ML050450592
| ML050450592 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 05/06/2004 |
| From: | Michael Webb NRC/NRR/DLPM/LPD4 |
| To: | Entergy Nuclear Operations |
| Webb M, NRR/DLPM, 415-1347 | |
| Shared Package | |
| ML050610499 | List: |
| References | |
| Download: ML050450592 (7) | |
Text
lMichael Webb - Questions re: River Bend Station EAL Submittal Page 1 From: Michael Webb To: LENGLAN@entergy.com---
Date: 5/6/04 2:31 PM
Subject:
Questions re: River Bend Stato EAL Submittal Les, The attachment is a list of preliminary questions related to the Entergy license amendment request dated December 19, 2003 for River Bend Station.
Our intention is to discuss the questions in a future NRC/Entergy telephone conference call related to the proposed EAL revisions Entergy has submitted for each of the Entergy South plants.
These questions and the insights gained from the call would be the basis for a future Request for Additional Information in response to the license amendment request.
Mike Webb NRC River Bend Station Project Manager 301-415-1347 CC: BYRD, RONALD W
[C:\W1IND0WS\TEMP\GW)00001 .TMP Page 1 l IC:\WINDOWS\TEMP\GW}OOO01 .TMP Page 1 1 Mail Envelope Properties (409A849E.A49: 5: 21368)
Subject:
Questions re: River Bend Station EAL Submittal Creation Date: 5/6/04 2:31PM From: Michael Webb Created By: MKW@nrc.gov Recipients Action Date & Time entergy.com Transferred 05/06/04 02:32PM LENGLAN (LENGLAN@entergy.com)
RBYRD CC (BYRD, RONALD W) nrc.gov owf4_po.OWFNDO Delivered 05/06/04 02:3 1PM MKW BC (Michael Webb) Opened 05/06/04 02:45PM Post Office Delivered Route entergy.com owf4_po.OWFNDO 05/06/04 02:31PM nrc.gov Files Size Date & Time River Bend EALs_.doc 49664 05/06/04 02:16PM MESSAGE 1458 05/06/04 02:3 1PM Options Auto Delete: No Expiration Date: None Notify Recipients: Yes Priority: Standard Reply Requested: No Return Notification: None Concealed
Subject:
No Security: Standard To Be Delivered: Immediate Status Tracking: Delivered & Opened
River Bend EAL-related questions for possible telephone discussion By letter dated December 19, 2003, Entergy's River Bend Station (RBS) requested NRC review and prior approval to proposed revisions of Grand Gulf's emergency action levels (EALs) using NRI 99-01, Revision 4 methodology.
NRR staff review determined that the proposed revision package was acceptable for evaluation. Based on a detailed review of the proposed changes, and in comparison to the NRC endorsed guidance in NEI 99-01 and RG 1.1 01, Revision 4, the NRR staff developed a list of preliminary questions in advance of a formal Request for Additional Information (RAI). NRR staff has the following comments and questions related to this submittal:
General Comments:
- 1) Specific definitions for "difference" and "deviation" do not appear to be consistently applied. Numerous examples, identified below, indicate that areas labeled "differences" appear to be "deviations". 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 99-01. 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. This was discussed with Entergy and other EAL change packages (for other Entergy plants) and one Entergy submittal contained definitions for "difference" and "deviation". It is recommended that "differences" and "deviations" be specifically defined within the change package (as was done for the ANO EAL submittal) and followed per the definition.
Specific Comments:
- 1) AU1 #1 99-01 EAL #1 applies to any effluent monitor. RBS applied #1 only to liquid releases (effluent monitors addressed in #2). Application for contamination in line causing monitor to continue to read high is acceptable. By applying to liquid only, does this disturb the logic for other EALs (see #2)? Explain why credit not applied for samples which correct monitor readings (as in #2 basis)?
- 2) AU1 #2 99-01 EAL #2 applies to radiation monitors, effluent monitors were addressed in #1. Why did you separate liquid from effluent (#1 and #2) monitors? Are there conditions where gaseous effluent Monitors can continue to read following term of releases as in #1? Explain why rad monitors are not included in EALs and why this deviation was not identified.
- 3) AU1 #3 Explain why wording differs from 99-01.
- 5) AU2 #1 This EAL specifically applies to areas around spent fuel. The value of (1000) is not intended to apply here and could result in very high radiation areas. Explain this deviation.
- 6) AU2 #2 This EAL is acceptable except for the omission of "unplanned", but the IC is changed, and is a deviation from 99-01. Explain the omission of this deviation, and why this is not identified. Explain use of valid versus unplanned.
- 7) M1 #1 and #2 Same issue as in AU1. #1 addresses liquid only, #2 effluent and not radiation Monitors.
- 8) AA1 #3 Explain difference between use of confirmed versus unplanned. Explain difference in wording, in general.
- 9) AA3 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.
10)AA2 Describe Max safe ops values in more detail. Does this apply to equip. or personnel?
11)AS1 #2 Explain deviation for using dose/hr values versus the 99-01 total dose criteria.
12)AG1 #2 Explain use of dose/hr values for field team readings, which may be higher than total dose values.
13)CU1#1 In deviation justification, explain relevance on 9.7 in. in relation to vessel level.
14)CU2 #2 Why reverse order of EALs?
15)CU3 #1 Explain why condition of EDGs is not included. Discussion says "implied that EDGs are operable" but not in EAL. Recommend including as in 99-
- 01. Difference does not appear to be correct in logic on loss of EDGs as well as offsite power. (Implies that UE for 15 min. then higher classification, which is incorrect.)
16)CU5 #1 Explain why RBS does not provide a consistent method for detecting this IC, similar to other Entergy plants (such as GG use of offgas monitor readings resulting in isolation). Further justification for deviating from this EAL is necessary.
17)CU5 #2 Explain why RBS does not provide a consistent method for detecting this IC, similar to other Entergy plants (such as GG use of offgas monitor readings resulting in isolation). Further justification for deviating from this EAL is necessary.
18)CU7 #2 Possible typo: offsite instead of onsite?
19)CU6 #1
20)CA1 #1 and #2 Why is EAL reversed, changes meaning? May be possible to not get sump reading and by EAL, no call. IF this was intentional, then provide justification why deviating from the NEI EAL.
21)CA3 #1 RBS EAL is not including status of EDGs, which is critical to this EAL.
Use of "unplanned" implies that if intentionally performed then EAL is not applicable. This is a deviation. If that is your intend, then provide detailed justification for this deviation.
22)CA4 #1,2,3 Compare w/ GG, RBS format may be better.
- 23) CS1 #1 1c. does not appear to be correct w/ CTMT not Estab. (direct to environ.)
This appears to be consistent with GG1. Review this EAL, and correct to be consistent with NEI EAL guidance.
24)FC Barrier #1
Explain use of 300 ucVgm, versus the use of 4 ucVgm for this EAL at other Entergy BWRs. In justification, provide evidence that the 300 ucVgm activity would correspond to less than 5% fuel failure, as referenced in NEI 99-01.
25)RCS Barrier #4 NEI NEI 99-01 discusses the inclusion of shine dose in this EAL, and expects that a differentiation be applied to determine the presence of either a single barrier of 2 barriers (clad and RCS) lost. It does not appear that the deviation is acceptable justification to omit this EAL. Provide specific information for this EAL, consistent with other Entergy sites if possible, to include within this scheme.
26)RCS Barrier #5 NEI 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.
27)RBS PC #3 Explain use of 9500 mr/hr justification for id of CTMT leakage. Value appears quite high to be associated with leak path (in that there would have to also be some core damage).
28)PC #4 Caution in 99-01 on failure of 2 barriers by these conditions does not appear in EAL and Basis. Recommend adding to make clear loss of more than one barrier.
29)NEI CTMT Barrier #5
- Look at other sites for comparison. Appears to be some additional conditions that should be referenced here.
30)HU1#3/RBS HU4#3 Additional clarification should be provided to ensure that the operator understands that actual resulting damage is not a prior basis for classification.
31)RBS HU5 #2 Explain additional wording in EAL , "expected to enter normally occupied areas". This appears to deviate from intent of EAL. If notified of evac, then it is expected that the site would perform some protective action, such as evacuating. The entry on toxic gas into normally occupied areas is not intended to be part of the criteria to declare per this EAL.
32)JU1 #1 This EAL is a judgment EAL for a general emergency. Modify to meet NEI EALs.
33)HA5 #4
NEI IC and EAL missing. (typo) 34)HA3 #1 Specific areas are not listed. Explain deviation why those areas are not listed and or provide list.
- 35) HA3 #1 Specific areas are not listed. Explain deviation why those areas are not listed and or provide list.
36)JA1 #1 This EAL is a judgment EAL for a general emergency. Modify to meet NEI EALs.
37)JS1 #1 This EAL is a judgment EAL for a general emergency. Modify to meet NEI EALs.
38)SU1 #1 Inclusion of EDG status should be added consistent with 99-01.
Explanation in Differences section is not the correct logic for discussion of EDGs.
39)SU2 #2 Explain why 35 gpm is used instead of 30, which is the TS limit at RBS.
Site the specific TS references to justify this deviation (and classify in section correctly.)
40)SS1 #1 EAL for status of EDGs is missing from this IC. Provide EAL consistent with 99-01 or justify why this EAL is omitted.
41)SS3 #1 Modes are different than in 99-01. Explain this deviation from 99-01.
42)SG1 #1 No reference for EDGs. If EDGs are operable, then busses would be powered.
Provide justification using site drawings and electrical logic diagrams to discuss the power-related EALs.