ML071560006
| ML071560006 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 06/19/2007 |
| From: | Wang A NRC/NRR/ADRO/DORL/LPLIV |
| To: | Keenan J Pacific Gas & Electric Co |
| Wang, A B, NRR/DORL/LPLIV, 415-1445 | |
| References | |
| TAC MD3924, TAC MD3925 | |
| Download: ML071560006 (16) | |
Text
June 19, 2007 Mr. John S. Keenan Senior Vice President and CNO Pacific Gas and Electric Company Diablo Canyon Power Plant P.O. Box 770000 San Francisco, CA 94177-0001
SUBJECT:
DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING CONVERSION OF THE EMERGENCY ACTION LEVELS (TAC NOS. MD3924 AND MD3925)
Dear Mr. Keenan:
By letter dated December 21, 2006, Pacific Gas and Electric Company, the licensee, submitted a request for approval of the conversion of the Emergency Action Levels to the Nuclear Energy Institute 99-01, "Methodology for Development of Emergency Action Levels Scheme, for the Diablo Canyon Power Plant, Unit Nos. 1 and 2.
The NRC staff has reviewed the above request and has determined that it requires additional information to complete its review. A request for additional information is enclosed. This request was discussed with Tom Grozan of your staff on June 8, 2007, and it was agreed that a response would be provided within 60 days of receipt of this letter.
If you or your staff have any questions concerning the resolution of this matter, please contact Alan B. Wang at (301) 415-1445.
Sincerely,
/RA/
Alan B. Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323
Enclosure:
Request for Additional Information cc w/encl: See next page
ML071560006 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NSIR/DPR/DEP/BC NRR/DORL/LPL4/BC NAME AWang JBurkhardt EWeiss THiltz DATE 6/11/07 6/11/07 6/12/07 6/19/07 Diablo Canyon Power Plant, Units 1 and 2 cc:
NRC Resident Inspector Antonio Fernández, Esq.
Diablo Canyon Power Plant Pacific Gas & Electric Company c/o U.S. Nuclear Regulatory Commission P.O. Box 7442 P.O. Box 369 San Francisco, CA 94120 Avila Beach, CA 93424 City Editor Sierra Club San Lucia Chapter The Tribune ATTN: Andrew Christie 3825 South Higuera Street P.O. Box 15755 P.O. Box 112 San Luis Obispo, CA 93406 San Luis, Obispo, CA 94306-0112 Ms. Nancy Culver Director, Radiologic Health Branch San Luis Obispo State Department of Health Services Mothers for Peace P.O. Box 997414, MS 7610 P.O. Box 164 Sacramento, CA 95899-7414 Pismo Beach, CA 93448 Mr. James Boyd, Commissioner Chairman California Energy Commission San Luis Obispo County 1516 Ninth Street MS (31)
Board of Supervisors Sacramento, CA 95831 1055 Monterey Street, Suite D430 San Luis Obispo, CA 93408 Mr. James R. Becker, Vice President Diablo Canyon Operations and Mr. Truman Burns Station Director Mr. Robert Kinosian Diablo Canyon Power Plant California Public Utilities Commission P.O. Box 56 505 Van Ness, Room 4102 Avila Beach, CA 93424 San Francisco, CA 94102 Jennifer Tang Diablo Canyon Independent Safety Field Representative Committee United States Senator Barbara Boxer Attn: Robert R. Wellington, Esq. 1700 Montgomery Street, Suite 240 Legal Counsel San Francisco, CA 94111 857 Cass Street, Suite D Monterey, CA 93940 Regional Adminstrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 January 2007
REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-275 AND 50-323 OPERATING LICENSE NOS. DPR-80 AND DPR 82 By letter dated December 21, 2006 (Agencywide Documents Access and Management System Accession No. ML063620364), Pacific Gas and Electric Company, the licensee, submitted a request for approval of the conversion of the Emergency Action Levels to the Nuclear Energy Institute 99-01, "Methodology for Development of Emergency Action Levels Scheme, for the Diablo Canyon Power Plant, Unit Nos. 1 and 2. The NRC staff had a conference call on May 29, 2007, with the licensee to discuss its request. Based on our review, the above request, and the conference call, the NRC staff has determined that the additional information is required to complete its review.
On the following pages is a table summarizing the areas for which the NRC staff needs additional information to complete its review.
Final Diablo Canyon RAIs RAI # NEI EAL # DCPP EAL # Pg. # RAI Generic Comment Changes to the basis of each EAL were not flagged or justified in the difference/deviation matrix.
1 NEI 99-01 provides a list of acronyms. Please provide a list as part of the basis document or justify its removal.
Comment Each site-specific EAL should reference the designator of its equivalent NEI 99-01 EAL in the reference section (or provide a cross reference in the basis document itself).
2 4 Are the fission product barrier definitions consistent with NEI 99-01 definitions?
Comment 4 A logic flow diagram would be a useful aid for fission product classifications.
Comment 7 As a matter of convention, the 3rd character of the EAL identifier is the Initiating Condition, not a subcategory.
Comment 12 Containment Closure definition:
Suggest using the NRC proposed NEI 99-01 Rev. 5 wording:
(PWR) is defined by site specific procedure. (BWR) is considered to be Secondary containment as required by Technical Specifications.
In either case, CONTAINMENT is any structure, system, or component that provides a functional barrier to fission product release under existing plant conditions as defined in Technical Specifications.
3 13 The definition of Hostile Action is not consistent with the definition provided in Bulletin 2005-02. Please correct or justify.
4 15 Why does the definition for Sabotage require it to be a Hostile Action? This is not consistent with the definition of Sabotage in NEI 99-01.
Final Diablo Canyon RAIs
Final Diablo Canyon RAIs RAI # NEI EAL # DCPP EAL # Pg. # RAI Abnormal Radiation Levels/Radiological Effluent 5 RU1.1/RU1.2/ Why is the description of valid different than the definition given in RA1.1/RA1.2 Section 4.0?
6 AU1/AA1/AS1/AG1 RU1.1/RU1.2/RU1.3/ NEI 99-01 basis includes information regarding declaration if there RU1.4/RA1.3/RS1.4/ is an unknown release start time. Please include this information or RG1.3 justify its removal.
7 AU1 (EAL 2)/ RU1.1/RU1.2/ RU1.1 and RU1.2 meet the intent of AU1 EAL 1. RA1.1 and RA1.2 AA1 (EAL 2) RA1.1/RA1.2 meet the intent of AA1 EAL 1. AU1 EAL 2/AA1 EAL 2 is intended for licensees that have established effluent monitoring on non-routine release pathways. Please provide justification for not incorporating AU1 EAL 2/AA1 EAL 2.
8 AS1/AG1 RS1.1/RG1.1 Are there any other effluent monitors applicable besides those listed on table R-1?
9 AS1/AG1 RS1.1/RG1.1 Why was the language on PAG guidance removed from the basis?
10 AG1 RG1.1 Note 1 discusses escalation of the classification. What would it escalate to?
11 AU1 RU1.3 Why was the NEI 99-01 wording about unmonitored pathways left out of the basis?
12 AA1 RA1.2 The basis states that the magnitude of the release is escalated by a factor of 200 from the UE value. Isnt it escalated by a factor of 100 from the UE value, since the UE value is 2 times the limit?
Possible typo.
13 AA1 RA1.3 The basis talks about taking two samples. This is not in the NEI 99-01 basis and could cause delay. Please justify.
14 AU1/AA1/AS1/AG1 RU1.4/RA1.4/RS1.4/ The statement due to known or credible site release could cause RG1.3 delay in declaring this EAL if validation is required. If the reading is valid, why must the source be known? Please justify.
Final Diablo Canyon RAIs
Final Diablo Canyon RAIs RAI # NEI EAL # DCPP EAL # Pg. # RAI 15 AU1/AA1/AS1/AG1 RU1.4/RA1.4/RS1.4/ If a release is occurring that is unknown to the operators, how RG1.3 would this EAL be declared? These readings are not available in the Control Room. How would this EAL be declared by operators in the Control Room (especially for the UE and Alert since these would normally originate from the Control Room)?
16 AA2 RA2.2 Should a predictive value of impending fuel uncovery be used for visual observation? How can personnel visually observe uncovered fuel without serious health effects? Are cameras involved?
17 AA2 RA2.2 Why was the escalation text removed from the basis?
Comment AA3 RA2.3 Why is this EAL not numbered RA3.1 to stick with the DCPP numbering convention?
18 AA3 RA2.3 What about the secondary alarm system (SAS)?
Deleted AA3 RA2.3 Are maintain plant safety functions, as worded in the EAL, the same as, maintain safe plant operations or perform a safe plant shutdown, as worded in the basis?
Comment AA3 RA2.4 Why is this EAL not numbered RA3.2 to stick with the DCPP numbering convention?
20 AA3 RA2.4 Areas should be listed. Do areas needed for safe operation and safe shutdown change?
Cold Shutdown/Refueling System Malfunctions 21 CU3/CA3 CU1.1/CA1.1 Are all 3 vital buses included in the fault analysis?
22 CU3 CU1.1 EAL language about TS minimum diesel generators should be included to aid in differentiating it from the Alert.
23 CU2 CU2.1 Why are the values/methods for monitoring RCS level below the flange not included in the EAL itself (rather than in just in the basis)?
Final Diablo Canyon RAIs
Final Diablo Canyon RAIs RAI # NEI EAL # DCPP EAL # Pg. # RAI 24 CU2/CA1/CS1 CU2.2/CA2.1/CA2.2/ The basis discusses the use of surveillance procedures for CS2.1/CS2.2 calculating leak rate. How timely are the methods for identifying an unexplained increase?
25 CA1 CA2.1 It may not be appropriate to replace RCS inventory with Reactor Vessel level. Please justify.
26 CS2 CS2.3/CS2.4 Are there any other site specific indications (e.g., refuel floor ARM channel)?
Comment CG1 CG2.1 NEI 99-01 states less than TOAF for > 30 minutes, while the DCPP version separates the TOAF condition from its time dependence, which could lead to confusion during declaration.
27 CG1 CG2.1 The EAL lists containment pressure > 47 psig. Is this the same pressure value that should be used for declaration when freeze seals and nozzle dams are in use?
28 CU6 CU4.1 Do all the methods in Table C-2 comprise methods used by plant operations staff to perform routine tasks necessary for plant operations?
Particularly:
How do Unit 1, Unit 2, and TSC radio consoles, CAS and SAS consoles, mobile radios (do they always work inside the plant?),
satellite phones (do they always work inside the plant?), EOF engineering consoles, and the direct line to the County and State Office of Emergency Services apply to routine onsite communication methods?
How do the Operations radio system and hot shutdown panel radio consoles apply to routine offsite communication methods?
29 CU5 CU5.1 See EAL FAQ 2006-015. Will letdown always be in service during these operating modes? If letdown is not in service, how will this initiating condition be identified?
Final Diablo Canyon RAIs
Final Diablo Canyon RAIs RAI # NEI EAL # DCPP EAL # Pg. # RAI 30 CU5 CU5.2 See EAL FAQ 2006-015. Are TS LCO limits applicable in these operating modes? Isnt this condition bounded by RU EALs?
31 CU1 CU6.1 See EAL FAQ 2006-014. What about reduced inventory indications (NEI 99-01 basis)? Is quantifiable leakage detection possible when in cold shutdown?
32 CU8 CU7.1 Why has the language about Hot Standby and Hot Shutdown been added to the basis? This is potentially confusing.
33 CU8 CU7.1 Why has the basis been changed to remove the statement about inadvertent criticalities during reactor startups?
34 CU8 CU7.1 Why was the escalation text removed from the basis?
Fission Product Barrier Degradation 35 FC P-LOSS 1/ FC P-LOSS 1/ Provide specific examples of how an event would be over-classified RCS P-LOSS 1 RCS P-LOSS 1 if the phase and heat sink required was not included in the EAL.
36 RCS LOSS 4 N/A Before deleting this EAL, are their any possible alternatives to meet this IC (such as those proposed by other PWRs)?
37 CONT P-LOSS 3 CONT P-LOSS 2 What indicates that restoration procedures are effective? NEI 99-01 provides information in the basis and the submittal does not.
38 CONT P-LOSS 3 CONT P-LOSS 2 Why was the escalation text removed from the basis?
39 CONT P-LOSS 3 CONT P-LOSS 3 The basis defines the term effective but it is not consistent with the definition in the NEI 99-01 basis.
40 CONT P-LOSS 6 CONT P-LOSS 4 NEI 99-01 basis words about the declaration of a GE were left out.
Please justify.
41 CONT P-LOSS 6 CONT P-LOSS 4 The last sentence in the basis may be incorrect. Shouldnt this imply that all 3 barriers have been affected?
42 CONT LOSS 5 CONT LOSS 5 See EAL FAQ 2006-020 for approved wording.
Final Diablo Canyon RAIs
Final Diablo Canyon RAIs RAI # NEI EAL # DCPP EAL # Pg. # RAI 43 CONT LOSS 5 CONT LOSS 5 Amplifying information in the NEI 99-01 basis was not included in the DCPP basis. Please justify.
44 CONT LOSS 7 N/A What about containment venting?
Comment ALL FP JUDGEMENT ALL FP JUDGEMENT The words in each fission product barrier judgement EAL say loss EALS EALS or potential loss. Please edit so the EALs under the loss column and loss sections only reflects a loss and likewise for potential loss.
Hazards and Other Conditions Affecting Plant Safety 45 HU1 HU1.1 See EAL FAQ 2006-022.
46 HU1 HU1.2 The basis notes that wind speed recorders measure wind speeds.
Do these recorders show real-time indication or does the recorder show and time averaged indication?
47 HU1 HU1.3 The wording of this EAL might lead the reader to infer than only Table H-1 structures apply to this EAL, while the NEI 99-01 intent is for all structures or systems within the protected area. Please resolve.
48 HU1 HU1.3 Will the declaration be delayed to determine if the vehicle crash is hostile in nature?
49 HU1 HU1.3 The example that was added to the basis implies that the crash must be of concern to operators or cause sufficient damage. The intent of the EAL is tied to the potential for damage due to the size of the vehicle, not whether the vehicle actually caused the damage.
Please resolve.
50 HU1 HU1.4 Why was the escalation text removed from the basis of this EAL?
51 HU1 HU1.6 What is the low ocean water level value of concern? Can this value be reached during conditions other than a tsunami? What if a tsunami causes this condition and there was no prior warning?
Final Diablo Canyon RAIs
Final Diablo Canyon RAIs RAI # NEI EAL # DCPP EAL # Pg. # RAI 52 HA1 HA1.1 The EAL should be more descriptive to explain how the staff determines that the OBE has been exceeded. The EAL should describe alternative methods if the EFM is not operable rather than referring to a procedure (makes the EAL not stand-alone).
53 HA1 HA1.1 Where is the EFM located in the Control Room? Can any operator read the EFM, or does it require the seismic instrumentation system engineer? If it requires the engineer, is he/she on shift 24/7? See IN 2005-19.
54 HA1 HA1.1 The term magnitude in the first paragraph of the basis might be a poor choice of words since magnitude of damage could easily be confused with magnitude of the earthquake.
55 HA1 HA1.2 Why were the refueling water storage tank and condensate storage tank omitted from Table H-1?
56 HA1 HA1.2 The basis reads that Vital areas include structures that are in contact with or immediately adjacent to the areas that actually contains the equipment of concern. The EAL reads, damage to ANY Table H-1 plant structures/equipment, which are all vital areas. These two statements are contradictory, in that the EAL is more restrictive than the basis. Please resolve.
57 HA1 HA1.3 Will the declaration be delayed to determine if the vehicle crash is hostile in nature?
58 HA1 HA1.3 Why were the refueling water storage tank and condensate storage tank omitted from Table H-1?
59 HA1 (EAL 6) N/A Are there no conditions (ocean level, hurricane, etc.) that could meet the threshold for the alert?
60 HU2 HU2.1 The basis does not contain a reference to the EAL if the fire is determined to be hostile in nature.
Final Diablo Canyon RAIs
Final Diablo Canyon RAIs RAI # NEI EAL # DCPP EAL # Pg. # RAI 61 HU2 HU2.1 Will the declaration be delayed to determine if the fire is hostile in nature?
62 HU1 HU2.2 Will the declaration be delayed to determine if the explosion is hostile in nature?
63 HU1 HU2.2 The basis states that a steam line break that causes damage is also classified under this EAL. Why is this condition not listed in the EAL itself?
64 HA2 HA2.1 Will the declaration be delayed to determine if the explosion is hostile in nature?
65 HA2 HA2.1 How can safety system parameter symptoms degrade? Wording has been changed from the NEI 99-01 basis and may change the meaning.
66 HA2 HA2.1 NUMARC/NESP-007 Questions and Answers are not valid for NEI 99-01. Only approved NEI 99-01 EAL FAQs are valid. The single pump criteria should be stricken from the basis.
67 HA2 HA2.1 The basis states that a steam line break that causes damage is also classified under this EAL. Why is this condition not listed in the EAL itself?
68 HU3/HA3 HU3.1/HA3.1 Refer to EAL FAQ 2006-023. Asphyxiant gases are also of concern and should be listed in the IC, the EAL, and the basis.
69 HU3/HA3 HU3.2/ HA3.2 Refer to EAL FAQ 2006-023. Asphyxiant gases are also of concern and should be listed in the IC and the basis.
70 HA3 HA3.1/HA3.2 The basis lists a reference related to seismic analysis. Is this meant to be included in the references for this EAL?
71 HU4 HU4.1 NEI 99-01 states that consideration should be given to civil disturbance and strike action; however, it is unclear how those are being addressed by this EAL. Please clarify.
Final Diablo Canyon RAIs
Final Diablo Canyon RAIs RAI # NEI EAL # DCPP EAL # Pg. # RAI 72 HA4/HA7/HA8 HA4.1 NEI HA4 and HA7/HA8 should not be combined. They do not share the same Initiating Condition and therefore are inappropriate to combine. HA4 describes security events within the PA, while HA8 describes hostile action within the OCA - which are two different concepts for two different plant locations. This difference could cause confusion in determination. Any changes made to security EALs from NEI 99-01 should follow the bases provided in Bulletin 2005-02.
73 HA4/HA7/HA8/HS1/H HA4.1/ HS4.1 Should the specific aircraft types be listed in this document?
S4 74 HS1/HS4 HS4.1 NEI HS1 and HS4 should not be combined. They do not share the same Initiating Condition and therefore are inappropriate to combine. HS1 describes security events within the VA, while HS4 describes hostile action within the PA - which are two different concepts for two different plant locations. This difference could cause confusion in determination. Any changes made to security EALs from NEI 99-01 should follow the bases provided in Bulletin 2005-02.
75 HS1/HS4 HS4.1 Why was site security force in NEI HS4 changed to Security Watch Commander in HS4.1 threshold #2?
76 HG1 HG4.1 The statement added about DCPP Safeguards Contingency Plan does not seem appropriate for this EAL. While the plan may contain guidance, as stated in the basis, the declaration of the EAL is not contingent upon a determination/report from the Security Watch Commander. The way this reads, only she/he has the capability to declare this EAL. Please justify this change if that is the intent.
77 HG1 HG4.1 How would the Spent Fuel Pool condition be declared without addition information in the EAL and not just the basis?
Final Diablo Canyon RAIs
Final Diablo Canyon RAIs RAI # NEI EAL # DCPP EAL # Pg. # RAI System Malfuctions 78 SU1 SU1.1 EAL language about TS minimum diesel generators should be included to aid in differentiating it from the Alert.
79 SU1/SA1/SS1/SG1 SU1.1/SA1.1/SS1.1/ Are all 3 vital buses included in the fault analysis?
SG1.1 80 SA2 SA2.1 Manual actions should only receive credit if they are from the reactor control console. The last sentence of the basis states this but appears contrary to the EAL itself. Please resolve.
81 SA2 SA2.1 Are the control room electrical panels for de-energizing the 480V buses 13D and 13E on the reactor control console? If not, they do not appear to satisfy this EAL.
82 SA2 SA2.1 Is actuation of the AMSAC logic achieved at the reactor control console panels?
83 SS2/SG2 SS2.1/SG2.1 Manual actions should only receive credit if they are from the reactor control console. The wording in the EAL and the basis is inconsistent. Please resolve.
84 SS2 SS2.1 The last paragraph of the basis is not consistent with Section 2.8 (page 8) of the document. This paragraph is only true if actions at the reactor control console caused the decrease in reactor power.
If action is taken away from the reactor control console to shutdown the reactor, this EAL is still applicable due to the gross failure of RPS.
Comment SG2 SG2.1 The words (initiated from the Control Room) are not needed in the EAL itself at the GE level. If any method was successful in shutting down the reactor, conditions wouldnt warrant a GE.
Final Diablo Canyon RAIs
Final Diablo Canyon RAIs RAI # NEI EAL # DCPP EAL # Pg. # RAI 85 SG2 SG2.1 The next to last paragraph of the basis is not consistent with Section 2.8 (page 8) of the document. This paragraph is only true if actions at the reactor control console caused the decrease in reactor power. If action is taken away from the reactor control console to shutdown the reactor, this EAL is still applicable (if accompanied by either Core Cooling - Red or Heat Sink - Red) due to the gross failure of RPS.
86 SS4 SS3.1 The basis states that CSFST Core Cooling RED and Heat Sink RED are indicative of this EAL condition. If these are the indicators, why are they not in the EAL itself?
87 SU3 SU4.1 NEI states that recognition of the availability of computer-based indication equipment is considered; however, the DCPP basis states that computer-based monitoring capability is not a factor at the UE level. Please resolve.
Comment SU6 SU4.2 Due to the long Table, the mode applicability slipped to the second page. For clarity, it should be kept on the first page.
88 SU6 SU4.2 Do all the methods in Table C-2 comprise methods used by plant operations staff to perform routine tasks necessary for plant operations? Particularly:
How do Unit 1, Unit 2, and TSC radio consoles, CAS and SAS consoles, mobile radios (do they always work inside the plant?),
satellite phones (do they always work inside the plant?), EOF engineering consoles, and the direct line to the County and State Office of Emergency Services apply to routine onsite communication methods?
How do the Operations radio system and hot shutdown panel radio consoles apply to routine offsite communication methods?
Final Diablo Canyon RAIs
Final Diablo Canyon RAIs RAI # NEI EAL # DCPP EAL # Pg. # RAI 89 SA4 SA4.1 The basis paragraph that begins, If both a major, includes a condition to the extent that additional operating personnel are required to monitor indications. This condition is not consistent with NEI 99-01 and changes the intent of the declaration.
90 SS6 SS4.1 What does ALL critical safety function status include? Is using ALL too limiting or ambiguous in what it includes? By combining the second and third NEI EAL conditions into one DCPP condition, it might reduce clarity of what operators are checking for before declaring this emergency. Reducing reading burden might be offset by increasing thought burden.
Comment SS6 SS4.1 Moving the Significant transient is in progress EAL to the top of the list might add clarity in differentiating it from the similar Alert EAL.
91 SU4 SU5.1 How is this condition recognized during operation (i.e., is this EAL operationally significant)? Will letdown always be in service during these operating modes? If letdown is not in service, how will this initiating condition be identified?
Final Diablo Canyon RAIs