ML082960642

EAL - RAIs

ML082960642
Person / Time
Site:	Davis Besse
Issue date:	10/22/2008
From:	Office of Nuclear Reactor Regulation
To:	FirstEnergy Corp
Sands, S, NRR/DLPM/PD3-2, 415-3154
Shared Package
ML082960663	List: ML082960198 ML082960642
References
Download: ML082960642 (2)

Text

Davis-Besse NRC Request for Additional Information (RAI)

RAI # EAL Question It is expected that licensees adhere to endorsed guidance, particularly for Initiating Conditions and Definitions, with no differences or deviations other than those related to a licensees particular design. This is to ensure regulatory stability by enforcing the expectation that licensees adhere to NRC reviewed GENERIC and endorsed guidance with no non-design related deviations and little to no differences. While the NRC is not proposing verbatim compliance with the endorsed guidance, where applicable, the NRC will be pointing out areas where we expect compliance with the endorsed guidance. This is primarily based upon industry and NRC experience with issues related to the particular EAL.

1. Explain why you deviated from the endorsed guidance by not including a definition for extortion, sabotage, or security condition, or incorporate 1 DEFINITIONS the definitions as expected.

2. The site definition of large aircraft is considered potential official use only (OUO) by the NRC and is not to be incorporated into the EAL scheme.

It is expected that the EAL related to ISFSI be incorporated using a separate numbering convention. The endorsed guidance uses E-HU1, but EU1 has 2 ISFSI, HU6 been found acceptable at other utilities. Please explain why this deviation is necessary.

ST PAGE 5, 1 This is a deviation from endorsed guidance. Please explain why this deviation 3

PARAGRAPH is necessary or follow endorsed guidance.

FISSION 4 Does your site use Critical Function Status Trees?

BARRIER FUEL CLAD, Please explain why low level AND high temperatures are needed for this 5 POTENTIAL barrier? As high temperature is already considered in the FB matrix, this LOSS appears redundant and unnecessary.

RG1, RS1, RA1, RU1, HU4, SS1, SA1, SU1, Add the timing notes from the endorsed guidance or explain their omission.

SS2, SS4, These were added due to the numerous issues related to licensees 6 SA4, SU4, understanding the NRCs expectations related to the timeliness of EAL CA1, CU1, declarations.

CU2, CG7, CS7, CA7, CU7, CU8, CU10 Please explain how you will address CDE Thyroid for adults.

7 RG1, RS1 This question was answered via telecon between NSIR reviewer D.Johnson and Davis-Besse licensing, dated 10/15/2008 using actual meteorology in the IC is a deviation from the endorsed 8 RS1 guidance. Please explain the deviation or follow the endorsed guidance.

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Davis-Besse NRC Request for Additional Information (RAI)

RAI # EAL Question Please explain how EAL decision-makers will be able to differentiate between 9 RA1 top of scale as an EAL entry condition versus failed instrumentation.

You included site specific information as to why CAS is on the list but did not mention that maintaining access through site doors and security barriers is the 10 RA3 basis for CAS being on this list. This may lead to misconceptions as to the intent of the EAL. Please explain why this was not incorporated or revise to reflect the above information.

Please explain why you deviated from endorsed guidance and added potentially official use only information to the EAL by stating large aircraft 11 HA1 instead of airliner. While the term does not create a potential OUO issue directly in the EAL, its use led to it being defined, which leads to the potential OUO.

The term security condition was developed by a joint EP-Security industry team to better align EALs with the upcoming revision to site security 12 HU1 contingency plans via a revision to NEI 03-12. This term is important to this needed alignment. Please explain the deviation or revise to follow endorsed guidance.

HA3, HU3, Please explain why your diesel generator room(s) are not considered a safe 13 HA4, HU4 shutdown vital area.

You stated For the purposes of declaring an emergency event, the term extinguished means no visible flames. Explain why excessive smoke or 14 HU4 other indications of a possible fire are not included as a discriminator for defining when a fire is extinguished.

15 SA1, SA3 Please explain the deviation in the IC or revise accordingly.

Please elaborate as to what controls area means. Is this synonymous with 16 SS3 the reactor control console?

Please explain the deviation of not adding the expected EAL 1b or add 17 SA3 accordingly.

The expectation for the logic is an or or either. Please elaborate on why SS4, SA4, 18 consideration must be given to endorse a new EAL scheme or revise SU4 accordingly.

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