ML051260191
| ML051260191 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, River Bend, Waterford  |
| Issue date: | 05/25/2004 |
| From: | England L Entergy Operations |
| To: | Alexion T NRC/NRR/DLPM/LPD4 |
| Alexion T W, NRR/DLPM, 415-1326 | |
| Shared Package | |
| ML051260191 | List: |
| References | |
| Download: ML051260191 (60) | |
Text
Thomas Alexion - EAL call Paae ! II Thomas Alexion - EAL call Paae 1 ii From:
'ENGLAND, LESLEY A" <LENGLAN~entergy.com>
To:
"'twa~nrc.gov`" <twa~nrc.gov>
Date:
5/25/04 3:53PM
Subject:
EAL call Tom:
Attached is our spread sheet for the Wednesday conference call to understand your draft questions on the EALs.. We have the general questions first followed by the questions in NEI EAL number order. How does this line up with your compilation? 'Clarify' means we're not sure what is needed;
'Discuss' means we will briefly state what we plan to do to be sure that will be responsive to the question. It is not our intent to necessarily try to answer the questions during the call. Where there is nothing specific noted we should spend minimal necessary time. As I noted earlier, Entergy will call in from 6 locations. Let me know how NRC would like to orchestrate the call. I'm in the office through Thursday this week.
<<EAL NRC Summary Questions.doc>>
Les England lenglan @entergy. corn internal 8-433-5766 external 601-368-5766 z
Fax #
601-368-5816 CC:
CC:
'HAYES, CURTLEY C" <CHAYES @ entergy.com>
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EAL call 5/25/04 3:49PM "ENGLAND, LESLEY A" <LENGLAN@entergy.com>
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W3/ANO/RBS/GGNS COMPARISON GENERAL NEI 99-01 Site Number Site Question NRC Discuss Entergy Action EAL Clarify number 1
FSAR Table 4-2 GGNS Specific There appear to be changes to the DBA X
1 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.
2 NA GGNS 1
NA Referenced changes to the Grand Gulf X
Why is 50.54q required?
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.
3 NA GGNS 2
NA Referenced changes to the Grand Gulf X
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 99-01 methodology, but no documentation for the review and justification for the change is included. Similarly, Table 4-2 of the FSAR contains minor changes, but documentation of the review of the design bases accidents and corresponding classification levels is not included.
4 NA GGNS 3
NA Specific definitions for (difference( and X
(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
NEI 99-01 Site Number Site Question NRC Discuss Entergy Action EALClarify number 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) 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.
NA W3 1
NA 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.
X Can this question be removed from list ?
Appears to be subjective.
6 NA W3 2
NA 10 CFR 50, Appendix E -- Section IV.B W3 will provide evidence of (Assessment Actions) states, review.
a.. 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 ift]hese changes have been reviewed and approved by...the State of Louisiana and local governmental authorities." Please provide documentation indicating that these discussion have
NEI 99-01 Site Number Site Question NRC Discuss Entergy Action EAL Clarify number 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.
7 NA ANO 1
NA 10 CFR 50, Appendix E -- Section IV.B X
(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.
8 NA W3 3
NA Provide copy of calculations used to W3 will provide additional determine effluent monitor thresholds information.
underAG1, ASI, M1 andAU1, and specify any deviations from guidance In NEI 99-01 (Basis for Radiological Effluent Initiating Conditions) and Appendix A. In addition, provide ranges for effluent monitor instrumentation referenced.
9 NA ANO 3
NA Provide copy of calculations used to ANO will provide additional determine effluent monitor thresholds information.
under AG1, AS1, AA1 and AU1, and specify any deviations from guidance in Appendix A to NEI 99-01 (Basis for Radiological Effluent Initiating Conditions).
10 NA W3 4
NA Provide a simplified drawing or schematic W3 will provide additional illustrating unit auxiliary and start-up information.
transformers and describe inter-relationship regarding conditions needed for a loss of off-site power and the ability of emergency diesel generators to supply on essential busses.
11 NA ANO 4
NA Provide a simplified drawing or schematic ANO will provide additional illustrating unit auxiliary and start-up information.
transformers and describe inter-relationship regarding conditions needed for a loss of off-site power and the ability of ___
NEI 99-01 Site Number Site Question NRC Discuss Entergy Action EAL Clarify number emergency diesel generators to supply on essential busses.
12 NA W3 5
NA Licensee Basis (under CU3) states that X
7tlemporary instrumentation andjumpers 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.
13 NA ANO 6
NA Describe whether temporary RCS water X
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.
14 NA W3 6
NA Evaluate changes proposed to NEI 99-01 X
W3 clarify difference and guidance in submittal to ensure that any deviation.
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 III
NEI 99-01 Site Number Site Question NRC Discuss Entergy Action EAL Clarify number appropriate. (Specific examples listed under "Specific Comments")
15 NA ANO 2
NA Clarify "deviation" example provided in X (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 technicaljustification for any deviations and differences, as appropriate. (Specific examples listed under "Specific Comments")
16 NA ANO 3
NA Discuss application of differences in design X
What is needed?
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?
17 NA ANO 4
NA Provide rational for the inconsistent use of ANO will correct unit nomenclature "ANO-1 / ANO-2" versus documentation.
"Unit 1 / Unit 2", or revise accordingly to ensure consistency in terminology.
18 NA ANO Spec 1 NA Section 6.2.1 (Downgrading the X
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) is I being addressed, which states in part that I
NEI 99-01 Site Number Site Question NRC Discuss Entergy Action EAL Clarify number
"[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..."
ABNORMAL RAD NEI 99-01 Site Number Site EAL Number NRC Discuss Entergy Action
_Clarify 1
Al
- 4) provides a listing of W3 establish list AA1 / EAL 1 EALl tion monitors. However, listing AA1 atrix (Attachment 3) for event EAL Clarify justification for attachments, or provide listing of tion monitors in EAL matrix.
AUl #1 99-01 EAL #1 applies to any X
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)?
3 AU1-EAL 2 ANO 2
AU ee inserted the statement ANO resolve wording EAL 2 ng a discharge", which is not
,sed under NEI 99-01, AUl -
)le EAL 2. However, statement t used in licensee AA1, EAL 2.
s insertion of statement as deviation or difference under ment 4, and provide justification nge and inconsistency with AA1, 4
AU /
Basis states that "[g]rab sample X
AA1 / EAL 2 EAL 2 analysis of the circulation water AA1 discharge, IAW EAL#3, would EAL 2 be necessary to determine the appropriate action." Clarify, per NEI 99-01 guidance, that a grab sample is not required to declare an event per AUl / EAL 2, based on effluent monitor threshold being exceeded for >
60 minutes.
NEI 99-01 Site Number Site EAL Number NRC Discuss Entergy Action
_________C larify_
AU1 #2 99-01 EAL #2 applies to X
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.
AU1 Provide listing of applicable, W3 provide list AA1 / EAL 3 EAL 3 site-specific technical AA1 specification references for EAL 3 gaseous and liquid releases per NEI 99-01 guidance.
AU1 #3 Explain why wording differs RBS revise wording from 99-01.
8 AU1-EAL 5/
ANO 3
AU1 Licensee modified NEI 99-01, X
AA1 -EAL 5 (and AUL1 / AA1 - Example EAL 5, AA1) under AU1 (and AA1), EAL 4 to EAL 4 reflect "RDAC data indicating NUE (Alert)." Identify in EAL 4 the site-specific value, as required under NEI 99-01, AUL1 (M1) - Example EAL 5, for event classification 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, AU1 (AA1) Basis for Example EAL 5.
AU1 Basis lists the deletion of EALs X
and 5 EALs 4 and 5 as a difference. While AA1 / EALs 4 4 and 5 deletion is technically justified, and 5 provide further clarification why AA1 change does not constitute a EALs deviation, based on the
NEI 99-01 Site Number Site EAL Number NRC Discuss Entergy Action C la rify_
4 and 5 elimination of specific NEI 99-01 example EAL criteria, or provide change listing deletion as a deviation.
10 AUl-Basis ANO 4
AU1 Licensee under AU1 Basis does ANO modify wording Basis not address NEI 99-01, AUM Basis guidance, which states
"...if an ongoing release is detected and the starting time for that release is unknown, the Emergency Director should, in the absence of data to the contrary, assume the release has exceeded 60 minutes."
Statement is included under licensee Ml Basis. Address deletion of Basis statement as either a deviation or difference under Attachment 3, and provide justification for deletion of Basis guidance and how EAL will be interpreted without guidance.
11 AU2-EAL 1
/
ANO 5
AU2 Licensee does not address the ANO clarify terminology AA2-EAL 2 EAL 1 "fuel transfer canal", which is AA2 identified under NEI 99-01, AU2 EAL 2
- Example EAL 1 and AA2 -
Example EAL 2. Identify deletion as either deviation or difference under Attachment 4 and provide justification for change, or provide proposed changes to comply with NEI 99-01 guidance.
12 AU2-EAL 1
/
RBS 4
AU2 NEI 99-01 IC does not apply RBS to align with fleet AA2-EAL 2 X1 000 throughout EALs for this IC.
AU2 Address site-specific indication X
W3 does not have fuel pool EAL 1 of uncontrolled water level level indication decrease in EAL per NEI 99-01 guidance.
NEI 99-01 Site Number Site EAL Number NRC Discuss Entergy Action Clarify 14 AU2-EAL 1 RBS 5
AU2 #1 This EAL specifically applies to RBS to align with fleet 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.
15 AU2-EAL 2 RBS 6
AU2 #2 This EAL is acceptable except RBS to clarify wording 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.
16 AA1 GGNS 2
Deviation, appears acceptable.
X Compare to other Entergy EAL submittals.
AA1 Correct Inconsistency in W3 to correct instrument Basis instrument number between numbering EAL 2 EAL matrix and Basis for the Fuel Handling Building Exhaust ERGM (e.g., PRM-/RE-3032).
18 AA1 Basis W3 7
AA1 Basis states that [f]or this IC W3 identify monitors and Basis
[initiating condition], it is designate thresholds 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.
19 AA1 /
AA1 Basis states, "...effluent W3 resolve inconsistency EAL 1 radiation monitor readings that exceed 200 times the Technical
NEI 99-01 Site Number Site EAL Number NRC Discuss Entergy Action Clarify 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 setpolnt established by the radioactivity discharge permit." Provide justification for inconsistency, or provide the proposed change to comply with NEI 99-01 guidance.
20 AA1 /EAL 1 RBS 7
M1 Same issue as in AU1. #1 X
AA1 / EAL 2
- 1 addresses liquid only, #2 and effluent and not radiation
- 2 Monitors.
M1 Explain difference between use RBS to modify wording
- 3 of confirmed versus unplanned.
Explain difference in wording, in general.
AA2 Provide a correlation between W3 to provide correlation.
EAL 1 site-specific radiation monitors designated licensee EAL 1 and those listed in NEI 99-01, AA2 /
EAL 1. In addition, specifically address the lack of Refuel Bridge Area Radiation Monitor per NEI 99-01 guidance.
Provide more detailed W3 has lead (RP to provide justification that 80 R/hr is fleet value) procedurally referenced in 05-S-01 -EP-4 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.
24 AA2 / EAL 2 W3 10 AA2 Licensee lists the deletion of I
_I W3 to provide additional
NEI 99-01 Site Number Site EAL Number NRC Discuss Entergy Action Clarify EAL 2 site-specific water level justification.
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.
25 AA2 ANO 6
AA2 Initiating Condition (IC)
ANO to provide clarification statement under Index of EALs, contained in Attachment 1 to EAL classification procedure, does not contain statement "outside the reactor vessel", as reflected In NEI 99-01, AA2 and Attachments 2 and 3 of the proposed EAL classification procedure. Provide change to reflect NEI 99-01, AA2 guidance or justify difference from guidance and AA2 IC statement in remainder of procedure.
26 AA2 W3 11 AA2 Licensee inserted the qualifier:
W3 will modify to match Basis
"...for this IC to apply the event NEI 99-01 must have radiological consequences - high radiation monitor alarm for this classification to apply." This statement is applicable to EAL 1 only, and not EAL 2 per NEI guidance, which is declared based on the actual or likely uncovery of irradiated fuel outside the reactor vessel.
Provide further justification for Basis qualification statement, or provide changes to comply with NEI 99-01, AA2 / EAL 2 guidance.
NEI 99-01 Site Number Site EAL Number NRC Discuss Entergy Action Clarify 27 AA2 -
W3 12 AA2 Licensee inserted the qualifier:
X W3 does not have level Basis "For this event, by definition, the instrumentation EAL 2 loss of water inventory would have to exceed makeup capacity." This statement may be misleading, since EAL is applicable if irradiated fuel is uncovered, regardless of make-up capacity. For. example, sufficient 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.
1.
28 AA2 RBS 10 AA2 Describe Max safe ops values W3 has lead (Develop fleet in more detail. Does this apply wording) to equip. or personnel?
29 AA3 GGNS 4
AA3 Typo under difference X
GGNS does not have water Deviation/
explanation level instrumentation Difference Look for comparison with other Entergy plants for reference to a site specific level for cavity.
Typically, a method is available in refueling outages where level can be monitored, even with alarm capability.
30 AA3 RBS 9
AA3 Combining EALs 99-01 AA2 #1 RBS break out into 2 EALs and #2 appears to result in two W3 lead on developing different conditions being common fleet RP values.
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.
NEI 99-01 Site Number Site EAL Number NRC Discuss Entergy Action Clarify 31 AA3-EAL 1 ANO 7
AA3 Differences listed in Attachment ANO provide site specific EAL 1 4 state that "[flor EAL #1...of the list 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 (EAL Matrix) states 'Control Room, TSC...",
while Attachment 3 (EAL Basis) states "Control RoomITSC...".
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.
32 AA3 / EAL 1 W3 13 AA3 Licensee deviates from NEI 99-X EAL 1 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
NEI 99-01 Site Number Site EAL Number NRC Discuss Entergy Action Clarify 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 u[t]he 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.
33 AA3 /EAL 1 W3 14 AA3 NEI 99-01, AA3 / EAL 1 W3 identify site specific EAL 1 requires licensee to identify site-areas 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 Iaddition, provide justification for
NEI 99-01 Site Number Site EAL Number NRC Discuss Entergy Action Clarify any deviations from NEI 99-01, AA3 / EAL 1 guidance.
34 AA3-EAL 2 ANO 8
AA3 Licensee states in Attachment 4 ANO to provide site specific EAL 2 that "[f]or EAL...#2 of the ANO's list 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.
35 AA3/EAL2 W3 15 AA3 Licensee has expanded EAL 2 W3 has lead to determine-EAL 2 criteria to add qualifier: "and fleet value.
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, M3
NEI 99-01 Site Number Site EAL Number NRC Discuss Entergy Action Clarify
/EAL2guidance.
In addition, do common Entergy radiation protection procedures exist that would provide for a consistent dose rate threshold ampong Entergy plants?
36 AA3-EAL 2 ANO 10 AA3 Licensee inserted the qualifier W3 has lead to determine EAL 2 "and access is required for safe fleet value.
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 as a deviation or difference under, and provide justification for proposed change based on NEI 99-01 example EAL criterion and basis.
37 AA3-EAL 2 ANO 9
AA3 Licensee specifies a threshold W3 has lead to determine EAL 2 of 5000 mR/hr. Describe fleet value.
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.
38 AS1 GGNS 5
AS1 Provide additional discussion GGNS to provide list of Dev/Diff on the deviation (correctly monitors.
document listed) for not listing default monitor set points for NEI 99-01 ASI. Other Entergy plants have included (ex. River Bend) monitor readings. Additional discussion to justify the
_I provision for prompt dose
NEI 99-01 Site Number Site EAL Number NRC Discuss Entergy Action C la rify assessment in the control room (in less than 15 minutes) and the procedural/commitment 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 Afor more than 1 hour@.
39 AS1 W3 16 AS1 In NEI EAL Differences W3 add definition AG 1AGI 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.
40 AS1 / EALs 2 W3 17 AS1 Licensee proposes to X
NEI wording is confusing and 4 EALs consolidate dose assessment AG1 I EALs 2 2 and 3 and filed survey data EAL and 4 criteria under a common EAL AGI for TEDE (whole body) and EALs thyroid CDE. However, while 2 and 3 identifying the threshold dose at or beyond the site boundary, I the proposed AS1 / EALs 2 and
NEI 99-01 Site Number Site EAL Number NRC Discuss Entergy Action Clarify 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.
41 AS1 / EALs 2 RBS 11 AS1 #2 Explain deviation for using RBS eliminate table and dose/hr values versus the 99-01 place values within EALs total dose criteria.
42 AS1 Basis and W3 18 AS1 Basis NEI 99-01 AS1/AG1 Bases W3 to modify wording.
Appendix A AG1 Basis guidance states that the AG1 Basis and meteorology and source term Appendix A 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 AUl and AA1 was not used for AS1/AG1. Rather, licensee appears to determine AS1/AG1 thresholds based on a ratio from AU1 dose rates. NEI 99-01 Basis and Appendix A state that thresholds for AUl and Ml are developed using ODCM methodology, and AS1 and AG1 using dose assessment method. Provide calculations for ASI EAL 1 monitor readings based on
NEI 99-01 Site Number Site EAL Number NRC Discuss Entergy Action Clarify meteorology and source term used in AUl and AA1 using station dose assessment model, versus ODCM calculational meth6d6logy, 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.
43 AG1 GGNS 6
AG1 Under NEI 99-01, example typo GGNS correct typo Dev/Diff (100 mR/hr),.
document Same as AS1 EALs #1 and #2, explain the deviation from the X
NEI 99-01 AS1 IC reference to A for more than 1 hour@.
44 AG1 EAL 2 RBS 12 AG1 #2 Explain use of dose/hr values X
for field team readings, which may be higher than total dose values.
SYSTEM MALFUNTIONS NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify 1
GU1 EAL 1 RBS 13 CUi #1 In deviation justification, explain relevance RBS provide more on 9.7 in. in relation to vessel level.
justification in basis.
2 CU2 ANO 11 CU2 Licensee IC statement in Attachment 4) is ANO to correct Inconsistent with that listed In Attachment inconsistency 1 (Index of EALs), Attachment 2 (EAL Matrix) and under NEI 99-01 CU2.
Correct inconsistency between IC statements.
3 CU2 W3 19 CUi Initiating condition (IC) title under NEI W3 to correct inconsistency EAL Differences Document does not reflect IC statement reflected under NEI 99-01 CU2. Provide justification for difference, orprovide change to comply with NEI 99-01 IC statement wording.
4 CU2 EAL 2 RBS 14 CU2 #2 Why reverse order of EALs?
RBS will reverse EALs to match NEI 99-01 5
CUi and CU2 W3 20 CUi Provide further technical justification for W3 will revise to match NEI CA1 and CA2 CA1 proposed modification to Mode 6 99-01 CS1 and CS1 CS1 applicability by adding qualifier 'with reactor vessel water level below the reactor vessel flange," which deviates from NEI 99-01 mode definitions, criteria guidance.
2.
6 GU2-EAL 2 ANO 12 CU2 Licensee states "UNPLANNED RCS level ANO to change to match EAL 1 drop below the reactor vessel flange NEI 99-01 greater than 15 minutes," rather than NEI 99-01, CU2 - Example EAL 1 criterion of
"[greater than or equal to]> 15 minutes."
Provide justification for deviation, or proposed changes to comply with NEI 99-01 guidance.
7 GU3-EAL 1 ANO 13 CU3 NEI 99-01 IC statements and Example ANO to eliminate GU3-EAL 1 EAL 1 EALs for both CU3 and SUI, with the inconsistency exception of mode applicability, are SUl Identical. However, listing of offsite power EAL 1 sources and criteria use for threshold 1.b, UAt least (site-specific) emergency generators are supplying power to I emergency busses," are inconsistent I
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify between licensee CU3 and SU1, EAL 1.
Provide justification for inconsistencies between criteria in CU3 and SUl based on common NEI 99-01 guidance, or proposed changes to eliminate inconsistency.
8 CU3 ANO 14 CU3 Licensee has chosen to make IC ANO to modify to comply applicable for modes 5 (Cold Shutdown),
with NEI 99-01 6 (Refueling) and D (Defueled). NEI 99-01 CU3 guidance lists applicability to Cold Shutdown and Refueling only. Basis merely states that licensee chose to add Defueling to mode applicability. Provide technical justification for deviation regarding applicability to Defueled mode, or proposed change to comply with NEI 99-01 guidance.
9 CU3 EAL RBS 15 CU4 #1 Explain why condition of EDGs Is not X
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.)
10 CU4-EAL 1 ANO 15 CU4 Licensee has chosen to insert '200OF, in X
CA4-EALs 1. 2 &
EAL 1 lieu of NEI 99-01 guidance statement of 3
'Technical Specification cold shutdown CA4 limit." Per guidance established by EALs licensee, this difference should be listed
- 1. 2 & 3 andjustifled as equivalent to the Technical Specification cold shutdown limit in Attachment 4. Identify difference, and provide justification as equivalent to the Technical Specification cold shutdown limit per NEI 99-01 guidance.
11 CU4 / EAL 1 W3 21 CU3 Licensee has chosen to insert "200 OF, in X
CA4 / EALs 1.2 EAL 1 lieu of NEI 99-01 guidance statement of and 3)
CA3 /
'Technical Specification cold shutdown EALs limit." Per guidance established by 1, 2 and 3 licensee, this difference should be listed
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify and justified as equivalent to the Technical Specification cold shutdown limit. Please identify difference, and provide justification as equivalent to the Technical Specification cold shutdown limit per NEI 99-01 guidance.
I I I
I I
12 CU5-EAL 1 SU4-EAL 1 ANO 16 CU5 SU4 Licensee 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 describe how the setpoint(s) correlate to Technical Specification allowable limits. If alarm setpoint does correspond to Technical Specification allowable limits, provide further technical justification for deviation from NEI 99-01 guidance.
ANO to provide alarm set point 13 CU5-EAL 1 RBS 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.
14 CU5 / EAL 1 SU4 / EAL 1 W3 22 CU4 SU9 Clarify whether letdown monitor is currently disabled, and identify whether other radiation monitors would be available to monitor fuel clad degradation based on Technical Specification allowable limits. In addition, provide justification for identifying elimination of radiation monitor criterion as a difference versus a deviation, since proposed change eliminates a specific EAL criterion listed in NEI 99-01 guidance.
X 15 CU5 / EAL 2 RBS 17 Explain why RBS does not provide a X
consistent method for detecting this IC, similar to other Entergy plants (such as GG use of offgas monitor readings
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify resulting in isolation). Further justification for deviating from this EAL is necessary.
16 CU6-EAL 2 ANO 17 CU6 Licensee includes the Station Radio ANO clarify SU6-EAL 2 Table C2 System under offsite communications capability. Clarify whether implementing SU6 procedures address the use of the Station Table M2 Radio System as a means of offsite notification purpose for consideration under these EALs.
17 CU6 / EALs 1 &
W3 23 CU5 Licensee includes cellular telephones W3 clarify 2
Tables under onsite and offsite communications SU6 / EALs 1 &
C1 & C2 capability. Clarify whether implementing 2
procedures address the use of cellular SU8 phones as a means of offsite Tables communications for consideration under Ml & M2 these EALs, and that cellular phones will function effectively within or in close proximity to plant structures to be considered a means of onsite and/or offsite communications.
18 CU6-EALs 1 & 2 ANO 18 CU6 Licensee includes portable cellular ANO clarify SU6-EALs 1 & 2 Tables telephones under onsite and offsite C1 & C2 communications capability. Clarify whether implementing procedures SU6 address the use of cellular phones as a Tables means of onsite communications and Ml & M2 offsite notification for consideration under these EALs, and that cellular phone will function effectively within or in close proximity to plant structures.
19 CU6-EALs 1 RBS 19 CU6 #1
shutdown EALs 20 CU6 / EAL 2 W3 24 CU5 Licensee lists civil defense radios under W3 procedure includes civil SU6 / EAL 2 Table offsite communications equipment, but defense radios C2 NEI 99-01 CU6 Basis lists radio transmissions as an extraordinary means SU8 of offsite communications. Clarify Table whether implementing procedures M2 address the use of civil defense radios as Ia back-up means of offsite
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify communications.
21 CU7 /EAL 1 W3 25 CU6 Revise DC voltage indication to reflect W3 provide additional nomenclature used to address voltages information less than 108 VDC and to reflect that used in SS4 and remainder of EALs (i.e.,
< 108 VDC vs. "of" 108 VDC).
22 CU6 / EAL 2 RBS 18 CU7 #2 Possible typo: offsite instead of onsite?
RBS resolve 23 CU8 GGNS 11 CU8 Justify the deviation (not difference) for GGNS to breakout including mode 3 in this IC. Note NEI Shutdown EALs 99-01 wording, in that fuel clad degradation is not considered a precursor because of the mode 4 or 5 condition, and if in mode 3, different considerations would be present.
24 CA1-EAL 1 ANO 19 CA1 Licensee states that NEI 99-01 criterion:
ANO to provide additional CA2-EAL 1 CA2 "Loss of RCS inventory as indicated by explanation CS1 -EAL 1 CS1 RPV level less than the bottom ID of the CS2-EAL 1 CS2 RCS loopr, 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.
25 CA1 and CA2 /
W3 26 CA1 Licensee Basis states that the Bottom ID W3 to use NEI 99-01 EAL 1 EAL 1 of the RCS loop is 11.8 ft. MSL, and that wording level monitoring systems in Modes 5 and 6 provide indication to 12.0 ft. Provide further technical justification why the conservative use of 12.0 ft MSL or indication off-scale low would not be appropriate, rather than proposed deletion of EAL criterion, since level difference between the Bottom ID of the RCS loop and the lowest indication is only 0.2 ft.
I
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify 26 CAl and CA2/
RBS 20 CAl Why is EAL reversed, changes meaning?
- 2 intentional, then provide justification why deviating from the NEI EAL.
27 CAl -Basis ANO 20 CAl Licensee incorrectly included discussion ANO needs to clarify regarding refueling mode from CA2 Basis wording in CAl Basis (3rd paragraph), rather than discussion on cold shutdown provided in NEI 99-01 CAl Basis. Licensee Basis also incorrectly references CA2 and CS2 due to this error, and in 1 st paragraph states ua loss of heat removal" versus NEI 99-01 discussion of ua loss of ability to adequately cool the core." Provide changes to Basis to address cold shutdown guidance in NEI 99-01 CAI Basis, or justification for differences.
28 CA3 ANO 21 CA3 lCs for NEI 99-01 for CA3 and SS1 ANO to provide additional SS1 SS1 states, "Loss of All Offsite Power and information 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 CAl 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 exception of mode applicability, but 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
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify 15 minutes under SS1.
29 CA3 / EAL 1 RBS 21 CA3 #1 RBS EAL is not including status of EDGs, RBS to provide additional which is critical to this EAL. Use of information.
"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.
30 CA3 / EAL 1.b W3 28 CA2 Licensee Basis takes credit for temporary W3 to provide additional SA5 Basis emergency diesels that may be used to information SS1 SA1 supplement onsite AC power in the event SG1 Basis emergency diesels are lost. Provide SS1 technical justification for deviation from Basis NEI 99-01 CA3 / EAL 1.b criterion, which SG1 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.
31 CA3 Basis W3 27 CA2 Licensee in Basis discussion substitutes W3 to clarify wording Basis the term "available" in lieu of NEI 99-01 term "operable", which is defined per technical specifications. Use of the term "available" is also inconsistent with licensee SS1 Basis, which uses term "operable". 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.
32 CA4 GGNS 12 CA4 Provide better justification why no GGNS/RBS standardize Dev/Diff reference to RCS reduced inventory. It wording and format document was included for River Bend (BWR).
33 CA4 / EAL1.2.3 RBS 22 CA4 Compare w/ GG, RBS format may be GGNS/RBS standardize
- 1,2,3 better.
wording and format
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify 34 CS1-EAL 2.a ANO 22 CS1 Licensee does not address NEI 99-01 ANO to clarify wording CS2-EAL 2.a EAL 2 criterion: '(RPV inventory as indicated by)
CG1-EAL 2.a RPV level less than TOAF [top of active CS2 fuel', based on justification that RVLMS EAL 2 will not monitor level below the bottom of ID of the RCS loop. Provide further CG1 technical justification, based on both EAL 2 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.
35 CS1-EAL 1 RBS 23 CS1 #1 1c. does not appear to be correct w/
X CTMT not Established. (direct to environ.) This appears to be consistent with GG1. Review this EAL, and correct to be consistent with NEI EAL guidance.
36 CG1 / EAL 2.b W3 34 CG1 Provide site-specific setpoint for W3 will add number and EAL 2 Containment High Range Radiation provide calculation Monitor reading within indicate core uncovery based on NEI 99-01 guidance for CONTAINMENT CLOSURE established.
37 CG1 I EAL 3 W3 35 CG1 Clarify whether safety analysis report or X
Table 5-F-4 EAL 3 other site-specific accident analyses Containment identify a site-specific explosive mixture Barrier Example CNB1 that would represent a challenge to EAL #2 Potential containment, equivalent to at least the Loss 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.
38 CS1 and CS2 /
W3 30 CS1 Under CS1 and CG1, licensee does not W3 make numbering agree
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify EAL 2.a CG1 address NEI 99-01 criterion associated CG1 / EAL 2.a 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.
39 CS1 / EAL 2.b W3 31 CS1 Per NEI guidance, with CONTAINMENT W3 split out EALs CLOSURE established, the inability to monitor RPV level for > 30 minutes with EITHER an unexplained sump and tank level increases OR erratic source range monitor indication would require classification. Describe how in Mode 5 (cold shutdown) with CONTAINMENT CLOSURE established, NEI 99-01 CS1 /
EAL 2.b criterion for erratic source range monitor Indication with the Inability to monitor RPV level for > 30 minutes, is met.
40 CS2-EAL 2.b ANO 23 CS2 Licensee EAL 1.a criteria is not consistent ANO perform additional EAL 1 with NEI 99-01 guidance, but rather research duplicates that in Example EALs 2.b (with the exception of SRM and CTE indication). In addition, the criterion "Reactor 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.
41 CS2-EAL 1.a &
ANO 24 CS2 NEI 99-01 guidance establishes ANO to perform calculation 2.b EAL 2
'Containment High Range Radiation CG1-EAL 2.a Monitor reading > [site-specific] setpoint"
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify CG1 as a criterion as evidence that RPV level EAL 2 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 usite-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 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.
42 CS2 / EALs 1.b W3 32 CS1 Licensee provides a valid high alarm on W3 to provide calculation and 1.b the Containment High Range Radiation Monitor, rather than exceeding a site-specific setpoint as established under NEI 99-01 guidance. Licensees justification 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
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify within indicate core uncovery based on NEI 99-01 guidance for CONTAINMENT CLOSURE established and not established.
43 CA4 / EAL 3 W3 29 CA3 Provide justification that the 20 psig is the W3 to evaluate set point EAL 3 lowest RCS pressure that can be read on installed Control Room instrumentation (that is equal to or greater than 10 psig) per 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.
44 CS2 / EALs 1.b W3 33 CS3 Provide justification for the designation W3 to provide additional and 1.b Core Exit Thermocouple > 7000 F" as a justification.
site-specific indication of core uncovery.
ISFSI NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify 1
E-HU1 ANO 25 E-HU1 Mode applicability is considered "not ANO to explain E-HU2 E-HU2 applicable" per NEI 99-01 guidance, since methodology 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.
2 E-HU1-EALs 1 &
ANO 26 E-HU1 Thresholds for natural phenomena and ANO to provide more detail 2
EALs accident conditions established by the 1 & 2 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 NRC Safety Evaluation Report.
FISSION PRODUCT BARRIER NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify 1
FA1 GGNS 17 FAI GGNS to correct Typo Typo for font in IC A reactor pressure boundary@
2 Table 5-F-2:
RBS 24 FC Explain use of 300 ucilgm, versus the X
4 ucilgm ?
Fuel Clad Barrier use of 4 ucVgm for this EAL at other Barrier Example
- 1 Entergy BWRs. In justification, EAL1 provide evidence that the 300 uci/gm activity would correspond to less than 5% fuel failure, as referenced In NEI 99-01.
3 Table 5-F-4 W3 37 Fission Licensee Basis states that 'Waterford X
W3 provide copy of CEOG Product 3 uses Safety Function Status Checks Document Barrier developed by the Combustion Degradation 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 Reactor]. 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 4
Table 5-F-2:
GGNS 14 Is the use of A-192 in@ a typo in the GGNS provide additional Containment difference explanation? Provide more clarification Barrier Example detailed discussion on the use of EAL #2 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.
5 Table 5-F-2:
GGNS 15 NEI 99-01 EAL #2 (potential loss GGNS change to agree RCS Example outside drywell) is missing. Discuss with RBS EAL #3 the deviation and provide justification for omitting or include in EAL scheme.
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify 6
Table 5-F-4:
ANO 29 CNB1 Licensee states 'Containment ANO provide clarification Containment 2n LTOSS pressure not consistent with event Barrier Example response". This is inconsistent with EAL #2 NEI 99-01 criterion, which states "Containment pressure or sump level not consistent with LOCA conditions".
Change was not Identified by licensee as a deviation or difference under. Identify as a deviation or difference and provide technical justification, or provide proposed change to comply with NEI 99-01 guidance.
7 Table 5-F-4:
W3 39 RCB2 Provide justification for establishing a W3 provide additional RCS Barrier Potential specific RCS leak rate versus NEI 99-information (has positive Example EAL #2 Loss 01 guidance criterion statement of displacement pump)
"...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.
8 Table 5-F-2:
RBS 27 RBS Explain use of 9500 mr/hr justification RBS to coordinate RCS Barrier PC #3 for id of CTMT leakage. Value response with GGNS Example EAL #3 appears quite high to be associated with leak path (in that there would have to also be some core damage).
9 Table 5-F-2:
RBS 28 PC #4 Caution in 99-01 on failure of 2 X
RCS Barrier barriers by these conditions does not Example EAL #4 appear in EAL and Basis.
Recommend adding to make clear loss of more than one barrier.
10 Table 5-F-2:
RBS 25 RCS NEI 99-01 discusses the inclusion of RBS and GGNS should RCS Barrier Barrier shine dose in this EAL, and expects have common approach Example EAL #4
- 4 NEI 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
NEI 99-01 Site Number Site EAL I Question NRC Discuss Entergy Action number Clarify with other Entergy sites if possible, to Include within this scheme.
11 Table 5-F-2:
RBS 26 RCS Additional information may be X
RCS Barrier Barrier warranted for this EAL, beyond simply Example EAL #5
- 5 NEI a stuck open relief valve. As example, also increases in suppression pool bulk temperature greater than TS limit.
12 Table 5-F-4:
ANO 30 CNB1 EAL criteria statement in Attachment 4 X
Containment 1
is worded, "Design pressure and Barrier Example POTENTIAL increasing hydrogen concentration >
EAL #2 LOSS 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.
13 Table 5-F-4:
ANO 31 CNB1 NEI 99-01 guidance establishes ANO to provide additional Containment 2nd criterion, "Explosive mixture exists",
discussion on 4%
Barrier Example POTENTIAL which per the NEI 99-01 Basis means concentration EAL #2 LOSS a hydrogen and oxygen concentration CG1-EAL 3 CG1 - EAL 3 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 ANO1 and ANO 2 containment structures, or provide further justification why oxygen concentration is not applicable to ANO1 and 2. In addition, revise criteria identified for an "explosive mixture inside containment" under CG1 - EAL 3 to ensure consistency with threshold in CNB1.
14 Table 5-F-4:
ANO 32 CNB2 NEI 99-01 guidance defines a ANO provide additional Containment POTENTIAL POTENTIAL LOSS as "core exist justification Barrier Example LOSS thermocouples in excess of 1200 EAL #3 degrees and restoration procedures
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify 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.
15 Table 5-F-4:
ANO 33 CNB2 NEI 99-01 guidance also defines a ANO to provide additional Containment POTENTIAL POTENTIAL LOSS as "core exit justification Barrier Example LOSS thermocouples in excess of 700 EAL #3 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.
16 Table 5-F-2:
GGNS 16 RCS This EAL is omitted form the GG GGNS align with RBS RCS Barrier Barrier EALs. This is listed as a difference Example EAL #4 EAL #4 due to location of monitors. The explanation is not sufficient to justify the omission. Provide more justification why this EAL should be omitted or add NEI 99-01 EAL to the scheme.
17 Table 5-F-4:
ANO 34 CNB3 Licensee considers NEI 99-01 X
Containment LOSS criterion, 'RUPTURED SIG is also Barrier Example faulted outside of containment", as EAL #4. 1' sredundant, and therefore, does not criterion address or provide further justification.
NEI 99-01 Basis (3rd paragraph) acknowledges that "[u]sers should realize that the two "loss" EALs
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify 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 completely. 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.
18 Table 5-F-2:
RBS 29 NEI
- Look at other sites for comparison.
X Containment CTMT Appears to be some additional Barrier Example Barrier conditions that should be referenced EAL #5
- 5 here.
19 Table 5-F-4:
ANO 28 RCB4 Provide basis for 60 uCi/gm dose X
RCS Barrier equivalent 1-131, consistent with NEI Example EAL #4 99-01 guidance.
20 Table 5-F-ANO 27 RCB4 Indications for an RCS Barrier LOSS, ANO correct EAL Matrix 4:RCS Barrier based on Containment Radiation Example EAL #4 Monitoring, were omitted from EAL Matrix in Attachment 2. Revise EAL Matrix to reflect RCB4 indications as outlined in EAL Basis (Attachment 3).
21 Table 5-F-GGNS 19 Reactor GGNS coordinate 2:RCS Barrier Pressure Justify the omission of A inside the response with RBS Example EAL #4 Boundary drywell@ for the potential loss for Parameters greater than 50gpm RPB leakage.
RPB Leak Rate 22 Table 5-F-4:
W3 40 CNB3 Provide EAL corresponding to NEI 99-X Containment Loss 01 criterion for a "RUPTURED S/G Barrier Example
[steam generator] is also FAULTED EAL #4 outside the containment," per Basis
NEI 99-01 Site Number Site EAL I Question NRC Discuss Entergy Action
__rnumber__
definitions, or provide specific technical Justification for deviation from NEI 99-01 guidance.
23 Table 5-F-2:
GGNS 20 Primary NEI 99-01 also discusses 02 levels, X
Containment CTMT which are omitted in the GG EAL.
Barrier Example Parameters, Justify your omission of the oxygen EAL #4 Hydrogen concentration and comparison to the Concentration lower deflagration limit.
24 Table 5-F-2:
GGNS 21 Primary Define ASAPs@. Justify the deviation X
Containment CTMT from declaring a loss from CTMT Barrier ExamDle Parameters, venting per EOPs, which is referenced EAL #4 Primary in NEI 99-01. (This is incorrectly listed CTMT iso.
as a difference.)
Failure Or Bypass (also in Dev/Diff document).
25 Table 5-F-2:
GGNS 22 Primary Justify the value (> 11,500 R/hr) in GGNS to evaluate use of Containment CTMT regard to being representative of 20%
RBS approach Barrier Example Parameters, fuel clad damage.
EAL #4 Primary CTMT Rad Monitoring (also in Dev/Diff document).
26 Table 5-F-4:
ANO 35 CNB4 Licensee criterion states, Unisolable ANO evaluate addition of Containment LOSS breach of containment with a direct new wording Barrier Example release path to the environment EAL #5 following containment isolation actuation." This is inconsistent with NEI guidance, which states "Valve(s) not closed AND 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 I
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number__
_i for change in EAL wording. Also, provide rational for the failure to address NEI 99-01 Basis guidance.
27 Table 5-F-4:
W3 41 CNB4 Provide justification for addition of W3 consider modifying Containment Loss qualifier, "...following containment wording Barrier Example isolation actuation."
EAL #5 28 Table 5-F-4:
ANO 36 CNB5 Clarify in licensee Basis that X
Containment POTENTIAL Containment high range radiation Barrier Example LOSS monitor reading of 4,000 R/hr EAL #6 corresponds to 20% fuel clad damage, or other site-specific analysis value, per the guidance in NEI 99-01 Basis.
29 Table 5-F-2:
GGNS 18 Provide justification that compares the X
Fuel Clad listed 5% clad failure with A300 Barrier Example ucilml@ value in NEI 99-01.
EAL #6 To be consistent with 99-01, the EAL for clad failure should be 300 uci/ml.
30 Table 5-F-4:
W3 38 Fission Provide evaluation of other site-W3 provide additional Fuel Clad Product specific indications of a loss or justification Barrier Example Barrier potential loss of the Fuel Clad Barrier EAL #6 Degradation per NEI 99-01 guidance, including indications from containment air monitors or other site-specific instrumentation.
31 Table 5-F-4:
ANO 37 CNB6 NEI 99-01 Basis states this EAL X
W3 has lead to contact Containment should cover other site-specific NEI in advance of NRC Barrier Example indications, including: area or meeting EAL #7 ventilation monitors in containment annulus or other contiguous buildings that may unambiguously indicate a loss or potential loss of the containment barrier, or venting of containment per site emergency operating procedures. Provide rational in licensee Basis why these criteria are not considered applicable to ANO-1 and/or ANO-2 Containment structures, or proposed wording to comply with NEI 99-01 Basis guidance.
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify 32 Table 5-F-4:
W3 42 Fission Provide evaluation of other site-X Containment Product specific indications of a loss or Barrier Example Barrier potential loss of the Containment EAL #7 Degradation Barrier per NEI 99-01 guidance, including indications from area or ventilation monitors in containment annulus or other contiguous buildings, or the intentional venting of containment per emergency operating procedures to prevent a catastrophic failure.
33 Table 5-F-4:
ANO 38 CNB6 Licensee chose to include "at least ANO provide additional Containment POTENTIAL 20% fuel damage failure as justification of approach Barrier Example LOSS determined from core damage EAL #6 & 7 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 "fr]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.
HAZARDS NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify 1
HU1 GGNS 26 Dev/Diff More justification is necessary to justify GGNS to evaluate flooding document omission of this EAL. Considerations for more than river flooding should be discussed, such as storm drain overflow, water main piping flooding, etc. This is incorrectly listed as a difference, instead of a deviation.
Consider adding EAL to scheme, or provide detailed justification for this deviation.
2 HU1-EAL 2 ANO 41 HU6 Please provide specific references to ANO to provide additional EAL 2 safety analysis report (SAR) for Units 1 information and 2 high winds design basis under Reference Document listing in (Basis).
3 HU1-EAL 3 RBS 30 HU1#3 Additional clarification should be X
Discuss NOUE vs Alert HU4-EAL 3 RBS provided to ensure that the operator HU4#3 understands that actual resulting damage is not a prior basis for classification.
4 HU1 -EAL 6 ANO 42 HU6 Provide site-specific listing, as ANO to provide plant EAL 6 specified by NEI 99-01 guidance, of specific list areas of the plant where uncontrolled flooding has the potential to affect safety-related equipment.
5 HU1 / EAL 6 W3 43 HU6 Clarify inconsistency between HU6!
W3 to clarify and make EAL HA1 / EAL 5 EAL 6 EAL 6 and HA6 / EAL 5,regarding site-more specific HA6 specific areas containing systems EAL 5 required for the safe shutdown of the plant, that are not designed to be wetted or submerged, that would be impacted by internal flooding per NEI 99-01 guidance (e.g., HU6 states -35 elevation areas vs. HA6 which states Reactor Auxiliary Building). In addition, identify the basis used for determining these areas (i.e.,
6 HU1 -EAL 7 ANO 43 HU6 Describe technical basis for low and ANO to provide reference EALs high lake water level and provide 7 & 8 reference to basis under Reference
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify Documents in Attachment 3 (Basis).
7 HU1 -EAL 7 ANO 44 HU6 Describe whether the ANO site is X
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.
8 HU2 GGNS 24 HU4 IC is different in GG HU4, (protected GGNS to add list of area boundary versus power block).
buildings Further, in the basis, NEI 99-01 describes a more detailed generalization of areas in actual contact or immediately adjacent to 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.
9 HU3-EAL 1 ANO 40 HU5 NEI 99-01 qualifier "...enter the site X
What is site boundary?
EAL 1 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 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.
10 HU3-EAL 2 GGNS 23 HU3 Wind speed limits are not included in GGNS coordinate response EAL #2 the EAL (as in NEI 99-01, HU1, #2).
with RBS (also in Justify the deviation from listing wind Dev/Diff speeds in the EAL. (This is incorrectly document).
listed as a difference.)
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify In the HU1 Deviation/Difference document, the justification is that hurricane force winds have never been recorded. Severe winds from very strong 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.
Justify the omission of EALs # 6 and
- 7 in HU3, as compared to 99-01 HU1.
11 HU3 GGNS 25 HU5 EAL #2 is missing from the GG EALs.
GGNS to add EAL Justify your deviation from NEI 99-01 by omitting EAL #2.
In the Deviation/Difference document, NEI 99-01 HU3 is omitted, with a difference listed that no industries are in the Grand Gulf area affecting 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.
12 HU4-EAL 2 ANO 39 HU1 Licensee deleted the term "site-ANO to add additional EAL 2 specific" from EAL wording and chose wording not to include the NEI Basis discussion, which states "Only the plant to which the specific threat is made need declare the Notification of an Unusual Event". Describe how EAL 2 would allow for the differentiation between a general (i.e., threat against company facilities / property) versus directed at station, since usite-specific" criteria was deleted from EAL wording
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify and basis. 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.
13 HU4-EAL 2 RBS 31 HU5 #2 Explain additional wording in EAL, X
What is normally occupied expected to enter normally occupied areas?
areas". This appears to deviate from intent of EAL. If notified of evacuation, 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.
14 HU5-EAL 1 RBS 32 Jul #1 This EAL is a judgment EAL for a RBS to modify numbering general emergency. Modify to meet NEI EALs.
15 HU5-EAL 1 RBS 36 JAl #1 (Duplicate)This EAL is a judgment EAL RBS to modify numbering for a general emergency. Modify to meet NEI EALs.
16 HU5-EAL 1 RBS 37 JS1 #1 This EAL is a judgment EAL for a RBS to modify numbering general emergency. Modify to meet NEI EALs.
17 HAl & HA2 GGNS 27 HA4 Wind speed limits are missing from the GGNS to modify wording GG EAL, #2. Deviation/Difference document discusses highest recorded wind speed as 69 mph, but does not review FSAR wind loading analysis or a comparison of historical events in the southeast to determine if there are other examples of hurricane force winds extending several hundred miles inland. Reexamine UFSAR to ensure that wind loading is not included (not just hurricane).
EAL #4 uses vital area instead of specific areas containing functions and systems necessary for safe shutdown I
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify (though may be the same).
HA4 #4 references Acausing damage@ as opposed to Aaffecting operability of@ as in NEI 99-01, HA2.
Change to match 99-01 EAL or provide detailed justification for this deviation.
18 HA1-EAL 1 ANO 48 HA6 Provide description in EAL 1 Basis that ANO to add reference EAL 1 supports the selection of 0.1g as indicative of an Operating Basis Earthquake (OBE), and reference to site-specific technical basis (i.e., SAR, etc.) under Reference Documents in.
19 HA1-EAL 2 ANO 49 HA6 Licensee does not include the "Turbine X
EAL 2 Building", since it does not contain a vital area. Clarify whether damage to equipment in the turbine building due to high winds could cause, either directly or indirectly, damage to safety functions and systems required for the safe shutdown of the plant per NEI 99-01, HA1 Basis. If so, provide proposed change to comply with NEI 99-01 guidance to include the Turbine Building in Table H-2.
20 HA1 -EAL 3 ANO 50 HA6 Licensee Basis contains statement, 'If ANO will provide additional EAL 3 the crash is confirmed to affect a plant justification vital area, escalation to ALERT is appropriate"; however, this statement is applicable to licensee HU6 Basis rather than HA6 Basis per NEI 99-01 guidance. Provide justification for including statement in HA6 Basis.
21 HAl-EAL 4 ANO 51 HA6 License references Table H-2 areas X
EAL 4 rather than developing a site-specific listings of areas, containing safety functions and systems required for the safe shutdown of the plant, that could realistically be impacted by turbine failure-generated missiles. Provide
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify justification for referencing Table H-2, rather that developing site-specific areas based on NEI 99-01 guidance.
22 HA1 EAL5 & 6 GGNS 28 HA1 Provide justification for the deviations GGNS to addresss flooding EALs from 99-01. Correct in
- 5 and #6 Deviation/Differences document to missing.
record as a deviation, with detailed justification why appropriate to eliminate. In justification, include analysis of other than Ariver flooding@, as discussed previously.
23 HA1 -EAL 5 ANO 52 HA6 Provide justification for the failure to ANO will provide list EAL 5 identify site-specific areas, per NEI 99-01 guidance, which include areas that contain systems required for safe shutdown of the plant, that are not designed to be wetted or submerged.
24 HA1-EAL 6 ANO 53 HA6 Provide reference to technical basis ANO will provide additional EAL 6 (i.e., SAR, etc.) for ALERT information classification based on low lake level, and include reference to technical basis(es) under Reference Documents in Attachment 3.
25 HA2-EAL 1 ANO 46 HA4 Licensee Basis does not include 1is ANO to add additional EAL 1 paragraph from NEI 99-01 guidance information providing basis for selection of site-specific areas. Describe basis for the selection of Table H1 areas based on NEI 99-01 guidance (i.e., safe shutdown analysis, etc.).
26 HA2 / EAL 1 W3 45 HA4 Identify the basis used for determining W3 will provide additional site-specific areas containing functions information and systems required for the safe shutdown of the plant (i.e., site-specific safe shutdown analysis, etc.).
27 HA3-EAL 1 ANO 47 HA5 Licensee inserted the following ANO will provide additional EAL 1 qualifier in Basis: "Areas that require information only temporary access that can be supported by the use of respiratory
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify protection should not be considered as exceeding this threshold. However, this qualifier is not addressed under NEI 99-01 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.
28 HA3-EAL 1 RBS 34 HA3 #1 Specific areas are not listed. Explain RBS will add EAL. (GGNS deviation why those areas are not and RBS to work together listed and or provide list.
for common approach.
29 HA3-EAL 1 RBS 35 HA3 #1 (Duplicate Question)Specific areas are RBS will add EAL. (GGNS not listed. Explain deviation why those and RBS to work together areas are not listed and or provide list.
for common approach.
30 HA5-EAL 1 ANO 45 HA3 Provide justification for use of qualifier, X
"in progress", rather than "has been initiated" as stated in IC, or provide proposed change to comply with IC statement. In addition, clarify that a site-specific procedure does not exist governing control room evacuation.
31 HA5 / EAL 1 W3 44 HA3 Provide site-specific procedure or W3 to provide procedure HS2/ EAL 1 HS3 equivalent objective measure, which reference upon entering procedure, initiating specific procedural step or action, or reaching criteria, would reflect requirement for control room 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.
32 HA5/ EAL 4 RBS 33 HA5 #4 NEI IC and EAL missing. (typo)
X 33 HS1 (also in GGNS 29 HS1 GG EAL considers only an armed GGNS to modify Deviation/Differences attack against the plant, versus the justification
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number
___if document).
other considerations in 99-01 (insider destruction of equipment, sabotage, hostage/extortion). Justify the deviation from the 99-01 other considerations. Justify the ommision of EAL #2 from GG EALs.
NEI 99-01 HS1, EAL #2 is missing from GG EALs. This is noted as a Adifference@, and appears to be a deviation. Provide more detailed justification why it is appropriate to omit this EAL.
34 HS2-EAL 1 ANO 54 HS3 Providejustification, based on site-ANO will provide additional EAL 1.b specific analysis or assessments per information.
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. In addition, please identify as deviation or difference, as appropriate, andprovide justification regarding the failure to include site-specific procedure reference for the transfer of plant control during a control room evacuation.
35 HS2 / EAL 1 W3 46 HS3 Please provide justification, based on W3 will provide additional EAL 1 site-specific analysis or assessments information 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.
36 HG1 GGNS 30 HG1 GGNS to address in basis SFP loss of control is not addressed in document the EALs, as discussed in NEI 99-01 EAL basis. Justify the deviation from referencing SFP conditions in the EAL.
37 HG2-EAL 1 ANO 55 HG2 Identify as a deviation or difference, as X
EAL 1 appropriate, and provide justification for change in EAL wording referring to
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify exceeding EPA Protective Action Guideline exposure 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".
SYSTEM MALFUNCTION NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify 1
SUl GGNS 8
SUl Justify the deviation (not difference)
GGNS will develop Dev/Diff between the mode applicability separate category for cold document between GG EALs and NEI 99-01 shutdown EALs EALs.
Typo under difference.
2 SU1-EAL 1 ANO 56 SUl Under the Basis, the licensee has ANO will provide additional EAL 1 chosen to include a discussion, which information states that "... failure of the offsite power sources results in a loss of RCPs..." Intent of NEI 99-01 guidance Is to reflect a prolonged loss of offsite power, and Is not Intended to consider the loss of specific station loads. Provide further clarification whether Basis statement, included by licensee, would preclude classification of event based on the loss of offsite power if specific station loads were not lost. If so, provide further justification for deviation or proposed change to comply with NEI 99-01 guidance.
3 SU1-EAL 1 RBS 38 SUl #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.
4 SU2-EAL 2 RBS 39 SU2 #2 Explain why 35 gpm is used instead X
of 30, which is the TS limit at RBS.
Site the specific TS references to justify this deviation (and classify in section correctly.)
5 SU3-EAL 1 ANO 57 SU3 Provide description in Basis, and ANO will provide additional EAL 1 technical justification as a deviation to information.
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.
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify 6
SU3-EAL 1 ANO 58 SU3 Provide a description of the number of ANO will provide additional EAL 1 Control Room annunciator panels in information.
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.
7 SU3-EAL 1 ANO 59 SU3 Licensee has chosen to insert the ANO will provide additional EAL 1 qualifier 'Loss of AC and DC" as information.
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.
8 SU3-EAL 2 GGNS 31 SU3 NEI 99-01 lists 25gpm as the EAL for GGNS will correct typo and (also in Identified leakage. In the GG basis, add additional information.
Deviation/Differences 35 gpm is discussed as the minimum document).
limit for detection for unidentified leakage, but is the identified leak rate limit in the EAL. 10 gpm is the unidentified limit. Correct the references in the basis, and justify the deviation for using 35 gpm as the identified leak rate, versus 25 gpm in 99-01. This is listed as a difference instead of a deviation.
9 SU3 W3 47 SU3 Describe logic for referencing Reg.
W3 to research in more SA4 Guide 1.97, rather than listing specific detail and add additional SS6 SA3 Control Room indicator panels information as applicable.
containing safety system SS3 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
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify label instrumentation to allow for the prompt classification of event.
10 SU4 GGNS 7
EAL Deviation appears justified, however, X
No practicable way to SU4 NEI 99-01 still lists the 10 gpm limit in measure Dev/Diff the EAL, which could be observed in document some situations using remotely installed equipment (as in refueling outages). Recommend that the 10 gpm be left in, and the inclusion of level also included. Additional justification is necessary for the omission of the 10 gpm. Identification of AO" A is missing from the discussion. Is 0" at the reactor head flange?
I
_ICompare to other Entergy plant EALs.
11 SU5 W3 48 SU7 Provide justification for Basis W3 to modify statement U
Cui statement, "[alt Waterford 3, steam generator leakage is considered to be identified leakage." In addition, clarify why this statement would also not be applicable during cold shutdown mode per CU1.
12 SU8-EAL 2 ANO 60 SU8 Describe in Basis the rational for Unit ANO to add additional CU8-EAL 2 EAL 1 1 (ANO-1) and Unit 2 (ANO-2) EAL information.
thresholds established by licensee, CU8 and justification for inclusion of site-EAL 1 specific thresholds for inadvertent criticality in SU8 (Modes 3 / 4), but not under CU8 (Modes 5/ 6).
13 SU8 W3 49 SU O Clarify use of terms 'extended" vs.
W3 to clarify wording.
CU8 CU7 usustained" for consistency with EAL thresholds and use of terms in licensee SU10 and CU7 Bases.
14 SU9 GGNS 10 SU 9 Justify the deviation (not difference)
GGNS to separate cold Dev/Diff for including modes 1, 2, and 3 in this shutdown EALs document IC. Note NEI 99-01 wording, in that fuel clad degradation is not considered a precursor because of the mode 4 or 5 condition, and if the
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify mode were 1, 2, 3, different considerations would be present.
15 SU10 GGNS 9
SUlo Justify the deviation (not difference)
GGNS to separate cold for including modes 1, 2, and 3 in this shutdown EALs IC. Note NEI 99-01 wording, in that fuel clad degradation is not considered a precursor because of the mode 4 or 5 condition, and if the mode were 1, 2, 3, different considerations would be present.
16 SA2-EAL 1 ANO 61 SA2 Licensee has revised EAL wording in X
ANO Add additional EAL 1 EAL Basis (Attachment 3) to include information qualifier "...and a successful manual trip or DSS trip occurred." This change is not consistent with NEI 99-01 guidance, nor the wording 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.
17 SA2-EAL 1 ANO 62 SA2 Under examples of what constitutes a ANO to provide additional EAL 1 "manual trip", licensee inserted information example: "de-energizing rod drive mechanism". Clarify that, based on NEI 99-01 guidance, the rod drive mechanism can be de-energized from main control rod panels, and does not require action in other adjacent Control Room auxiliary (side or back) panels (i.e., pulling fuses) or actions outside of control room, which are not to be considered under a manual scram.
18 SA2 W3 50 SA2 Clarify whether rod withdrawal would W3 to clarify wording.
occur in hot standby (Mode 3), as part of a plant start-up, prior to entering Mode 2. If rod withdrawal would initiate in hot standby, prior to entering Mode 2 (Start-up), then
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify address Mode 3 applicability per NEI 99-01 guidance.
19 SA2 W3 51 SA2 Intent of the NEI 99-01 IC is to W3 o modify wording Basis address the failure of an automatic shutdown, whenever an automatic reactor trip is initiated. While steam generator high level per the Waterford 3 Technical Specifications does not correspond to a safety limit, its functional capability at the specified trip setting is required to enhance the overall reliability of the Reactor Protection System (RPS), and therefore, should be applicable to this IC. This Is also applicable to 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 guidance.
20 SA3 GGNS 32 SA3 In the basis, the allowance for ARI as GGNS to supply reviewer (also in one of the successful means for a with additional information.
Deviation/Differences manual scram is referenced. Discuss document).
the ability (in terms of time and operator actions (ie. Manual actions or control room actions) to use ARI as a means to A rapidly@ manually shut down the reactor.
21 SA4-EAL 1)
ANO 63 SA4 Define what constitutes a loss of most ANO to provide additional EAL 1 or all indicators, consistent with information.
licensee's SU3-EAL 2, or identify as a deviation and provide justification from NEI 99-01 guidance.
22 SA4-EAL 1 ANO 64 SA4 Licensee uses term 'Plant Transient",
ANO to provide additional EAL 1 which is defined differently than a explanation.
"Significant Transient" per Sections 4.34 and 4.39, and NEI 99-01,
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify 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.
23 SS1-EAL 1 RBS 40 SS1 #1 EAL for status of EDGs is missing RBS to provide additional from this IC. Provide EAL consistent reference to diesel with 99-01 or justify why this EAL is generator.
omitted.
24 SS3-EAL 1 RBS 41 SS3 #1 Modes are different than in 99-01.
RBS to provide justification Explain this deviation from 99-01.
for hot shutdown in deviation document.
25 SS3 GGNS 33 SS3 In NEI 99-01 Basis discussion of SS3, GGNS to provide additional there is a specific reference to wording in basis document.
operator actions away from the reactor control console which define a NOT SUCCESSFUL manual shutdown. That specific caution is 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.
26 SS3-EAL 1 ANO 65 SS3 Describe rational for listing of unit-ANO will provide additional CU7-EAL 1 EAL 1 specific busses in SS3 (Modes 1_4),
information.
but not in CU7 (Modes 5/ 6). In CU7 addition, confirm that nomenclature EAL 1 for Unit 1 (ANO-1) DC busses is D01 and D02, versus use of unit designator 1 D01 and 2D02.
27 SS4 GGNS 13 SS4 Additional justification for RVP levels GGNS will provide Dev/Diff and their representations, to compare additional justification and document with NEI 99-01 levels.
will coordinate response with RBS.
Is A not established@ a typo in SS4 EAL #2, as NEI 99-01 CS4, EAL #2 Is A established @.
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify No EAL for sump/tank levels or for source range monitor increases.
Justify deviation for not including in EAL.
28 SS4-EAL 1 ANO 66 SS4 While not required per NEI 99-01 ANO will provide additional EAL 1 guidance, licensee has chosen to information.
insert specific system availability to provide core cooling and heat sink.
Describe in Basis rational for the selection of Criteria 1.a, 1.b and 1.c.
29 SS4 / EAL 1 W3 53 SS5 Licensee inserted qualifier, W3 will modify wording.
"...necessary to reach Hot Shutdown",
1 and 2 in IC statement. However, per NEI 99-01 Basis and licensee criteria provided, this IC reflects capabilities to reach or maintain hot shutdown.
Revise licensee proposed IC statement to reflect intent of NEI 99-01 guidance.
30 SS6, EAL #1 GGNS 34 SS6 Use of word A unplanned@ appears GGNS will modify wording.
EAL #1 to indicate that if planned, this would be acceptable. Provide detailed justification why this deviation is acceptable, as written.
31 SS6 ANO 67 SS6 Licensee uses term "Transient" in IC ANO clarify wording.
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.
32 SS6-EAL 1.c ANO 68 SS6 NEI 99-01 criterion states, ANO to provide further EAL 1.c "Indications needed to monitor (site-evaluation.
specific) safety functions are unavailable". However, licensee has Iestablished a threshold of a "loss of I
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify 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.
33 SS6 / EAL 1.c W3 52 SS3 NEI 99-01 does not require that all W3 to modify wording and Reg. Guide 1.97 indication be lost as coordinate with ANO.
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.
34 SG1-EAL 1.b ANO 69 SG1 NEI 99-01 guidance states, uSite-X EAL 1.b specific) indication of continuing degradation of core cooling based on Fission Product Barrier monitoring."
Licensee has designated criterion, "FA1 entry conditions met."
Designate Fuel Clad Barrier criteria from Fission Product Barrier Matrix, contained in Attachment 2, which specifically indicate a continuing degradation of core cooling.
35 SG1-EAL 1 RBS 42 No reference for EDGs. If EDGs are RBS to add reference to SG1 #1 operable, then busses would be diesel generator.
powered. Provide justification using site drawings and electrical logic diagrams to discuss the power-related EALs.
36 SG2 GGNS 35 SG2 As in item 32, justify the use of ARI as X
(also in A rapid@ insertion of rods.
Deviation/Differences
??
document).
NEI 99-01 Site Number Site EAL Question NRC Discuss Entergy Action number Clarify 37 SG2-EAL l.a ANO 70 SG2 Describe the correlation and technical ANO to evaluate further EAL 1.a basis between the unit-specific and provide consistency.
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."
38 SG2-EAL 1.b ANO 71 SG2 Describe the correlation and technical X
EAL 1.b basis between the thresholds indicating heat removal is extremely challenged (EAL 1.b), with the NEI 99-01 Basis guidance of "emergency feedwater flow is Insufficient to remove the amount of heat required by design from at least one steam generator."
39 SG2 EAL 1.b W3 54 SG2-EAL 2 NEI 99-01 Basis guidance and that X
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.