ML091180283

EAL Request for Additional Information

ML091180283
Person / Time
Site:	Turkey Point
Issue date:	02/26/2009
From:	Siva Lingam, Jason Paige Plant Licensing Branch II
To:	Tomonto B Florida Power & Light Co
Lingam, Siva NRR/DORL 415-1564
References
TAC MD9924, TAC MD9925
Download: ML091180283 (9)

Text

EAL draft RAIs.txt From: Jason Paige Sent: Thursday, February 26, 2009 2:15 PM To: Bob_Tomonto@fpl.com Cc: Siva Lingam

Subject:

EAL draft RAIs Attachments: Turkey Point_EAL_Upgrade_RAIs - DRAFT.DOC Bob, attached are the draft RAIs for the EAL submittal. Please review and notify me when TP is ready to discuss with the NRC.

Thank you, Jason Received: from HQCLSTR02.nrc.gov ([148.184.44.77]) by TWMS01.nrc.gov

([148.184.200.145]) with mapi; Thu, 26 Feb 2009 14:15:29 -0500 Content-Type: application/ms-tnef; name="winmail.dat" Content-Transfer-Encoding: binary From: Jason Paige <Jason.Paige@nrc.gov>

To: "Bob_Tomonto@fpl.com" <Bob_Tomonto@fpl.com>

CC: Siva Lingam <Siva.Lingam@nrc.gov>

Date: Thu, 26 Feb 2009 14:15:27 -0500

Subject:

EAL draft RAIs Thread-Topic: EAL draft RAIs Thread-Index: AcmYRpV3YPIQ/qd0SHSgFd0Za8VRJA==

Message-ID: <DC2088DF7F51A8499309AA4A35D0C1E01CEF81AF1B@HQCLSTR02.nrc.gov>

Accept-Language: en-US Content-Language: en-US X-MS-Has-Attach: yes X-MS-Exchange-Organization-SCL: -1 X-MS-TNEF-Correlator: <DC2088DF7F51A8499309AA4A35D0C1E01CEF81AF1B@HQCLSTR02.nrc.gov>

MIME-Version: 1.0 Page 1

Turkey Point NRC Request for Additional Information (RAI)

DRAFT 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 of the EAL scheme by enforcing the expectation that licensees adhere to NRC reviewed and endorsed guidance with no non-design related deviations and little to no differences.

GENERIC This also ensures that, as stated in 10 CFR 50.47(b)(4), licensees implement a standard emergency classification and action level scheme.

While the NRC is not enforcing strict verbatim compliance with the endorsed guidance, where applicable, the NRC will be pointing out areas where we expect compliance with the endorsed guidance to ensure implementation of a standard scheme. This is primarily based upon industry and NRC experience with issues related to the particular EAL.

Staff has noted discrepancies between the proposed Bases Information BASES wording and the endorsed Bases Information wording. Incorporate the INFORMATION endorsed wording to ensure a standard emergency classification and action level scheme or provide detailed justification for not doing so in each case.

DRAFT Page 1

Turkey Point NRC Request for Additional Information (RAI)

DRAFT RAI EAL Question

1. Add the Fission Barrier Matrix to the list of discretionary EALs found in the last paragraph dealing with multiple events and emergency class upgrading.

2. Follow the expectations as stated in the endorsed guidance to ensure a standard emergency classification and action level scheme or provide detailed justification for not doing so in each case. All of the parts of Attachment 6 are, for the most part, inconsistent with the endorsed guidance. Use the endorsed guidance, or provide additional information to support the staffs consideration of these deviations. For consistency, it is expected that licensees adopt the intent, if not the exact wording, of the endorsed guidance for all of Attachment 6.

1 ATT. 6

3. The 3rd paragraph of the Multiple Events section requires additional justification to support the deviation. Explain how the regulatory requirements would be met if one unit is at a GE when the other unit meets the criteria for a GE (separate events); how would this be declared and how would a classification downgrade for the unit that declared the GE impact the unit that still meets the criteria for a GE but never actually declared it?

4. This attachment is inconsistent with Sections 3.10, 3.11, and 3.12. Explain the inconsistency or revise to ensure a standard emergency classification and action level scheme or provide detailed justification for not doing so in each case.

2 SECT 3.5 Incorporate information from NEI 99-01 R5 related to the digital I&C example.

The first paragraph is not in accordance with NEI 99-01 R5. Remove this paragraph and replace it with the 1st paragraph of Section 3.9 from NEI 99-01 3 SECT 3.9 R5 to ensure compliance with the standard emergency classification and action level scheme.

1. Add the definition for Extortion, Hostage, Intrusion, Sabotage, and Strike Action to ensure compliance with the standard emergency classification and action level scheme.

2. Is the term power block defined in your FSAR? In addition, this term is too all encompassing for effective use in the EALs. In addition, this term 4 SECT. 5.2 appears to be inconsistently used throughout the document. Staff expects area determination to be consistent with the endorsed guidance without adding any other areas that may lead to unnecessary EAL declarations.

3. For the terms Containment Closure Protected Area, and Vital Areas, use your site-specific definition, not the generalized wording from NEI 99-01 R5.

SECT 5.3 5 Incorporate Section 5.3 from NEI 99-01 R5 to ensure adequate understanding.

(NEI)

DRAFT Page 2

Turkey Point NRC Request for Additional Information (RAI)

DRAFT Add 3rd paragraph from endorsed EAL basis to ensure compliance with the 6 RU1 standard emergency classification and action level scheme.

1. Value and time in RA1.3 is incorrect; it should be 200 times and 15 minutes, please correct this error. The justification matrix you provided has the correct information.

2. Add 3rd paragraph from endorsed EAL basis to ensure compliance with the standard emergency classification and action level scheme.

7 RA1 3. For PRMS-R-14, PRMS-3(4)-R-15, PRMS R-18 and PRMS-3(4)-R-19:

How do you differentiate between Off scale High and instrument failure?

4. RAI values are expected to be 100X greater than the RU1 values. Explain why this is not the case for your RU1/RA1. Either correct the values or ensure the IC wording is consistent with how you plan to implement these EALs.

Explain why you added the TSC and SAS? Are these areas requiring continuous occupancy that, if evacuated, would impede operation of systems 8 RA3 required to maintain plant safety functions or perform a safe shutdown? Fully justify their inclusion or remove to ensure compliance with the standard emergency classification and action level scheme.

RS1 For PRMS-R-14 and PRMS-3(4)-R-15: How do you differentiate between Off 9

RG1 scale High and instrument failure?

Add the endorsed information related to relief valves to ensure compliance with 10 CU1 the standard emergency classification and action level scheme.

1. The threshold numbering goes from (1), to (1), to (2). Please explain the numbering convention used for this EAL, or revise the apparent error. In addition, the Bases information will need to be revised accordingly.

11 CU2

2. Use the wording from the endorsed guidance in the Bases information, particularly paragraph 2, to ensure compliance with the standard emergency classification and action level scheme.

Use the wording from the endorsed guidance in the Bases information to 12 CU3 ensure compliance with the standard emergency classification and action level scheme.

Remove the word Unplanned from threshold 2 to ensure compliance with the 13 CU4 standard emergency classification and action level scheme.

CU6 Is the LGR system a viable method for communicating with the NRC? If not, 14 SU6 justify its inclusion on this list or remove it.

DRAFT Page 3

Turkey Point NRC Request for Additional Information (RAI)

DRAFT

1. Remove the word Unplanned from the IC to ensure compliance with the standard emergency classification and action level scheme.

15 CU7 2. How was ANY 2 determined to be an acceptable alternative to the expectation that the site-specific busses be listed? Justify or revise accordingly to ensure compliance with the standard emergency classification and action level scheme.

1. The expectation is to adhere to the defined EAL threshold as defined in the endorsed guidance for CA4.1. Justify why consideration should be given for the proposed deviation or revise to ensure compliance with the 16 CA4 standard emergency classification and action level scheme.

2. Is the 10-psi value in CA4.2 within the calibrated range of the instrumentation used in these operating modes? What are the scale markings for these indicators?

Verify that the stated level values are equivalent to the expected values from the endorsed guidance. Specifically address the values and the indicators 17 CS1 stated, in particular, explain why the EAL thresholds are limited to specific indicators.

1. The expectation is for the value in CG1.1a to be the same as CS1.2.

Explain why consideration should be given for this deviation from the standard emergency classification and action level scheme as endorsed.

2. Explosive mixture in containment is an expected criterion for indications of containment challenges. Explain, in greater detail, why consideration should be given for this deviation. Your justification (Att 14) stated that the exemption would be handled separately; however, the staff cannot find this 18 CG1 exemption. In addition, the stated amendment changed the equipment classification to RG 1.97 Cat 3 (from Cat 1), but does not allude to this equipment being unavailable. In addition, pg 2 of the Safety Evaluation (paragraph 4) still states the basis for the H2 monitors (ADAMS Accession No. ML013550500). In summary, the staff finds no regulatory basis for allowing this deviation, please provide more detailed explanation to justify its exemption, or revise to ensure compliance with the standard emergency classification and action level scheme.

DRAFT Page 4

Turkey Point NRC Request for Additional Information (RAI)

DRAFT

1. The note at the bottom of the IC Matrix is not needed if the logic flow diagram is implemented at the site.

2. For Cont Barrier PL2: Explosive mixture in containment is an expected criterion for indications of containment challenges. Explain, in greater detail, why consideration should be given for this deviation. Your justification (Att 14) stated that the exemption would be handled separately; however, the staff cannot find this exemption. In addition, the stated amendment changed the equipment classification to RG 1.97 Cat 3 (from Cat 1), but does not allude to this equipment being unavailable. In addition, pg 2 of the Safety Evaluation (paragraph 4) still states the basis for the H2 monitors (ADAMS Accession No. ML013550500). In summary, the staff finds no regulatory basis for allowing this deviation, please provide more detailed explanation to justify its exemption, or revise to ensure compliance with the standard emergency classification and action level scheme.

3. For RCS Barrier PL1: Explain why maximum charging is equivalent to one charging pump, or revise to ensure compliance with the 19 FB MATRIX standard emergency classification and action level scheme.

4. For Fuel Clad Barrier PL1: This level seems inconsistent with other EAL thresholds that use a value equivalent to TOAF. Explain the inconsistency or revise all applicable thresholds to ensure compliance with the standard emergency classification and action level scheme.

5. Provide more justification to explain why you do not have any thresholds for #7 (from the endorsed guidance). It is expected that licensees adopt thresholds that equate to loss or potential loss of the applicable fission barrier. The endorsed guidance intends for licensees to provide other indicators here, or provide additional justification detailing the considerations that went into the decision to not add additional indicators.

6. For RCS Barrier PL1 bases: Incorporate the language from the endorsed guidance to ensure compliance with the standard emergency classification and action level scheme.

7. For Cont Barrier PL2, L2, and language for #4 bases: Incorporate the language from the endorsed guidance to ensure compliance with the standard emergency classification and action level scheme.

1. HU1.1: Explain how the first criteria would work to ensure a timely EAL declaration. Is this available in the control room without any operator/technician interaction?

2. HU1.2: Is 145 mph within the calibrated range of the instrumentation used to measure wind speed?

20 HU1

3. Where is the internal flooding threshold? Provide additional justification for its removal, or revise to ensure compliance with the standard emergency classification and action level scheme.

4. The bases information for threshold #4 needs to be specific to your site, not a regurgitation of the generic information from the endorsed guidance.

DRAFT Page 5

Turkey Point NRC Request for Additional Information (RAI)

DRAFT

1. Add the note from the endorsed guidance to ensure compliance with the standard emergency classification and action level scheme.

21 HU2

2. See RAI related to use of the term power block and justify its use in this EAL.

Add the note from the endorsed guidance to ensure compliance with the 22 HU4 standard emergency classification and action level scheme.

1. HA1.1: Explain how the first criteria would work to ensure a timely EAL declaration. Is this available in the control room without any operator/technician interaction? Where is the wording related to indication of degraded performance? Provide additional justification for its removal, or revise to ensure compliance with the standard emergency classification and action level scheme.

2. HA1.2: Is 145 mph within the calibrated range of the instrumentation used to measure wind speed?

3. HA1.3: Explain why you did not use the term Vital Areas as expected from the endorsed guidance. If sufficient justification is given to allow the staff to reach a similar conclusion, explain why these are the only two areas listed for this threshold, particularly given the bases for the threshold as defined 23 HA1 in the endorsed guidance.

4. HA1.4 and HA1.5: See RAI related to use of the term power block and justify its use in this EAL.

5. Explain in greater detail why a threshold for turbine failure is not provided in this EAL or revise to ensure compliance with the standard emergency classification and action level scheme.

6. The bases numbering is inconsistent with the actual EAL numbering, correct the discrepancies. In addition, the bases information uses the term vital areas whereas the actual threshold uses power block, correct the discrepancies (staff prefers the use of the term vital areas to ensure consistency in implementation of the endorsed guidance, however, licensees can provide justification for the deviation for staff review).

1. See RAI related to use of the term power block and justify its use in this EAL.

24 HA2 2. The expectation is for a specific list of areas this EAL would be applicable to. Justify the deviation or revise to ensure compliance with the standard emergency classification and action level scheme.

1. While the use of the term vital areas meets the staffs expectations, it does highlight the inconsistency in the use of this term versus power block in the proposed EAL scheme.

2. Add the note from the endorsed guidance to ensure compliance with the 25 HA3 standard emergency classification and action level scheme.

3. Add paragraphs #3 and #4 from the endorsed guidance to ensure compliance with the standard emergency classification and action level scheme.

DRAFT Page 6

Turkey Point NRC Request for Additional Information (RAI)

DRAFT

1. Add the note from the endorsed guidance to ensure compliance with the standard emergency classification and action level scheme.

26 HA4 2. Incorporate the bases wording from the endorsed guidance for threshold

1. 1 to ensure compliance with the standard emergency classification and action level scheme.

1. Incorporate the bases information from the endorsed guidance into paragraph #1.

27 HS2

2. Explain how Emergency Coordinator equates to ED as stated in the 4th paragraph of the bases.

28 ALL S ICS The header is incorrect for all the S Initiating Conditions, correct the errors.

1. Provide additional justification for the removal of thresholds/bases information related to indication as this is an expectation from the endorsed guidance.

SU3

2. Incorporate the rest of the bases information from the endorsed guidance 29 SA4 to ensure compliance with the standard emergency classification and SS6 action level scheme.

3. [SA4/SS6 only] Why define significant transient in the Definitions section, then define it again in this EAL?

1. In order to ensure consistency and compliance with 10 CFR 50.47(b) (4) for a standard emergency classification and action level scheme provide additional justification to support the deviations in this EAL, including the bases wording. In particular, justify why you do not use the term reactor control console, or the equivalent for your site. It is not the expectation to allow all action(s) in the control room to suffice for this EAL.

SA2 Incorporate the wording from the endorsed guidance, or provide additional 30 justification to support the staffs consideration of this deviation.

SS2

2. Provide more information related to the suitability of CSF Status Tree Subcriticality - Red Conditions Met and why you feel it is acceptable for use in this EAL.

3. Incorporate the rest of the bases information from the endorsed guidance to ensure compliance with the standard emergency classification and action level scheme.

1. Explain why you use the term station blackout in the IC and unit blackout in the EAL.

2. Explain why you incorporated guidance related to SBO crossties in this EAL and not in SU1, what procedure controls this crosstie activity, and why 31 SA5 is it not referenced in this EAL.

3. Incorporate the rest of the bases information from the endorsed guidance to ensure compliance with the standard emergency classification and action level scheme.

DRAFT Page 7

Turkey Point NRC Request for Additional Information (RAI)

DRAFT Explain why you incorporated guidance related to SBO crossties in this EAL 32 SS1 and not in SU1, what procedure controls this crosstie activity, and why is it not referenced in this EAL.

The 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for buss restoration is higher than the typical time frame for this 33 SG1 EAL. Provide additional justification for the acceptability of this value in this EAL.

Paragraphs #2 and #3 in the bases section is not applicable for this EAL and 34 SG2 needs to be removed to ensure compliance with the standard emergency classification and action level scheme.

DRAFT Page 8