ML092150378
| ML092150378 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/05/2009 |
| From: | Lyon C Plant Licensing Branch IV |
| To: | Minahan S Nebraska Public Power District (NPPD) |
| Lyon C Fred, NRR/DORL/LPL4, 301-415-2296 | |
| References | |
| TAC ME0849 | |
| Download: ML092150378 (9) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 5, 2009 Mr. Stewart B. Minahan Vice President-Nuclear and CNO Nebraska Public Power District 72676 648A Avenue Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - REQUEST FOR ADDITIONAL INFORMATION RE: EMERGENCY ACTION LEVEL CHANGES (TAC NO. ME0849)
Dear Mr. Minahan:
By letter dated February 26,2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML090700408), to the U.S. Nuclear Regulatory Commission (NRC),
Nebraska Public Power District submitted a request for approval to adopt revised Emergency Action Level documents based on Nuclear Energy Institute (NEI) 99-01, Revision 5, for use in the Cooper Nuclear Station Emergency Plan. Your request was submitted in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(q).
The NRC staff is reviewing your submittal and has determined that additional information is required to complete its review. The specific information requested is addressed in the enclosure to this letter and was provided to Mr. D. Van Der Kamp of your staff on August 3, 2009. Please provide a response by September 25, 2009, to this request for additional information.
The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at 301-415-2296.
Sincerely, Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-298
Enclosure:
As stated cc w/encl: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION (RAI)
EMERGENCY ACTION LEVEL (EAL) CHANGES COOPER NUCLEAR STATION (CNS)
DOCKET NO. 50-298 RAI# SECTION Question Note that it is the NRC staff's expectation that licensees adhere to the NRC-endorsed guidance in Nuclear Energy Institute (NEI) 99-01, Revision 5, particularly for Initiating Conditions and Definitions, with no differences or deviations other than those related to a licensee's particular design. This expectation will serve to create regulatory stability regarding EAL schemes.
While compliance with the endorsed guidance is not a requirement, where applicable, the NRC staff will be pointing out areas where GENERIC compliance with the endorsed guidance is expected to ensure implementation of a standard scheme. This is primarily based upon industry and NRC experience with issues related to the particular EAL.
While formatting is usually not technically relevant to the staff's review of EALs, when inconsistent formatting may result in a potential misunderstanding, an RAI will be developed to identify the potential problem so that the licensee may correct the formatting or provide clarification.
Please discuss why the following sections are not included in CNS EAL Technical Bases consistent with NEI 99-01, Revision 5, and revise the technical bases as appropriate:
- 3.2 - Definitions used to develop EAL Methodology (e.g.,
Emergency Classification Level and Initiating Condition)
GENERAL EAL
- 3.3 - Differences in Perspective TECHNICAL
- 3.5 - Design Differences (particularly the discussion pertaining 1
BASES to Digital I&C)
DISCUSSION
- 3.6 - Required Characteristics
- 3.7 - Emergency Classification Level Descriptions
- 3.10 - Treatment of Multiple Events and Classification Level Upgrading
- 3.11 - Emergency Classification Level Downgrading Enclosure
-2 RAI# SECTION Question Verify that all stated values, set points, and indications provided in 2 GENERAL the EAL Technical Bases are within the calibrated range of the applicable instrumentation.
Incorporate the term "VALID" into Initiating Conditions (ICs) and AU1.1, AA1.1, EALs as stated in the endorsed guidance such that the likelihood of AS1.1, AG1.1, 3 classifying an event due to false readings or indications would be AU1.2, AU2.1, minimized, or provide additional justification as to why the AU2.2, AA2.1 incorporation is not needed.
Provide a statement to clarify that the CNS EAL Technical Bases 4 1.0 will be controlled pursuant to 10 CFR 50.54(q), or justify why the statement is not needed.
- 1. Explain why the definition of "DEFUELED" is not consistent with the endorsed guidance.
5 2.8
- 2. Explain why paragraph 2, section 3.13, of the endorsed guidance was not incorporated into the CNS EAL submittal.
Multiple versions of NEI 99-01, Revision 5, are available in ADAMS and are not the endorsed version. Please clarify that your reference 3.1.1 is ADAMS Accession No. ML080450149, which 6 3.1 corresponds to the endorsed revision of NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels,"
February 2008.
Provide a definition of Explosion consistent with endorsed guidance 7 4.0 such that it takes into account the failure of pressurized and energized equipment or justify the deviation.
Explain the following inconsistencies with the CNS to NEI EAL cross-reference table:
8 5.0
The cross-reference should be NEI 99-01, IC AA 1, EAL 3.
The cross-reference should be NEI99-01, IC AS1, EAL 4.
-3 RAI# SECTION Question
- 1. Explain why additional EAL criteria (e.g., Effluent discharge is not isolated) is necessary when criteria is incorporated into 9 AU1.2, AA1.2 Table A-1.
- 2. Explain how the additional criteria stated above is applicable to Service Water Effluent.
Explain why the bases discussion for these EALs does not 10 AA1.1, AA1.2 incorporate the bases discussion in the endorsed guidance.
Explain why the discussion regarding "...any release for which a radioactivity discharge permit was not prepared, or a release that 11 AA1.3 exceeds the conditions ...on the applicable permit," consistent with endorsed guidance, was not incorporated into EAL bases discussion.
AS1.1, AS1.2, Discuss whether or not the definition of Site Boundary provided in AS1.3, AG1.2, the EAL bases discussion is consistent with the definition of Site 12 AG.1.3, HA6.1, Boundary as stated in the CNS Updated Safety Analysis Report HS6.1, HG6.1 (USAR).
AS1.3, AG1.3 Explain why the timing note pertaining to "Emergency Director 13 CS2.1, CS2.2, declaration of event. .." was not incorporated into EALs consistent CU3.1, HU2.2, with the endorsed guidance.
The phrase "or by survey" included in the EAL criteria adds an additional condition to the EAL which could impact the timeliness of 14 AU2.1 emergency declaration. Explain why the phrase "or by survey" was added to the EAL and discuss the specifics surrounding the survey to be performed (e.g., type of survey, frequency, etc.).
Explain why the transfer canal was not included in this EAL 15 AA2.2 consistent with endorsed guidance.
A different IC title should require a different IC number, per the endorsed guidance. While combining some ICs/EALs may be AA2.3, CU1.2, acceptable, the IC wording should be consistent for all ICs using 16 CU2.2, CU2.3, the same core number (e.g., AA2.x). Please justify the numbering SS1.2, SU4.2 convention proposed by CNS or revise it to ensure implementation of a standard emergency classification and action level scheme by using the endorsed guidance wording and numbering approach.
- 4 RAI# SECTION Question
- 1. Explain whether or not the list of site-specific areas requiring continuous occupancy to maintain plant safety functions is consistent with the list provided in the CNS USAR.
- 2. The Main Control Room (CR) and Central Alarm Station (CAS) 17 AA2.3 are listed as areas requiring continuous occupancy to maintain plant safety functions. The CR is identified with an associated area radiation monitor, however the CAS is not. Explain how radiation dose rates will be monitored in the CAS if it requires continuous occupancy to maintain plant safety functions.
CU1.1, CA1.1, Discuss whether the 15-minute backfeed timing note and reference 18 SU1.1, SA1.1, to it being considered as an offsite power source is significant SS 1. 1, SG 1.1 enough such that it should be included as a note to the EAL.
Discuss how an Operator would be able to determine whether L1-86 19 CU 2.2 is calibrated for normal or elevated conditions.
Are there any site-specific tank level indications that could be CU 2.3, CA2.1, 20 included in Table C-1? If so, please discuss why they have not CS2.3, CG2.2 been included.
Discuss why Table C-1 is inconsistent with the Table C-1 included CA 2.1, CS2.3, 21 in other ICs and EALs (e.g., CA2.1 lists 'Suppression Pool' water CG2.2 level rise versus CU2.3 lists 'Torus' water level rise).
Provide additional justification as to why the CHARMS cannot be 22 CS2.3, CG2.2 used as an indicator for these EALs. Include discussion in the associated EAL Technical Bases.
- 1. Discuss why the wording, "with containment challenged," after the first sentence in the EAL technical bases was not included in the bases discussion as per the endorsed guidance.
23 CG 2.1 2. Discuss why the wording, "... is re-established prior to exceeding the 30 minute core uncover time limit. .." was not included in the last sentence, fourth paragraph, of the EAL bases discussion consistent with endorsed guidance.
Discuss why the wording, "is re-established prior to exceeding the 30 minute core uncover time limit. .. ," was not included in the last 24 CG 2.2 sentence, seventh paragraph, in the EAL bases discussion consistent with endorsed guidance.
-5 RAI# SECTION Question Discuss why the bases discussion regarding the "redundant means of RPV level indication" and "loss of all level and temperature 25 CU 3.1 indication" was not included in the NEI 99-01 EAL bases discussion, second to last paragraph, consistent with the endorsed guidance.
Discuss why the term UNPLANNED was not included in the IC 26 CU 3.2 consistent with endorsed guidance.
27 CA 3.1
- 2. Is the reference in paragraph 6 correct (e.g., Escalation to SA would be via CS1.1), or should it be CS2.1?
- 1. Discuss whether the CNS State Notification Telephones are available to notify the NRC in the event of an emergency declaration and all other means of offsite communication are unavailable. Include explanation in CNS Bases discussion.
- 2. Discuss whether the Microwave Telephone Network is available 28 CU4.1, SU4.2 to notify State and local authorities, as well as the NRC. Include explanation in CNS Bases discussion.
- 3. Discuss whether there are any other onsite or offsite communication systems that should be included in Table C-2, Communication Systems (e.g., Sound Powered Phone System - onsite; National Warning System in CR offsite).
Please add "... Other Conditions Affecting Plant Safety" to the 29 H recognition category title consistent with the endorsed guidance, or justify why it should not be added.
Discuss the timeliness associated with retrieving information from 30 HU1.1, HA1.1 the SMA-3 Strong Motion Accelograph relative to declaring the EAL.
Are the sustained high wind values provided within the range of the 31 HU1.2, HA1.2 meteorological instrumentation IJsed to measure wind speed?
-6 RAI # SECTION Question
- 1. Pursuant to EAL Technical Bases discussion in endorsed guidance, are HU 2.2 and 3.2 applicable for classifying actual fires and flammable gas buildup? Revise references in bases discussion as appropriate.
32 HU1.3
- 2. Explain why the last sentence, "These latter events would be classified by the radiological ICs or Fission Product Barrier ICs,"
in the endorsed guidance was not included in the EAL bases discussion.
Explain why the EAL does not include wording consistent with the 33 HU1.4 endorsed guidance (e.g., .....safety-related equipment required by Technical Specifications ... ").
Verify that the Probable Maximum Flood (PMF) level of 899' MSL 34 HU1.5 stated in the EAL disclJssion is consistent with stated PMF level in CNS USAR section 11-4.2.2.2. (e.g., 899' versus 903').
Are there are any other areas that come in contact with or immediately adjacent to those listed in Table H-1, Safe Shutdown 35 HU2.1 Areas, which contain or may contain equipment or cabling that could have an impact on safe shutdown equipment? Add any additions to Table H-1.
The CNS bases discussion provided in the EAL states that Engineering is required to evaluate the recording retrieved from the SMA-3, Strong Motion Accelograph. Provide discussion regarding 36 HA1.1 the availability of Engineering to evaluate this information should an Earthquake occur and the effect of this evaluation on the timeliness and availability of earthquake data.
Does the physical security plan provide appropriate guidance to the Security Shift Supervisor as to whether events are classified as 37 HU4.1 follows: Security Condition or Hostile Action? NOTE: Do not include any safeguards or sensitive information in response to question.
Discuss why the site-specific procedure(s) that require a control 38 HA5.1 room evacuation during an emergency were not included in the EAL consistent with endorsed guidance.
-7 RAI# SECTION Question The CNS bases discussion included in the EAL describes actions that can be taken rapidly at the reactor control console (Panel 9-5) 39 SA2.1, SS2.1 to initiate a manual scram. Verify whether the second action, "Reactor mode switch in SHUTDOWN," is correct. Discuss whether the action should state, "Reactor mode switch moved from RUN."
- 1. Discuss why the Note 5 regarding manual scram methods for EAL SS2.1 is not included as part of IC/EAL SA 2.1.
40 SS2.1
- 2. Discuss why manual scram action #3, "Manual or auto actuation of ARI," is different than action #3 in SA2.1.
Discuss why the bases discussion regarding the "Planned loss of 41 SU4.1, SA4.1 annunciators" was not included as part of the EAL bases discussion consistent with endorsed guidance (paragraph 3).
Provide bases discussion to include" ....offsite communication is 42 SU4.2 sufficient to inform federal, state, and local authorities ... " consistent with endorsed guidance or justify why it is not needed.
Discuss why the BWR [boiling-water reactor] EAL Fission Product 43 F Barrier Logic Flow Diagram was not included in your submittal consistent with endorsed guidance.
Discuss why there are no "OTHER" site-specific thresholds included in Table F-1 to indicate the loss or potential loss of the 44 TABLE F-1 Fuel Clad, Reactor Coolant System, and Primary Containment Fission Product Barriers.
... ML092150378 *email OFFICE NRR/LPL4/PM NRR/LPL4/LA NSIR/ONRLB/BC NRR/LPL4/BC NRR/LPL4/PM NAME FLyon JBurkhardt KWiliiams
- MMarkley FLyon DATE 8/4/09 8/4/09 7/29/09 8/5109 8/5/09