
will resolve.)
communications equipment, but NEI Clarify whether Implementing 99-01 CU6 Basis lists radio procedures address the use of the transmissions as an extraordinary Station Radio System as a means of means of offsite communications.
offsite notification purpose for Clarify whether Implementing consideration under these EALs.
procedures address the use of civil (ACTION: ANO clarify.)
defense radios as a back-up means of offsite communications.
(ACTION: W3procedure Includes civil defense radio. -Plan?)
1 of 1
CATEGORY C: SHUTDOWN CONDITIONS CU7 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition Describe rational for listing of unit-(CU6) Revise DC voltage indication specific busses In SS3 (Modes 1_4),
to reflect nomenclature used to but not in CU7 (Modes 5/ 6). In address voltages less than 108 VDC addition, confirm that nomenclature and to reflect that used In SS4 and EAL 1 for Unit 1 (ANO-1) DC busses is DOI remainder of EALs (i.e., < 108 VDC and D02, versus use of unit vs. "or 108 VDC). (ACTION: W3 designator I DO1 and 2D02.
will provide additional (ACTION: ANO will provide Information.)
additional information.)
I of 1
CATEGORY C: SHUTDOWN CONDITIONS CU8 Arkansas Nuclear One Grand Gulf River Bend Waterford Justify the deviation (not difference) for Including mode 3 In this IC. Note NEI 99001 wording, In that fuel clad degradation Is not considered a Initiating precursor because of the mode 4 or 5 Condition condition, and If in mode 3, different considerations would be present.
(ACTION: GGNS to breakout shutdown EALs.)
(CU7) Clarify use of terms "extended" vs. "sustained" for consistency with EAL thresholds and use of terms in EAL 1 licensee SU10 and CU7 Bases.
(ACTION: W3 to clarify wording.)
Describe in Basis the rational for Unit 1 (ANO-1) and Unit 2 (ANO-2) EAL thresholds established by licensee, and justification for Inclusion of site-EAL 2 specific thresholds for Inadvertent criticality In SU8 (Modes 3/4), but not under CU8 (Modes 5/ 6).
(ACTION: ANO to add additional Information.)
1 of 1
CATEGORY C: SHUTDOWN CONDITIONS CAl Arkansas Nuclear One Grand Gulf River Bend Waterford Provide further technical justification for proposed modification to Mode 6 applicability by adding qualifier "with reactor vessel water level below the Inition reactor vessel flange," which deviates Conditionfrom NEI 99-01 mode definitions, criteria guidance. (ACTION: W3 will revise to match NEI 99-01.)
(CAl / EAL1) Ucensee states that (CAl I EALs1&2) Why is EAL (CAl) Ucensee Basis states that the NEI 99-01 criterion: "Loss of RCS reversed, changes meaning? May be Bottom ID of the RCS loop is 11.8 ft.
Inventory as Indicated by RPV level possible to not get sump reading and MSL, and that level monitoring less than the bottom ID of the RCS by EAL, no call. IF this was systems in Modes 5 and 6 provide loop, was not considered since intentional, then provide justification indication to 12.0 ft. Provide further RVLMS will not monitor level below why deviating from the NEI EAL.
technical justification why the the bottom ID of the RCS loop.
(ACTION: RBS to use NEI 99-01 conservative use of 12.0 ft MSL or However, CAl and CA2 Basis wording.)
Indication off-scale low would not be discussions state that RCS level appropriate, rather than proposed EAL 1 indication may be lost below the deletion of EAL criterion, since level bottom ID of the RCS loop, rather difference between the Bottom ID of than Is not available. If instrument the RCS loop and the lowest design may allow for RPV level Indication Is only 0.2 ft. (ACTION:
indication under certain conditions, W3 to use NEI 99-01 wording.)
then provide specific justification why criterion was not addressed, or proposed changes to comply with NEI 99-01 guidance. (ACTION:
IANO tn nrnvldp pwrnanntlnn )
EAL 2 Ucensee Incorrectly Included discussion regarding refueling mode from CA2 Basis in CAI Basis (3td paragraph), rather than discussion on cold shutdown provided in NEI 99-01 CAl Basis. Ucensee Basis also incorrectly references CA2 and CS2 due to this error, and In 15t paragraph Basis states "a loss of heat removal" versus NEI 99-01 discussion of "a loss of ability to adequately cool the core."
Provide changes to Basis to address cold shutdown guidance In NEI 99-01 CAl Basis, or justification for differences. (ACTION: ANO needs to clarify wording.)
1 of 1
CATEGORY C: SHUTDOWN CONDITIONS CA2 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (CA2 / EALl) Licensee states that Combined with CAl?
Combined with CAl?
NEI 99-01 criterion: "Loss of RCS inventory as indicated by RPV level less than the bottom ID of the RCS loop", was not considered since RVLMS will not monitor level below the bottom ID of the RCS loop.
However, CAI and CA2 Basis discussions state that RCS level EAL 1 indication may be lost below the bottom ID of the RCS loop, rather than Is not available. If Instrument design may allow for RPV level indication under certain conditions, then provide specific justification why criterion was not addressed, or proposed changes to comply with NEI 99-01 guidance. (ACTION:
IANO to provide eprnlanation.)
EAL 2 1 of 1
CATEGORY C: SHUTDOWN CONDITIONS CA3 Arkansas Nuclear One Grand Gulf River Bend Waterford ICs for NEI 99-01 for CA3 and SS1 states, "Loss of All Offsite Power and Loss of All Onsite Power to Essential Busses." Licensee defines uessential busses" as "required 4.16 K(V busses" under CA3 IC and 'vital 4.16 busses' under SS1 IC. Licensee also uses term 'emergency busses in CA1 EAL criterion, which is consistent with NEI 99-01 guidance, but uses the term "vital busses" in SS1 EAL criterion. In addition, NEI 99-01 example EAL criterion for CA3 and SS1 are Identical, with the Initiating exception of mode applicability, but Condition licensee criteria under CA3 and SS1 are not consistent. Licensee criterion under SS1 would not allow credit for the restoration of offsite power to an essential bus, but only from an emergency diesel generator. Provide justification for deviation In term definition and interpretation of EAL criterion between licensee CA3 and SS1, and the apparent failure to address a restoration of offsite power to an essential bus within 15 minutes under SS1. (ACTION: ANO needs to clarify wording.)
(CA3 / EAL1) RBS EAL Is not including status of EDGs, which Is critical to this EAL Use of
'unplanned" implies that if EAL 1 intentionally performed then EAL is not applicable. This Is a deviation. If that Is your intend, then provide detailed justification for this deviation.
(ACTION: RBS to provide additional Information.)
1 of 2
CATEGORY C: SHUTDOWN CONDITIONS CA3 Arkansas Nuclear One Grand Gulf River Bend Waterford (CA2) Licensee Basis takes credit for temporary emergency diesels that may be used to supplement onsite AC power in the event emergency diesels are lost. Provide technical justification for deviation from NEI 99-01 CA3 / EAL 1.b criterion, which requires licensee to list site-specific emergency diesel generators that are part of plant design and safety analysis, or provide change to comply with NEI 99-01 guidance. In addition, clarify specific reference to where credit is taken for temporary diesel generators in safety analysis report accident analyses or station blackout coping analysis. (ACTION: W3 to Basis provide additional Information.)
(CA2) LUcensee in Basis discussion substitutes the term "available" in lieu of NEI 99-01 temm 'operable", which is defined per technical specifications. Use of the term
'available" Is also Inconsistent with licensee SS1 Basis, which uses term
'operablew. Provide further technical justification for deviation from NEI 99-01 guidance and define "available' In relation to technical specifications under Basis definitions, or provide changes to comply with NEI 99-01 guidance. (ACTION: W3 to clarify wording.)
2 of 2
CATEGORY C: SHUTDOWN CONDITIONS CA4 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (CA4 / EALsl, 2 & 3) Licensee has (CA4 / EALs 1, 2 &3) Compare w/
(CA4 / EALs1, 2 & 3) Ucensee has chosen to Insert "2000 F, In lieu of GG, RBS format may be better.
chosen to Insert "2000F, in lieu of EAL 1 NEI 99-01 guidance statement of (ACT7ON: GGNS/RBS standardize NEI 99-01 guidance statement of "Technical Specification cold wording and format.)
'Technical Specification cold shutdown limit." Per guidance shutdown limit." Per guidance established by licensee, this CA4 / EAL2) Provide better established by licensee, this difference should be listed and justification why no reference to RCS difference should be listed and justified as equivalent to the reduced inventory. It was included justified as equivalent to the EAL 2 Technical Specification cold for River Bend (BWR). (ACTION:
Technical Specification cold shutdown limit in Attachment 4.
GGNS/RBS standardize wording shutdown limit. Please Identify Identify difference, and provide and formaL) difference, and provide justification justification as equivalent to the as equivalent to the Technical Technical Specification cold Specification cold shutdown limit per shutdown limit per NEI 99-01 NEI 99-01, guidance.
guidance.
(CA3 / EAL3) Provide justification that the 20 psig is the lowest RCS pressure that can be read on installed Control Room Instrumentation (that is equal to or greater than 10 psig) per EAL 3 guidance In NEI 99-01 Basis for EAL
- 3. In addition, provide justification in NEI EAL Differences Document for including qualifier, "...due to reactor vessel Inventory temperature increase", in EAL 3 criterion.
(ACTION: W3 to evaluate set point.)
1 of 1
CATEGORY C: SHUTDOWN CONDITIONS CS1 Arkansas Nuclear One Grand Gulf River Bend Waterford Provide further technical Justification for proposed modification to Mode 6 applicability by adding qualifier "with Initiating reactor vessel water level below the Condition reactor vessel flange," which deviates from NEI 99-01 mode definitions, criteria guidance. (ACTION: W3 will revise to match NEI 99-01.)
(CS1 / EALl) Ucensee states that (CSi / EALU) 1 c does not appear to Licensee does not address NEI 99-NEI 99-01 criterion: 'Loss of RCS be correct w/ CTMT not Established. 01 criterion associated with RPV inventory as indicated by RPV level (direct to environ.) This appears to level corresponding to the TOAF.
less than the bottom ID of the RCS be consistent with GG1. Review this This Is Inconsistent with FCB3, loop", was not considered since EAL, and correct to be consistent Potential Loss of the Fuel Clad RVLMS will not monitor level below with NEI EAL guidance.
Barrier, and licensee SG12 which the bottom ID of the RCS loop.
defines TOAF as "RVLMS upper However, CA1 and CA2 Basis plenum level < 20%." Provide further discussions state that RCS level technical justification for the deletion EAL 1 indication may be lost below the of TOAF criterion, based on use of bottom ID of the RCS loop, rather criterion in FCB3, or provide changes than is not available. If Instrument in CS1 and CG1 to comply with NEI design may allow for RPV level 99-01 guidance. (ACTION: W3 Indication under certain conditions, make numbering agree.)
then provide specific justification why criterion was not addressed, or proposed changes to comply with NEI 99-01 guidance. (ACTION:
_I ANO tn nrnuvlp nrnlnnntlion-)
I 1 of 2
CATEGORY C: SHUTDOWN CONDITIONS CS1 Arkansas Nuclear One Grand Gulf River Bend Waterford (CS1 I EAL2) Licensee does not Per NEI guidance, with address NEI 99-01 criterion: '(RPV CONTAINMENT CLOSURE inventory as Indicated by) RPV level established, the inability to monitor less than TOAF [top of active fuel'",
RPV level for > 30 minutes with based on justification that RVLMS will EITHER an unexplained sump and not monitor level below the bottom of tank level Increases OR erratic ID of the RCS loop. Provide further source range monitor Indication technical justification, based on both would require classification.
ANO-1 and ANO-2 Instrumentation Describe how in Mode 5 (cold capabilities, for omission of NEI 99-shutdown) with CONTAINMENT EAL 2 01 criterion consistent with response CLOSURE established, NEI 99-01 to Specific Comment #20. If CS1 / EAL 2.b criterion for erratic Instrument design may allow for RPV source range monitor Indication with level Indication at TOAF under the Inability to monitor RPV level for certain conditions, then provide
> 30 minutes, Is met. (ACTION: W3 specific Justification why criterion was will split out EALs.)
not addressed, or proposed changes to comply with NEI 99-01 guidance.
(ACTION: ANO to clarify wording.)
2of2
CATEGORY C: SHUTDOWN CONDITIONS I of 3 CS2 Arkansas Nuclear One Grand Gulf River Bend Waterford InitIating Combined with CS1?
Condition (CS2 / EAL1) LIcensee states that NEI 99-01 criterion: GLoss of RCS Inventory as Indicated by RPV level less than the bottom ID of the RCS loop, was not considered since RVLMS will not monitor level below the bottom ID of the RCS loop.
However, CA1 and CA2 Basis discussions state that RCS level Indication may be lost below the bottom ID of the RCS loop, rather than is not available. If Instrument design may allow for RPV level indication under certain conditions, then provide specific justification why criterion was not addressed, or proposed changes to comply with NEI 99-01 guidance. (ACTION:
ANO to provide explanation.)
(CS1) Ucensee provides a valid high alarm on the Containment High Range Radiation Monitor, rather than exceeding a site-specific setpoint as established under NEI 99-01 guidance. Licensees lustification for this deviation is that this value was not calculated due to the range of unknowns Involved, including time after shutdown and reactor vessel head Installation status and Installation of external structures.
However, NEI 99-01 In Basis guidance states that calculations should be performed to conservatively estimate a dose rate indicative of core uncovery (i.e., level at TOAF), and In specifically required monitor reading for both CONTAINMENT CLOSURE established and not established to account for reactor vessel head installation status and Installation of external structures. Provide site-specific setpoints for Containment High Range Radiation Monitor readings within Indicate core uncovery based on NEI 99-01 guidance for CONTAINMENT CLOSURE established and not established. (ACTION: W3 Drovide EAL 1 4
+
4 (CS3) Provide justification for the designation 'Core Exit Thermocouple
> 7000F as a site-specific indication of core uncovery. (ACTION: W3 will provide additlonaljustiflcatlon.)
CATEGORY C: SHUTDOWN CONDITIONS CS2 Arkansas Nuclear One Grand Gulf River Bend Waterford (CS2 / EAL2) NEI 99-01 guidance Additional Justification for RVP levels establishes "Containment High and their representations, to compare Range Radiation Monitor reading >
with NEI 99001 levels. No EAL for
[site-specific] setpoint7 as a criterion sump/tank levels or for source range as evidence that RPV level cannot be monitor increases. Justify deviation monitored with Indication of core for not including In EAL. (ACT7ON:
uncovery. Ucensee does not GGNS will provide additional consider this criterion because ANO's justification and will coordinate monitors have not been analyzed for response with RBS.)
this setpolnt. However, the Intent of this "site-specific" criterion is for the licensee to perform calculation which should be performed at TOAF for both Containment Closure established and not established EALs 1 & configurations. In addition, criterion
'RPV level cannot be monitored with indication of core uncovery" is not reflected in licensee criteria. Provide site-specific Containment High Range Radiation Monitor setpoints (readings) or further Justification why setpoint (reading) cannot be calculated per NEI 99-01 guidance.
Also, address NEI 99-01 statement "RPV level cannot be monitored with Indication of core uncovery, or provide further justification why statement was not considered.
(ACTION: ANO to perform calculation.)
2 of 3
CATEGORY C: SHUTDOWN CONDITIONS 3 of 3 CS2 I
Arkansas Nuclear One l
Grand Gulf River Bend Waterford (CS2 / EAL2) Ucensee does not address NEI 99-01 criterion: "(RPV inventory as indicated by) RPV level less than TOAF [top of active fuel]',
based on justification that RVLMS will not monitor level below the bottom of ID of the RCS loop. Provide further technical justification, based on both ANO-1 and ANO-2 instrumentation capabilities, for omission of NEI 99-01 criterion consistent with response to Specific Comment #20. If instrument design may allow for RPV level indication at TOAF under certain conditions, then provide specific Justification why criterion was not addressed, or proposed changes to comply with NEI 99-01 guidance.
(ACTION: ANO to clarify wording.)
Is 'not established' a typo In SS4 EAL #2, as NEI 99001 CS2, EAL #2 is "established".
Licensee does not address NEI 99-01 criterion associated with RPV level corresponding to the TOAF.
This is Inconsistent with FCB3, Potential Loss of the Fuel Clad Barrier, and licensee SG12 which defines TOAF as 'RVLMS upper plenum level < 20%." Provide further technical Justification for the deletion of TOAF criterion, based on use of criterion in FCB3, or provide changes in CS1 and CG1 to comply with NEI 99-01 guidance. (ACTION: W3 make numbering agree.)
EAL 2
- 4.
4 4
Licensee EAL 1.a criteria is not consistent with NEI 99-01 guidance, but rather duplicates that In Example EALs 2.b (with the exception of SRM and CTE indication). In addition, the criterion oReactor vessel level cannot be monitored for greater than 30 minutes", was inserted under licensee CS2 - EAL 1.b and 2.b; however, this criterion is not provided under NEI 99-01 CS2 example EALs or basis, nor are deviations adequately Justified by licensee.
Provide further technical justification for deviations, or proposed change to comply with NEI 99-01 guidance.
(ACTION: ANO will perform additional research.)
CATEGORY C: SHUTDOWN CONDITIONS I of 3 CG1 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition. _..
E A L 1I (CG1 / EAL2) Licensee does not address NEI 99-01 criterion: "(RPV Inventory as Indicated by) RPV level less than TOAF [top of active fuelr, based on Justification that RVLMS will not monitor level below the bottom of ID of the RCS loop. Provide further technical justification, based on both ANO-1 and ANO-2 instrumentation capabilities, for omission of NEI 99-01 criterion consistent with response to Specific Comment #20. If instrument design may allow for RPV level indication at TOAF under certain conditions, then provide specific Justification why criterion was not addressed, or proposed changes to comply with NEI 99-01 guidance.
(ACTION: ANO to clarify wording.)
Uicensee does not address NEI 99-01 criterion associated with RPV level corresponding to the TOAF.
This is inconsistent with FCB3, Potential Loss of the Fuel Clad Barrier, and licensee SG12 which defines TOAF as 'RVLMS upper plenum level < 20%." Provide further technical justification for the deletion of TOAF criterion, based on use of criterion in FCB3, or provide changes in CS1 and CG1 to comply with NEI 99-01 guidance. (ACTION: W3 make numbering agree.)
CATEGORY C: SHUTDOWN CONDITIONS 2of 3 EAL 2 (CG1 / EAL2) NEI 99-01 guidance establishes 'Containment High Range Radiation Monitor reading >
(site-specific] setpoinr as a criterion as evidence that RPV level cannot be monitored with Indication of core uncovery. Licensee does not consider this criterion because ANO's monitors have not been analyzed for this setpoint. However, the intent of this "site-specific" criterion is for the licensee to perform calculation which should be performed at TOAF for both Containment Closure established and not established configurations. In addition, criterion
'RPV level cannot be monitored with Indication of core uncovery' Is not reflected in licensee criteria. Provide site-specific Containment High Range Radiation Monitor setpoints (readings) or further justification why setpolnt (reading) cannot be calculated per NEI 99-01 guidance.
Also, address NEI 99-01 statement
'RPV level cannot be monitored with indication of core uncovery", or provide further justification why statement was not considered.
(ACTION: ANO to perform calculation.)
Provide site-specific setpoint for Containment High Range Radiation Monitor reading within Indicate core uncovery based on NEI 99-01 guidance for CONTAINMENT CLOSURE established. (AC770N:
W3 will add number and provide calculation.)
J.
.L J
CATEGORY C: SHUTDOWN CONDITIONS 3 of 3 CATEGORY C: SHUTDOWN CONDITIONS 3 of 3 EAL 3 (CNB1/2nd Potential Loss) NEI 99-01 guidance establishes criterion,
'Explosive mixture exists", which per the NEI 99-01 Basis means a hydrogen and oxygen concentration of at least the lower deflagration limit curve exists. The licensee's criterion only states 'Containment Hydrogen Concentration greater than 40/%", and does not address oxygen component.
Provide hydrogen and oxygen concentrations reflective of the lower deflagration limit for ANO1 and ANO 2 containment structures, or provide further Justification why oxygen concentration is not applicable to AN01 and 2. In addition, revise criteria Identified for an "explosive mixture Inside containment under CG1 - EAL 3 to ensure consistency with threshold in CNB1. (ACT1ON:
ANO to provide additional discussion on 4% concentration.)
Clarify whether safety analysis report or other site-specific accident analyses Identify a site-specific explosive mixture that would represent a challenge to containment, equivalent to at least the lower deflagration limit. If not, discuss why explosive mixture, equivalent to at least the lower deflagration limit, could not be determined based on Industry and owners group guidance.
In addition, discuss basis for Containment hydrogen threshold under Basis for CNB1.
£ I
A.
I
CATEGORY H: HAZARDS HU Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition EAL i (HU6 / EAL2) Please provide specific (HU3 / EAL2) Wind speed limits are references to safety analysis report not Included in the EAL (as in NEI (SAR) for Units 1 and 2 high winds 99001, HUI #2). Justify the design basis under Reference deviation from listing wind speeds In Document listing in Attachment 3 the EAL. (This Is Incorrectly listed as (Basis). (ACTION: ANO to provide a difference.) In the HUI additional Infornation.)
Deviation/Difference document, the justification Is that hurricane force winds have never been recorded.
Severe winds from very strong EAL 2 storms can occur (greater than minimal hurricane force) as can hurricanes. (There is ample evidence of hurricanes existing for several hundred miles Inland.)
Typically, wind loading analysis Is included In FSARs. Recommend providing wind limit to EAL or providing detailed justification for this deviation. (AC77ON: GGNS will coordinate response with RBS.)
(HU4 / EAL3) Additional clarification should be provided to ensure that the EAL 3 operator understands that actual resulting damage Is not a prior basis for classification. (ACTION: NOUE vs. Alert.)
CATEGORY H: HAZARDS HU1 Arkansas Nuclear One Grand Gulf River Bend Waterford Provide site-specific listing, as (HU3) More justification is necessary (HU6 / EAL6) Clarify Inconsistency specified by NEI 99-01 guidance, of to justify omission of this EAL.
between HU6 / EAL 6 and HA6 / EAL areas of the plant where uncontrolled Considerations for more than river 5,regarding site-specific areas flooding has the potential to affect flooding should be discussed, such containing systems required for the safety-related equipment. (ACTION: as storm drain overflow, water main safe shutdown of the plant, that are ANO to provide plant specific list.) piping flooding, etc. This Is not designed to be wetted or Incorrectly listed as a difference, submerged, that would be Impacted EAL 6 instead of a deviation. Consider by internal flooding per NEI 99-01 adding EAL to scheme, or provide guidance (e.g., HU6 states -35 detailed justification for this deviation.
elevation areas vs. HA6 which states (ACTION: GGNS to evaluate Reactor Auxiliary Building). In flooding.)
addition, identify the basis used for determining these areas (i.e., IPEEE, etc.). (ACTION: W3 to clarify and make EAL more specific.)
(HU6 I EALs7&8) Describe technical basis for low and high lake water level and provide reference to basis under Reference Documents In (Basis). (ACTION:
ANO to provide reference.)
Describe whether the ANO site is EAL 7 subject to other site-specific phenomena, such as hurricanes, or subject to severe weather as defined in the NUMARC station blackout initiative (i.e., activation of severe weather mitigation procedures) per guidance In NEI 99-01 Basis. If applicable, include site-specific EALs.
2of2
CATEGORY H: HAZARDS HU2 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (HU4) IC Is different in GG HU4, (protected area boundary versus power block). Further, in the basis, NEI 99001 describes a more detailed generalization of areas In actual contact or immediately adjacent to EAL 1 plant vital areas, which are referenced but not defined In GG EALs. Justify the deviation from the IC and describe the areas In the plant that you Intend to apply to this EAL.
(ACTION: GGNS to add list of
_ buildings.)
1 of 1
CATEGORY H: HAZARDS HU3 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (HU5 / EALl) NEI 99-01 qualifier
"...enter the site boundary area..."
was replaced with "...enter normally occupied areas of the site". This interpretation is not consistent with NEI 99-01 guidance, which considers the Impact of any toxic or flammable gases that has or could enter the site EAL 1 area boundary, and not Just occupied areas, on normal plant operations (as defined in Section 5.4 to NEI 99-01).
Identify change as a deviation or difference and provide Justification for further consideration, or provide proposed change to comply with NEI 99-01 guidance. (ACTION: What Is the site boundary?)
(HU5) EAL #2 is missing from the GG EALs. Justify your deviation from NEI 99001 by omitting EAL #2. In the Deviation/Difference document, NEI 99001 HU3 Is omitted, with a difference listed that no industries are in the Grand Gulf area affecting EAL 2 evacuation or sheltering. This fails to consider river barges, tanker accidents (rail or roadway) or other possible toxic gas, smoke, etc.
scenarios. Recommend adding EAL or providing detailed Justification for the deviation to not include this EAL.
1 of 1
CATEGORY H: HAZARDS HU4 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition EAL 1 (HU1 / EAL2) Ucensee deleted the (HU5 i EAL2) Explain additional term "site-specific" from EAL wording wording in EAL, 'expected to enter and chose not to include the NEI normally occupied areas". This Basis discussion, which states 'Only appears to deviate from intent of the plant to which the specific threat EAL. If notified of evacuation, then it Is made need declare the Notification is expected that the site would of an Unusual Event". Describe how perform some protective action, such EAL 2 would allow for the as evacuating. The entry on toxic differentiation between a general (i.e.,
gas Into normally occupied areas is EAL 2 threat against company facilities /
not intended to be part of the criteria property) versus directed at station, to declare per this EAL. (ACTION:
since "site-specific criteria was What are normally occupies deleted from EAL wording and basis.
areas?)
In addition, Identify changes as deviations or differences and provide justification for further consideration, or provide proposed change to comply with NEI 99-01 guidance.
(ACTION: ANO to add additional wordinoa I1I 1 of 1
CATEGORY H: HAZARDS HU5 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (JU1 / EALU) This EAL Is a judgment EAL for a general emergency.
EAL I Modify to meet NEI EALs. (ACTION:
RBS to modify numbering.)
1 of 1
CATEGORY H: HAZARDS 1 of 2 HA1 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (HA6 / EALI) Provide description in EAL 1 Basis that supports the selection of 0.1 g as indicative of an Operating Basis Earthquake (OBE),
EAL 1 and reference to site-specific technical basis (i.e., SAR, etc.) under Reference Documents in Attachment
- 3. (ACTION: ANO to add reference.)
(HA6 / EAL2) Licensee does not (HA$ I EAL2) Wind speed limits are include the Turbine Building", since it missing from the GG EAL, #2.
does not contain a vital area. Clarify Deviation/Difference document whether damage to equipment in the discusses highest recorded wind turbine building due to high winds speed as 69 mph, but does not could cause, either directly or review FSAR wind loading analysis or indirectly, damage to safety functions a comparison of historical events in EAL 2 and systems required for the safe the southeast to determine if there shutdown of the plant per NEI 99-01, are other examples of hurricane force HA1 Basis. If so, provide proposed winds extending several hundred change to comply with NEI 99-01 miles inland. Reexamine UFSAR to guidance to include the Turbine ensure that wind loading is not Building in Table H-2.
included (not just hurricane).
(ACTION: GGNS to modify wording.)
(HA6 / EAL3) Licensee Basis contains statement, ulf the crash is confirmed to affect a plant vital area, escalation to ALERT is appropriate";
however, this statement is applicable EAL 3 to licensee HU6 Basis rather than HA6 Basis per NEI 99-01 guidance.
Provide justification for including statement In HAG Basis. (ACTION:
ANO will provide additional
_ustification.)
CATEGORY H: HAZARDS 2of 2 HA1 Arkansas Nuclear One Grand Gulf River Bend Waterford (HA6 / EAL4) License references (HA3) Specific areas are not listed.
Table H-2 areas rather than Explain deviation why those areas developing a site-specific listings of are not listed and or provide list.
areas, containing safety functions (ACTION: RBS will add EAL, and and systems required for the safe GGNS and RBS to work together shutdown of the plant, that could for common approach.)
SAL 4 realistically be Impacted by turbine failure-generated missiles. Provide justification for referencing Table H-2, rather that developing site-specific areas based on NEI 99-01 guidance.
(HA6) Provide justification for the (HA4) Provide justification for the (HA3) Specific areas are not listed.
(HA6 / EAL5) Clarify inconsistency failure to identify site-specific areas, deviations from 99-01. Correct In Explain deviation why those areas between HU6 / EAL 6 and HA6 / EAL per NEI 99-01 guidance, which Deviation/Differences document to are not listed and or provide list.
5,regarding site-specific areas include areas that contain systems record as a deviation, with detailed (ACTION: RBS will add EAL, and containing systems required for the required for safe shutdown of the justification why appropriate to GGNS and RBS to work together safe shutdown of the plant, that are plant, that are not designed to be eliminate. In justification, include for common approach.)
not designed to be wetted or wetted or submerged. (ACTION:
analysis of other than "river flooding",
submerged, that would be impacted SAL 5 ANO will provide list.)
as discussed previously. (ACTION:
by Intemal flooding per NEI 99-01 GGNS to address flooding.)
guidance (e.g., HU6 states -35 elevation areas vs. HAG which states Reactor Auxiliary Building). In addition, identify the basis used for determining these areas (i.e., IPEEE, etc.). (ACTION: W3 to clarify and make EAL more specific.)
(HA6) Provide reference to technical (HA4) Provide justification for the basis (i.e., SAR, etc.) for ALERT deviations from 99-01. Correct in classification based on low lake level, Deviation/Differences document to and Include reference to technical record as a deviation, with detailed SAL 6 basis(es) under Reference justification why appropriate to Documents In Attachment 3.
eliminate.
(ACTION: ANO will add additional Information.)
CATEGORY H: HAZARDS HA2 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (HA4 / EAL1) Licensee Basis does (HA4 / EAL4) Uses vital area Instead (HA4) Identify the basis used for not include 1 st paragraph from NEI 99 of specific areas containing functions determining site-specific areas 01 guidance providing basis for and systems necessary for safe containing functions and systems selection of site-specific areas.
shutdown (though may be the same).
required for the safe shutdown of the Describe basis for the selection of (ACTION: GGNS to modify plant (i.e., site-specific safe shutdown Table H1 areas based on NEI 99-01 wording.)
analysis, etc.). (ACTION: W3 will guidance (i.e., safe shutdown provide additional Information.)
EAL 1 analysis, etc.). (ACTION: ANO to add additional Information.)
(HA4 / EAL4) References 'causing damage' as opposed to 'affecting operability of' as In NEI 99-01, HA2.
Change to match 99001 EAL or provide detailed justification for this deviation. (ACTION: GGNS to modify wording.)
1 of 1
CATEGORY H: HAZARDS 1 of 1 HA3 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (HA5 / EALl) Licensee inserted the following qualifier in Basis: "Areas that require only temporary access that can be supported by the use of respiratory protection should not be considered as exceeding this threshold. However, this qualifier is not addressed under NEI 99-01 EAL 1 guidance. In addition, licensee fails to identify the addition of this qualifying Basis statement under Deviations in Attachment 4. Identify change as a deviation or difference, as appropriate, and provide justification, or provide proposed change to comply with NEI 99-01 guidance. (ACTION: ANO will nrmi,,PId OrlrPInnal In1^rrnftI n I J.
J.
CATEGORY H: HAZARDS HA4 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition EAL 1 EAL 2 1 of 1
CATEGORY H: HAZARDS 1 of 1 HA5 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (HA3) Provide justification for use of (HA3) Provide site-specific qualifier, 'in progress", rather than procedure or equivalent objective "has been initiated" as stated in IC, or measure, which upon entering provide proposed change to comply procedure, initiating specific with IC statement. In addition, clarify procedural step or action, or that a site-specific procedure does reaching criteria, would reflect not exist governing control room requirement for control room EAL 1 evacuation.
evacuation. Entry into this procedure or meeting a designated procedural step or criteria is used under licensee HS3 to determine whether control of plant was established outside the control room within 15 minutes. (ACTION: W3 to provide procedure reference.)
CATEGORY H: HAZARDS 1 of 1 HA6 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (JA1 / EALl) This EAL is a judgment EAL for a general emergency.
EAL 1 Modify to meet NEI EALs. (ACTION:
RBS to modify numbering.)
CATEGORY H: HAZARDS HSI Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition EAL1 (HS1) NEI 99-01 HS1, EAL #2 is missing from GG EALs. GG EAL considers only an armed attack against the plant, versus the other considerations In 99-01 (insider destruction of equipment, sabotage, hostage/extortion). Justify the EAL 2 deviation from the 99-01 other considerations. Justify the ommision of EAL #2 from GG EALs. This is noted as a "difference", and appears to be a deviation. Provide more detailed justification why It is appropriate to omit this EAL.
(ACTION: GGNS to modify
_lustification.)
I 1 of 1
CATEGORY H: HAZARDS HS2 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (HS3) Provide justification, based on (HS3) Provide site-specific procedure site-specific analysis or assessments or equivalent objective measure, per NEI 99-01 guidance, as to how which upon entering procedure, quickly control must be re-Initiating specific procedural step or established to ensure that core action, or reaching criteria, would uncovering and/or core damage will reflect requirement for control room not occur with the 15 minute time evacuation. (ACTION: W3 to threshold established. In addition, provide procedure reference.)
EAL 1 please Identify as deviation or difference, as appropriate, and provide justification regarding the failure to Include site-specific procedure reference for the transfer of plant control during a control room evacuation. (ACTION: ANO will provide aditional Information.)
(HS3) Please provide justification, based on site-specific analysis or assessments per NEI 99-01 guidance,-as to how quickly control must be re-established to ensure that core uncovering and/or core damage will not occur with the 15 minute time threshold established. (ACTION:
W3 will provide additional Innformation.)
1 of 1
CATEGORY H: HAZARDS 1 of 1 HS3 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition (JS1 / EALl) This EAL is a judgment EAL for a general emergency.
EAL 1 Modify to meet NEI EALs. (ACTION:
RBS to modify numbering.)
CATEGORY H: HAZARDS 1 of 1 HG1 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition EAL 1 Loss of Spent Fuel Pool of control is not addressed in the EALs, as discussed in NEI 99001 EAL basis.
Basis Justify the deviation from referencing SFP conditions in the EAL.
(ACTION: GGNS to address In basis document.)
CATEGORY H: HAZARDS 1 of 1 HG2 Arkansas Nuclear One Grand Gulf River Bend Waterford Initiating Condition Identify as a deviation or difference, as appropriate, and provide justification for change in EAL wording referring to exceeding EPA Protective Action Guideline exposure EAL 1 levels "beyond the exclusion area",
rather than NEI 99-01 guidance, and that defined for a General Emergency by licensee under Section 4.10.4, of
.offsite for more than immediate site area'.
CATEGORY E: ISFSI 1 of 1 E-HU1 Arkansas Nuclear One Grand Gulf River Bend Waterford E-HU2 Mode applicability is considered "not applicable" per NEI 99-01 guidance, since classification based on a ISFSI / dry storage-related event is not tied to plant operating mode. Licensee chose to list all operating modes, including Defueling. Provide justification for deviation from NEI 99-01 guidance. (ACTION: ANO to explain methodology.)
EAL 1 Thresholds for natural phenomena and accident conditions established by the licensee appear to provide insufficient detail. EAL user Is required to use Basis to determine magnitude or consequence of event for classification purposes (e.g., high winds resulting In a loss of shielding due to missile impact, tornado resulting in a long-term loss of heat transfer due to blockage of air Inlets, case drop greater than X ft., etc. In addition, EALs do not address a tipped-over cask or a seismic event as listed in NEI 99-01 E-HU1 Basis and licensee Basis.
Provide specific thresholds for Identified natural phenomena and accident conditions listed, based on description In licensee Basis. In addition, provide a listing of natural phenomena and accident conditions considered in the results of the ISFSI Safety Analysis Report (SAR) per NUREG-1536 or SAR referenced in the cask's Certification of Compliance and related EAL 2 NRC Safety Evaluation Report. (ACTION: ANO to provide more detail.)