ML093480455

Request for Additional Information, Emergency Plan Changes to Implement Nuclear Energy Institute (NEI) 99-01, Revision 5, Methodology for the Development of Emergency Action Levels

ML093480455
Person / Time
Site:	Comanche Peak
Issue date:	12/23/2009
From:	Balwant Singal Plant Licensing Branch IV
To:	Flores R Luminant Generation Co
Singal, B K, NRR/DORL, 301-415-301
References
NEI 99-01, TAC ME1304, TAC ME1305
Download: ML093480455 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 23, 2009 Mr. Rafael Flores Senior Vice President and Chief Nuclear Officer Attention: Regulatory Affairs Luminant Generation Company LLC P.O. Box 1002 Glen Rose, TX 76043 SUB..IECT: COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE PROPOSED EMERGENCY PLAN CHANGES TO IMPLEMENT NUCLEAR ENERGY INSTITUTE (NEI) 99-01, REVISION 5, METHODOLOGY FOR THE EMERGENCY ACTION LEVELS (TAC NOS. ME1304 AND ME1305)

Dear Mr. Flores:

By letter dated May 12, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091390820), as supplemented by letter dated May 28, 2009 (ADAMS Accession No. ML091550030), Luminant Generation Company LLC (the licensee) submitted the proposed changes to the emergency plan to implement Nuclear Energy Institute (NEI) 99-01, Revision 5, "Methodology for Development of Emergency Action Levels," for Comanche Peak Steam Electric Station (CPSES), Units 1 and 2, for U.S. Nuclear Regulatory Commission (NRC) approval.

The NRC staff has reviewed the information provided by the licensee and determined that additional information is needed in order to complete the review. A draft copy of the request for additional information (RAI) was forwarded to Mr. Jim Barnette of your staff on November 24, 2009, via e-mail. The licensee had discussions with the NRC staff on December 11, 2009, to ensure mutual understanding of the RAI. Mr. Barnette agreed to provide the final response by January 29, 2010.

R. Flores - 2 If you have any questions, please contact me at 301-415-3016 or via e-mail at balwant.singal@nrc.gov.

Sincerely, b~\L0o.-.1 t.-8,~~

Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosure:

As stated cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION PROPOSED CHANGES TO EMERGENCY PLAN LUMINANT GENERATION COMPANY LLC COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446 By letter dated May 12, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091390820), as supplemented by letter dated May 28, 2009 (ADAMS Accession No. ML091550030), Luminant Generation Company LLC (the licensee) submitted the proposed changes to the emergency plan to implement Nuclear Energy Institute (NEI) 99-01, Revision 5 (ADAMS Accession No. ML080450149), "Methodology for Development of Emergency Action Levels," for Comanche Peak Steam Electric Station (CPSES), Units 1 and 2, for U.S. Nuclear Regulatory Commission (NRC) approval.

The NRC staff has reviewed the information provided by the licensee and determined that the additional information identified in the following table is needed in order to complete its review.

It was agreed that the licensee will provide the additional information being requested by January 29, 2010.

TABLE IDENTIFYING THE REQUEST FOR ADDITIONAL INFORMATION (RAI) FOR CPSES, UNITS 1 AND 2

~,<t#*f EAL Que$tion 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 licensee's particular design. This is to ensure regulatory stability of the Emergency Action Level (EAL) scheme.

This also ensures that, as stated in Title 10 of the Code of Federal Regulations, (10 CFR), Paragraph 50.47(b)(4), licensees implement "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters .... "

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

While formatting is usually not technically relevant to the NRC staffs review of EALs, when inconsistent formatting may result in potential misunderstanding, an RAI will be developed to correct the formatting or to obtain additional information in support of the deviation.

Enclosure

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EAL Question

1. Off-scale high or low thresholds are usually not within the calibrated range of instrumentation. Please confirm that all stated values, setpoints, and indications provided are within the calibrated range of the applicable instrumentation.

1 GENERAL 2. Sections 3.9,3.10, and 3.11 from the endorsed guidance contain important information necessary to understand the intent of the guidance as well as NRC staff expectations. Please indicate whether these sections will be incorporated into the document or fully document the technical basis for why it cannot be incorporated.

While no specific section in NEI 99-01, Revision 5, documents the purpose of the EAL Technical Bases Document (EAL TBD), however, it can be implied from statements made in NEI 99-01, Revision 5, Sections 4.2, 5.1, and particularly 2 SECT 1.0 Section 5.3. Please indicate whether the purpose statement in Section 1.0 of the EAL TBD for CPSES, Units 1 and 2 will be revised, to align with NEI 99-01, Revision 5, to state the purpose of the EAL TBD, or provide justification of why this is not necessary.

Generally, the industry implementation method has been for a HOT [hot conditions] EAL Wallboard and a COLD [cold conditions] EAL Wallboard.

Please explain how having three EAL Wallboards is more effective than two EAL 3 SECT 2.6 Wallboards and will not cause a situation whereby an Emergency Response Organization decision-maker neglects the ANY Operating Mode EAL Wallboard when reviewing the applicable HOT/COLD EAL Wallboard, or vice versa.

The NRC staff requests that ADAMS Accession No. ML080450149 be used to reference I\lEI 99-01, Revision 5, to ensure that the multiple draft copies of this 4 SECT 3.0 document that are in ADAMS are not inadvertently referenced. Please revise Section 3.0 to reference this ADAMS accession number.

It is expected that definitions are verbatim from the endorsed guidance, with the exception of terms specifically defined by the licensee, to ensure implementation of a standard emergency classification and action level scheme.

Please provide the following:

1. Please define the term PROJECTILE as worded in the endorsed guidance, 5 SECT 4.0 or provide adequate justification supporting the deviation.

2. As noted above, please provide the site-specific definition for VITAL AREA rather then the generic wording used in the endorsed guidance.

3. Add the word "energized" to the definition of EXPLOSION or provide adequate justification to support the deviation.

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RAI# EAL Question RU1.1

1. [RU 1, RA1] Please provide documentation to support that the values "2 x RU1.2 HIGH ALARM and 200 x HIGH ALARM" are within the calibrated range of the applicable instrumentation.

RA1.1

2. Table R-1 appears to be formatted incorrectly. Please verify that the listed 6 RA1.2 values for u-RE-2325 thru u-RE-2328 are as stated. It appears that the RA1.3 values listed in the table may be only applicable to u-RE-2325.

RS1 3. All the values that should be "IJCi" state "IJC" instead. Please correct these typographical errors or provide justification to support the deviation.

RG1 Please explain why the value for X-RE-5570 A&B is only 10x the UE value 7 RA1.1 instead of 100x. Please correct the discrepancy or provide adequate justification for the deviation.

RA1.1 The RU 1 set of EALs incorporate language that is derived from the endorsed 8 RA1.2 guidance; however, the RA1 set of EALs do not. Please incorporate the endorsed language or provide justification to support the deviation.

RA1.3 RS1 Please confirm that the resolution of the instrumentation used for these EALs 9

RG1 can accurately indicate the stated values.

RS1.3 Please restore the note related to timing as stated in the endorsed guidance, or 10 RG1.3 provide justification to support why it is not applicable.

HU2.1 RA2.3 CU1.2 CU2.2 If using the same Initiating Condition (IC) numbering base (RA2.1, RA2.3, etc.),

11 then the IC title is expected to be the same. Please indicate whether the CU2.3 endorsed guidance will be followed or provide justification for the deviation.

SS1.2 SU4.2

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RAI# EAti Question

1. Please explain why "station blackout" is not part of the EAL, as endorsed.

Please indicate whether the endorsed wording will be incorporated or justify the deviation.

12 CU1.1 2. The plant-specific basis information on page 89 of EAL TBD for CPSES, Units 1 and 2, does not include language to support the expectation that this EAL be declared, if the EAL is expected to continue beyond the time allowed. Please clarify.

Please confirm that the instrumentation to be used for the 10 psig value is 13 CA3.1 capable of reading this value (i.e., within the resolution and calibrated range).

1. Please explain why the Engineering Notification System (ENS) is not listed in Tables C-2 and S-2 as a viable option for onsite and offsite communications.

2. The plant-specific description for CU4.1 states the FAX transmissions are CU4.1 included. FAX transmissions are not actually a method that is considered 14 SU4.2 reasonably viable nor is it a method CPSES, Units 1 and 2, chose to list in Tables C-2 and S-2. Please indicate whether the discrepancy will be corrected or justify the deviation.

3. The plant-specific information is not consistent for these two EALs. Please explain the inconsistency.

The plant-specific basis information states "later." Please include information for 15 EU1.1 review or change the basis to "none."

HU1.1 Please confirm that the stated alarms and indicators are available in the Control 16 Room, or, if not, justify the effect these alarms and indicators have on the timing HA1.1 of this EAL.

This EAL on page 160 of the EAL TBD for CPSES, Units 1 and 2, should 17 HU1.3 actually be numbered HU1.4. Please correct the discrepancy or justify why the EAL scheme has two HU1.3 EALs.

Please explain why "startup" is not an operating mode listed for this EAL or 18 SA2.1 justify the deviation.

Please provide documentation to support the values chosen for 1-131 and 19 SU5.1 XE-133 specific activity and, in addition, confirm that CPSES, Units 1 and 2, do not have an activity threshold over a certain site-specific duration.

-5 RAitt****. SAL Question Please provide additional documentation to support what was reviewed, and Fission what was considered, for the "Other Site Specific Indications" from the endorsed 20 Product guidance (line 7 for all barriers). Please indicate the extent to which a Barrier Matrix reasonable effort has been made to determine a site-specific indicator of a loss or potential loss of any fission barrier.

R. Flores -2 If you have any questions, please contact me at 301-415-3016 or via e-mail at balwant.singal@nrc.gov.

Sincerely, IRA!

Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosure:

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PUBLIC LPLIV Reading RidsAcrsAcnw_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNsirDprDdep Resource RidsNrrPMComanchePeak Resource RidsNrrLAJBurkhardt Resource RidsOgcRp Resource RidsRgn4MailCenter Resource DJohnson, NSIRIDDEP/ONRB/ORLT ADAMS Accession No.: ML093480455 RAI Received via e-mail dated November 13 , 2009 OFFICE NRR/LPL4/PM NRR/LPL4/LA NSIR/ORLOB NRR/LPL4/BC NRR/LPL4/PM NAME BSingal JBurkhardt JAnderson* MMarkley BSingal DATE 12/23/09 12/16/09 11/13/09 12/23/09 12/23/09 OFFICIAL AGENCY RECORD