ML101400133

Reply to Request for Additional Information Regarding Proposed Changes to the Emergency Plan

ML101400133
Person / Time
Site:	Ginna
Issue date:	05/14/2010
From:	John Carlin Constellation Energy Nuclear Group, Ginna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML101400133 (51)

Text

John Carlin Site Vice President R.E. Ginna Nuclear Power Plant, LLC CENG a joint venture of 1503 Lake Road Ontario, New York 14519-9364 585.771.5200 585.771.3943 Fax Consel:on eDF John.Carlin@cengllc.com May 14, 2010 U. S. Nuclear Regulatory Commission Washington, DC 20555 - 0001 ATTENTION: Document Control Desk

SUBJECT:

R.E. Ginna Nuclear Power Plant Docket No. 50-244 Reply to Renuest for Additional Information RE: Proposed Changes to the Emergency Plan

REFERENCES:

(a) Letter from Mr. J. T. Carlin (Ginna LLC) to Document Control Desk (NRC) dated November 30, 2009, License Amendment Request: Proposed Changes to the Emergency Plan (b) Letter from Mr. D. V. Pickett (NRC) to Mr. J. T. Carlin (Ginna LLC) dated March 9, 2010, Request for Additional Information RE: Proposed Changes to the Emergency Plan (TAC NO. ME2916)

On November 30, 2009, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) submitted a License Amendment Request (LAR) seeking to revise the Ginna Emergency Plan.

Subsequent to the submittal, the NRC issued a Request for Additional Information (Reference (b)).

Enclosure 1 contains our response to this request. As the result of further site review of the non-annunciator related Emergency Action Levels (EALs) we are formally withdrawing our request for those specific EALs. We will address those other EALs in our planned EAL conversion which we are currently initiating efforts on. Enclosure 2 and its attachments have been modified from the original submittal (Reference (a)) to include our revised evaluation of the proposed changes and revised supporting material.

No new commitments are being made in this submittal. Should you have questions regarding the information in this submittal, please contact Mr. Thomas Harding at (585) 771-5219 or via email at Thomas. HardingJr(cengll c.com.

w \JIR-/c-10`23o 3

Document Control Desk May 14, 2010 Page 2 STATE OF NEW YORK TO WIT:

COUNTY OF WAYNE I, John Carlin, being duly sworn, state that I am Site Vice President, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC), and that I am duly authorized to execute and file this request on behalf of Ginna LLC.

To the best of my knowledge and belief, the statements contained in this document are true and correct.

To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Ginna LLC employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be re^le.

Subscribed and sworn before me, a Notary Public in and for the State of New York and County of MO0fIZOE ,this jLday of MO, ,2010.

WITNESS my, .Handand Notarial Seal:

SHARON L MILLER

,JA~ANotary LRegistration Public,No.

State01MI6017755 of New York Monroe County Notary Public Commission Expires December21, 20/0 : Response to Request for Additional Information Regarding Proposed Changes to the Emergency Plan : Revised Evaluation of Proposed Changes cc: S. J. Collins, NRC D. V. Pickett, NRC Ginna Resident Inspector, NRC P. D. Eddy, NYSDPS A. L. Peterson, NYSERDA G. Bastedo, Wayne County Emergency Management M. Meisenzahl, Monroe County Office of Emergency Management

ENCLOSURE 1 Response to Request for Additional Information Regarding Proposed Changes to the Emergency Plan R.E. Ginna Nuclear Power Plant, LLC May 14, 2010

Enclosure 1 Response to Request for Additional Information Regarding Proposed Changes to the Emergency Plan Request for Additional Information Question #1:

EAL Scheme The currentemergency action levels (EALs) scheme in use at Ginna is based on NUMARCiNESP-007, January 1992, "Methodologyfor Development of Emergency Action Levels." The proposedchanges involve upgradingselected Ginna EALs based on Nuclear Energy Institute (NEI) 99-01, Revision 5, "Methodologyfor Development of Emergency Action Levels,"

using the guidance of NRC Regulatory Issue Summary 2003-18, Supplement 2, "Use ofNuclear Energy Institute (NEI)99-01, Methodologyfor Development of Emergency Action Levels."

Does Ginna have future plans to upgrade the overall EAL scheme to NEI 99-01, Revision 5?

Yes, Ginna has commenced a project to upgrade from the NUMARC/NESP-007 EAL scheme to NEI 99-01, Revision 5 EALs.

Request for Additional Information Question #2:

Section 2.0, "DetailedDescription,"contains the following errors/discrepancies,please correctthem or providejustification to supporttheir inclusion:

You state ".. . the following selected hazard-basedEALs... "when it is actually hazardand system basedEALs.

You state "... Nuclear Energy Institute (NEI)99-01, Revision 5,... January2003, as endorsed by the Nuclear Regulatory Commission (NRC) in Regulatory Guide (RG) 1.101... "when infact the version of NEI 99-01, Revision 5, endorsedby the NRC is dated February2008, and it was endorsedby letter [ADAMS Accession No. ML080430535] not by RG 1.101.

Attached Enclosure 2, Section 2.0, has been revised. The hazard based EALs have been removed from the list of requested EAL changes and the reference to the NRC endorsement of NEI 99-01 has been revised to incorporate the above comment.

Request for Additional Information Question #3:

Section 6.0, "References" Pleaseput in the ADAMS Accession Nos. of the stated documents Attached Enclosure 2, Section 6.0, has been revised to incorporate ADAMS accession numbers for the referenced documents.

Request for Additional Information Question #4:

EAL 7.3.1 The "note"from NEI 99-01, Revision 5, is intendedto be within the body of the EAL, not in the Basis information. Please align with staff expectationsfor the development of this EAL orjustify why it is inappropriatefor Ginna.

The Note was moved into the body of the EAL. The note was given a number to allow the text of the note to be placed at the bottom of the implementing procedure and wallboard. This allows for easier implementation of the EALs by the Emergency Coordinator.

R.E. Ginna Nuclear Power Plant, LLC May 14, 2010 Page 1

Enclosure 1 Response to Request for Additional Information Regarding Proposed Changes to the Emergency Plan Request for Additional Information Question #5:

EAL 7.3.3 The "note"from NEI 99-01, Revision 5, is intended to be within the body of the EAL, not in the Basis information.Please align with staff expectationsfor the development of this EAL orjustify why it is inappropriatefor Ginna.

The Note was moved into the body of the EAL. The note was given a number to allow the text of the note to be placed at the bottom of the implementing procedure and wallboard. This allows for easier implementation of the EALs by the Emergency Coordinator.

Reauest for Additional Information Question #6:

EAL 7.3.4 The "note"from NEI 99-01, Revision 5, is intended to be within the body of the EAL, not in the Basis information. Please align with staff expectationsfor the development of this EAL orjustify why it is inappropriatefor Ginna.

There is a probable logic issue with how Ginnadeveloped this EAL. There are three separate EAL thresholds logically "and-ed"together, however, the first thresholdas two thresholds logically "or-ed." The EAL as submitted does not appearto satisfy the intent of the endorsed development guide. Please align with staff expectationsfor the development of this EAL orjustify why it is inappropriatefor Ginna.

The Note was moved into the body of the EAL. The note was given a number to allow the text of the note to be placed at the bottom of the implementing procedure and wallboard. This allows for easier implementation of the EALs by the Emergency Coordinator.

The potential EAL logic issue was addressed through aligning the OR and AND logical connectors as shown in the development guide. The layout of the EAL is now similar to other existing Ginna EALs such as 4.1.6, Containment Integrity Status.

Request for Additional Information Question #7:

EAL 8.2.1 The "note"from NEI 99-01, Revision 5, is intended to be within the body of the EAL. Please align with staff expectationsfor the development of this EAL orjustify why it is inappropriatefor Ginna.

EAL 8.2.1 has been withdrawn.

R.E. Ginna Nuclear Power Plant, LLC May 14, 2010 Page 2

Enclosure 1 Response to Request for Additional Information Regarding Proposed Changes to the Emergency Plan Request for Additional Information Question #8:

Please explain why there is a different tablefor EAL 8.2.1 and EAL 8.2.2. The staffs expectation is that these tables be the same. The difference between the Alert and the Unusual Event is evidence of visible damage or degradedperformance.

EAL 8.2.1 and EAL 8.2.2 have been withdrawn.

Request for Additional Information Question #9:

EAL 8.3.5 The "note"from NEI 99-01, Revision 5, is intended to be within the body of the EAL. Please align with staffexpectationsfor the development of this EAL orjustify why it is inappropriatefor Ginna.

EAL 8.3.5 has been withdrawn.

Reauest for Additional Information Question #10:

Please explain the implementation methodfor Ginna.

If this is the primary tool usedfor EAL declaration,then please explain why the Initiating Condition (IC) and applicable "notes"are not included The staff considers the IC-EAL, Thresholds-OperatingModes-Notes, "all to be of importance in declaringthe EAL in a timely manner. The applicableBasis information is intended to be available to support understandingof the EAL and to aid in ensuringthe consistency of training.

Please explain the implementation method used by Ginna, i.e., do you use EAL Wallboardsor do you use your Emergency Plan and Emergency Plan Implementing Proceduresdirectly?

Ginna uses an implementing procedure and EAL wallboard to implement the EALs. The implementing procedure is a smaller version of the EAL wallboard containing the entry conditions for each EAL. The EAL technical basis document is available to the Emergency Coordinator but is not required for classification of an event. The notes found in Revision 5 EALs and mentioned in this Request for Additional Information will be added to the implementing procedure and EAL wallboard. The entry conditions will have a note reference such as "Note 1" with a corresponding entry at the bottom of the table or wallboard with the text of the note.

R.E. Ginna Nuclear Power Plant, LLC May 14, 2010 Page 3

Enclosure 1 Response to Request for Additional Information Regarding Proposed Changes to the Emergency Plan Additional Changes to the EAL Submittal Package As the result of the Ginna internal review of the EAL submittal package during the incorporation of the RAI responses, a number of additional minor changes/corrections were identified that were also addressed at this time. These changes are listed below and have been determined to either be grammatical corrections or are differences that maintain the meaning and intent of the EAL or basis wording.

EAL 7.3.1

1. Changed "6 or more annunciators" to "6 or more annunciator panels". This better defines the EAL. The EAL describes the loss of 6 annunciator panels, not the loss of 6 individual annunciators.

2. Grammar correction: changed "75% of lost annunciators is defined as..." to "A 75% loss of annunciators is defined as..."

3. Grammar correction: changed "safety system annunciators or indicators are lost" to "safety system annunciators or indications are lost" EAL 7.3.3

1. Changed "6 or more annunciators" to "6 or more annunciator panels". This better defines the EAL. The EAL describes the loss of 6 annunciator panels, not the loss of 6 individual annunciators.

2. Changed "Emergency Director" to "Emergency Coordinator" to align with Ginna site specific reference.

3. Grammar correction: changed "75% of lost annunciators is defined as..." to "A 75% loss of annunciators is defined as..."

4. Grammar correction: changed "safety system annunciators or indicators are lost" to "safety system annunciators or indications are lost" EAL 7.3.4

1. Changed "6 or more annunciators" to "6 or more annunciator panels". This better defines the EAL. The EAL describes the loss of 6 annunciator panels, not the loss of 6 individual annunciators.

2. Changed "Emergency Director" to "Emergency Coordinator" to align with Ginna site specific reference.

3. Changed "This EAL recognizes the inability of..." to "This EAL recognizes the threat to plant safety associated with the complete loss of capability of..." to align with the wording in NEI 99-01.

4. Grammar correction: changed "75% of lost annunciators is defined as..." to "A 75% loss of annunciators is defined as..."

5. Grammar correction: changed "safety system annunciators or indicators are lost" to "safety system annunciators or indications are lost"

6. Changed "...monitor safety functions needed for protection of the public." to "...monitor safety functions needed for protection of the public while a significant transient is in progress." to align with the wording in NEI 99-01.

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Enclosure 1 Response to Request for Additional Information Regarding Proposed Changes to the Emergency Plan

7. Changed "(e.g. rad monitors, etc)" to "(e.g. area, process and/or rad monitors, etc)" to align with wording in NEI 99-01.

8. Changed "The specific indications should be those used to determine such functions as the ability to shut down the reactor, maintain the core cooled and in a coolable geometry, to remove heat from the core, to maintain the reactor coolant system intact, and to maintain containment intact." to "The specific indications should be those used to determine such functions as the ability to shut down the reactor, maintain the core cooled, to maintain the reactor coolant system intact, maintain the spent fuel cooled, and to maintain containment intact." This aligns with the wording in NEI 99-01 which removes the criteria of maintaining a coolable geometry and adds the criteria of maintaining the spent fuel cooled.

R.E. Ginna Nuclear Power Plant, LLC May 14, 2010 Page 5

ENCLOSURE 2 Revised Evaluation of Proposed Changes R.E. Ginna Nuclear Power Plant, LLC May 14, 2010

Enclosure 2 Revised Evaluation of Proposed Changes TABLE OF CONTENTS 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Significant Hazards Consideration 4.3 Conclusions

6.0 REFERENCES

ATTA CHMENTS

1. Red-line of the Current Ginna EAL Technical Basis Document

2. Clean Copy of the Proposed Ginna EAL Technical Basis Document

3. Red-line of NEI 99-01 Revision 5

4. Clean Copy of Proposed Ginna EALs

5. Plant-Specific EAL Guideline Cross Reference

6. EAL Differences and Deviations R.E. Ginna Nuclear Power Plant, LLC May 14, 2010 Page 1

Enclosure 2 Revised Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION In accordance with the provision of 10 CFR 50.90, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) is submitting a license amendment request to change the R.E. Ginna Nuclear Power Plant (Ginna)

Emergency Plan.

The proposed changes involve upgrading selected Ginna Emergency Action Levels (EALs) based on NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels," using the guidance of NRC Regulatory Issue Summary 2003-18, Supplement 2, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels." The current EAL scheme in use at Ginna is based on NUMARC/NESP-007, "Methodology for development of Emergency Action Levels." The plan, as changed, would continue to meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR 50. Ginna LLC has reviewed the proposed changes in accordance with 10 CFR 50.54(q), and has determined these changes are considered a decrease in effectiveness of the approved emergency plan.

2.0 DETAILED DESCRIPTION The Ginna Emergency Plan currently uses the NUMARC/NESP-007 EAL scheme. Ginna LLC is proposing to change the existing scheme for Ginna for the following selected system based EALs to that described in NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels,"

February 2008, as endorsed by the Nuclear Regulatory Commission (NRC) by letter dated February 22, 2008:

EAL Number Classification Level Summary Description 7.3.1 Unusual Event Loss of Annunciators 7.3.3 Alert Loss of Annunciators 7.3.4 Site Area Emergency Loss of Annunciators The current Ginna NUMARC/NESP-007 based EALs were developed in 1994. At that time, it was decided that the loss of any one safety system annunciator panel, versus the "approximately 75%"

recommended by the NUMARC document, was an accurate description of the conditions that met the Initiating Condition as detailed in NUMARC/NESP-007. Ginna has eight safety system annunciator panels in the Main Control Room. 75% of those would equal six panels. The NUMARC document states "This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment." During EAL development, it was concluded that the indications available in the Main Control Room at that time were such that the loss of any one of the safety system annunciator panels created sufficient challenges to the operating crews to result in a potential decrease in the level of safety of the plant. Hence, the EAL developers considered the loss of one safety system annunciator panel to meet the definition of a Notification of Unusual Event.

That concept was carried to the related emergency classifications at the Alert and Site Area Emergency levels. The loss of annunciator emergency action levels were endorsed by the NRC in a Safety Evaluation Report dated 2/15/1995 as part of the overall approval of the new EAL scheme for Ginna.

Subsequent to the approval of the NUMARC-based EALs for Ginna, improvements in Main Control Room indications took place. The EAL bases were not revisited after completion of the upgrades. Once the Main Control Room upgrades were complete, the conservatism of the annunciator loss EAL's had increased, given the additional indications that were now available to monitor plant conditions without the use of annunciators. At this point, loss of a single safety system annunciator panel no longer constituted a R.E. Ginna Nuclear Power Plant, LLC May 14,2010 Page 2

Enclosure 2 Revised Evaluation of Proposed Changes potential decrease in the level of safety of the plant. However, this was not recognized as an opportunity to improve the EALs.

Ginna LLC has experienced two loss of annunciator panel events, each of which resulted in the declaration of a Notification of Unusual Event. The 7/4/2007 event resulted in a loss of all annunciators in the Main Control Room. The event on 2/5/2009 involved the loss of three safety system annunciator panels. During the later event, the experience of the operating crews caused them to question the validity of the basis that the loss of a single safety system annunciator panel constituted a Notification of Unusual Event. Investigation into the 2009 event revealed the conservatism in the current EALs and caused Ginna LLC to investigate the re-alignment of the EALs with NRC-endorsed guidance.

NRC Regulatory Issue Summary (RIS) 2005-02, Clarifying the Process for Making Emergency Plan Changes defines a decrease in effectiveness as a change in an emergency preparedness (EP) requirement that results in the degradation or loss of the capability to perform a function or perform a function in a timely manner, as contained in the emergency plan. RIS 2005-02 clarifies a change in an EP requirement based on capability, means the emergency plan as changed, would result in the loss or degradation of the capability to meet the regulatory requirements of an emergency plan. Consequently, the capability to perform a function(s) as previously stated in the emergency plan no longer exists or is degraded. RIS 2005-02 defines an EP requirement, in part, as a statement made in the emergency plan which addresses how a particular regulatory requirement will be met and emphasizes all EP requirements are subject to the 10 CFR 50.54(q) change process.

Ginna LLC has reviewed these changes in accordance with 10 CFR 50.54(q), and has determined that the proposed changes are considered a decrease in effectiveness of the approved emergency plan and require prior approval before implementation. The proposed changes would result in a minor degradation of the function as defined in the current Ginna LLC emergency plan, but still meet NUMARC/NESP-007 requirements. This degradation does not result in a degrading of the level of public safety.

3.0 TECHNICAL EVALUATION

These changes affect the Ginna Emergency Plan and do not alter requirements of the Operating License or the Technical Specifications. These changes do not alter any of the assumptions used in the safety analyses, nor do they cause any safety system parameters to exceed their acceptance limit. Therefore, the proposed changes have no adverse effect on plant safety. Additionally, these changes can be made without adverse impact to plant operations or to the health and safety of the public.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.47(b)(4) states "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures."

R.E. Ginna Nuclear Power Plant, LLC May 14, 2010 Page 3

Enclosure 2 Revised Evaluation of Proposed Changes 10 CFR 50 Appendix E, section W. Content of Emergency Plans, item B. Organization states "The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. These initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC. Thereafter, emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis. A revision to an emergency action level must be approved by the NRC before implementation if:

(1) The licensee is changing from one emergency action level scheme to another emergency action level scheme (e.g., a change from an emergency action level scheme based on NUREG-0654 to a scheme based upon NUMARC/NESP-007 or NEI-99-01);

(2) The licensee is proposing an alternate method for complying with the regulations; or (3) The emergency action level revision decreases the effectiveness of the emergency plan.

A licensee shall submit each request for NRC approval of the proposed emergency action level change as specified in § 50.4. If a licensee makes a change to an EAL that does not require NRC approval, the licensee shall submit, as specified in § 50.4, a report of each change made within 30 days after the change is made."

Regulatory Guide 1.101 Revision 4, Section C. Regulatory Position states "The guidance in NUMARC/NESP-007 (Revision 2, January 1992), "Methodology for Development of Emergency Action Levels," is acceptable to the NRC staff as an alternative method to that described in Appendix 1 to NUREG-0654/FEMA-REP-1 for developing EALs required in Section IV.B of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4). In addition, the guidance contained in NEI 99-01 (Revision 4, January 2003), "Methodology for Development of Emergency Action Levels," is acceptable to the NRC staff as an alternative method to that described in Appendix 1 to NUREG-0654/FEMA-REP- 1 and NUMARC/NESP-007 for developing EALs required in Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4)."

10 CFR 50.54(q) requires, "Proposed changes that decrease the effectiveness of the approved emergency plans may not be implemented without application to and approval by the Commission. The licensee shall submit, as specified in 10 CFR 50.4, a report of each proposed change for approval."

4.2 Significant Hazards Consideration Ginna LLC has evaluated whether or not a significant hazards consideration (SHC) is warranted with the proposed changes by addressing the three criterion set forth in 10 CFR 50.92(c) as discussed below.

Criterion 1:

Does the proposed amendment involve a significantincrease in the probabilityor consequences of an accidentpreviously evaluated?

R.E. Ginna Nuclear Power Plant, LLC May 14, 2010 Page 4

Enclosure 2 Revised Evaluation of Proposed Changes Response: No.

These changes affect the R.E. Ginna Nuclear Power Plant Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. The proposed changes do not modify any plant equipment and do not impact any failure modes that could lead to an accident.

Additionally, the proposed changes have no effect on the consequence of any analyzed accident since the changes do not affect any equipment related to accident mitigation. Based on this discussion, the proposed amendment does not increase the probability or consequences of an accident previously evaluated.

Criterion 2:

Does the proposedamendment create the possibility of a new or different kind of accidentfrom any accidentpreviously evaluated?

Response: No.

These changes affect the R.E. Ginna Nuclear Power Plant Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. They do not modify any plant equipment and there is no impact on the capability of the existing equipment to perform their intended functions. No system setpoints are being modified and no changes are being made to the method in which plant operations are conducted. No new failure modes are introduced by the proposed changes. The proposed amendment does not introduce accident initiator or malfunctions that would cause a new or different kind of accident. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Criterion 3:

Does the proposedamendment involve a significantreduction in a margin ofsafety?

Response: No.

These changes affect the R.E. Ginna Nuclear Power Plant Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. The proposed changes do not affect any of the assumptions used in the accident analysis, nor do they affect any operability requirements for equipment important to plant safety. Therefore, the proposed changes will not result in a significant reduction in the margin of safety as defined in the bases for technical specifications covered in this license amendment request.

In summary, Ginna LLC concludes that the proposed amendment does not represent a significant hazards consideration under the standards set forth in 10 CFR 5 0.92(c).

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission' regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

R.E. Ginna Nuclear Power Plant, LLC May 14, 2010 Page 5

Enclosure 2 Revised Evaluation of Proposed Changes

5.0 ENVIRONMENTAL CONSIDERATION

Ginna LLC has determined that the proposed amendment would not change requirements with respect to use of a facility component located within the restricted area, as defined by 10 CFR 20, nor would it change inspection or surveillance requirements. Ginna LLC has evaluated the proposed change and has determined that the change does not involve:

I. A Significant Hazards Consideration II. A significant change in the types or significant increase in the amounts of any effluent that may be released off site, or III. A significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10)(ii). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

(1) NUMARC/NESP-007, Revision 2, "Methodology for development of Emergency Action Levels," January 1992 (ADAMS Accession No. ML041120174)

(2) NEI 99-0 1, Revision 5, "Methodology for Development of Emergency Action Levels," February 2008 (ADAMS Accession No. ML080450149).

(3) Appendix 1 to NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

November 1980 (ADAMS Accession No. ML040420012)

(4) Regulatory Guide 1.101, Revision 4, "Emergency Planning and Preparedness for Nuclear Power Reactors," July 2003 (ADAMS Accession No. ML032020276)

(5) NRC Regulatory Issue Summary 2003-18, "Use of NEI 99-01, 'Methodology for Development of Emergency Action Levels,' Revision 4, Dated January 2003," October 8, 2003; Supplement 1, July 13, 2004, and Supplement 2, December 12, 2005. (ADAMS Accession Nos. ML032580518, ML041550395, and ML051450482)

(6) NRC Regulatory Issue Summary 2005-02, "Clarifying the Process for Making Emergency Plan Changes," February 2005 (ADAMS Accession No. ML042580404)

(7) Letter from Christopher Miller, NRC to Alan Nelson, NEI, "US Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 5, Dated February 2008," dated February 22, 2008 (ADAMS Accession No. ML080430535).

R.E. Ginna Nuclear Power Plant, LLC May 14, 2010 Page 6

ATTACHMENT (1)

Red-line of the Current Ginna EAL Technical Basis Document R.E. Ginna Nuclear Power Plant, LLC May 14, 2010

ATTACHMENT (1)

Red-line of the Current Ginna Technical Basis Document Additions to the current document are highlighted text. Deletions to the current document are strikethrough text.

ATTACH MENT (1)

Page 1-1

7.0 Equipment Failures 7.3 Loss of Indications /Alarms I Communication Capability 7.3.1 Unusual Event URplanned

,c .. of annumnc.ator. or indicatione..on any Control Room Pa elTabe...3.for

-AND Incrnirn,1 ruir'niII~ncn In rnnulrnd tor pio ni~int

- i-*-~*-

nooration r

T=able 7.3 Vit-al Co.nt-rol- Roo-m-. Panels A I A 1 8 1 G 1 0 I1 E r- I Unplanned loss of meet or all cte. annuniation or indication in the cnrol roo f*rafet for FPB losslpotential loss:

N/A Mode Applicability:

1-Power operations, 2-startup, 3-hot shutdown, 4-hot standby Basis:

This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment. Recognition of the availability of computer based indication equipment is considered (PPCS and SAS).

"NotPlanned" loss of annunciators or indicators e*,ludes scheduled maintenance and testing activities.

ATTACHMENT (1)

Page 1-2

It is not intended that plant personnel perform a detailed count of the instrumentation lost but the use of judgment by the Shift Manager as the threshold for determining the severity of the plant conditions. This judgment is suppo,.d by the specific.opinion of the Shift Manager that additional oereating personno! will bo required to prOv.idc increased mo~nitoring Of SyStemA operation to safely operate the plant.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification.

The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via IOCFR50.72. If the shutdown is not in compliance with the Technical Specification action, the Unusual Event is based on EAL 7.1.1, Inability to Reach Required Shutdown Within Technical Specification Limits.

Annunciators or indicators for this EAL must include those identified in the Abnormal Operating procedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.).

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Due to the limited number of safety systems in operation during cold shutdown, refueling, and defueled modes, this EAL is not applicable during these modes of operation.

This Unusual Event will be escalated to an Alert iasednt a ntoindication. a in progress durm*thenlsato PEG Reference 5SU3.1 Basis Reference(s):

None ATTACHMENT (1)

Page 1-3

7.0 Equipment Failures 7.3 Loss of Indications /Alarms I Communication Capability 7.3.3 Alert J

• i i

• X P J

• Unpanned 1966 0? annunciatoc Or IndIcavens On anY 60nIroi ro9m P-'anels, ITable 7. 3or >-

-AND Inreeased sur'.eillance ic required I for Safe Plant operation

.AQh )e itheF

• nrnn r*

--OR PPCS Or, unav:ailable Table 7.3 Vit-al Cointronel Rooem Panolec A ~AAI 8 01 &

ITE mN Table 7.3 Control Room Annunciator Panels A I AA I B I C I D E F Note 1: The Emergency Coordinator should notwait until the applicable-time has elapsed, but should declare the event as soon, as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

hiU MARC If-Unplanned 1066 Of mee~t or all safety syrctom annunciation or RindiationR in control room With either (1) a Signifficant tranciOnt in progreSc, or (2) componsatGry non alaFARmi@idctr are A "I W." -4 1 & nrn 0C 5VI VVVIHI B5 - 5VV I NEI 99-01 Rev. 5 IC:

Unplanned loss of safety system annunciation or indication in the:control room with either (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indications' unavailable.

FPB losslpotential loss:

N/A Mode Applicability:

1-Power operations, 2-startup, 3-hot shutdown, 4-hot standby ATTACHMENT (1)

Page 1-4

Basis:

This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a t*aRsieF#

SIGNA NTR I . Recognition of the availability of computer based indication equipment is considered (PPCS, SAS, etc.).

"LoPlanned" loss of annunciators or indicators dees-Ret includei scheduled maintenance and testing activities.

It is n*t intended that plant pr'S..nnl p.*.trm a detailod count oft* h st-umentat-ion.st but the inhe use of judgment by the Shift Managore as the threshold forF determ~ining the syeveity of the plant eQoRdition-s. This judgment is,supportod by the sp6cific op.inin Of the Shift Manager that additional operating porsonnel will be roqUircd topoidnr asedmoitoring of 6Y6te operation to safely operate the plant.-

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptable power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification.

The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10CFR50.72.....*

Annunciators or indicators for this EAL icterude c those identified in the oSgifcnransifent"yse Abnormal tev Operating indcludes Procedures, rspon ormnalanta ldsetoaomaticOperating in the Emergency functionoftaspcicsysuch Procedures, as and in other EAnLs (e. g., area, process, and/or effluent rad monitors, etc.).

trips, ubeck inpotoving g Creater Ithan 25%uthermalspoter chmlange, with the~n, orethermal (e. olons, v.,rea, of1/or eavrf.e m r ATTACHMENT (1)

Page 1-5

If bo~th a-major portion of the -ann-unciation system and all computer monGitoing are unaVailablo to the extent that the additional operating perconnol are regUired to moenitor indicGation6, theAlt Due to the limited number of safety systems in operation during cold shutdown, refueling and defueled modes, no EAL is indicated during these modes of operation.

This Alert will be oscalated to a Site Area Emergency, if the operating crew cannot monitor the transient in progrecs. u oacnurn oso opnaoyidctoswt INFCN PEG

Reference:

NSA4.1 Basis Reference(s):

None ATIACHMENT (1)

Page 1-6

7.0 Equipment Failures 7.3 Loss of Indications /Alarms I Communication Capability 7.3.4 Site Area Emergency I-~

A-iOA _T (a A--; n SAanu o.A-r annRuncA1atr A-nQF 1A on Gontrei ReooM. Franeis. Taoi .

-AND

-AND A plant tranci8At in prOgrooc T-able 7.3 Vital Control Room PInle I

11 A I AA 1 43 1 G I [) I E_ F_ G Loss of the following for 15 minutes or longer 6 or more Control Room Annunciator Panels listed in Table 7.3 OR An approximate 75% reduction in Control Room safety indications AND A SIGNIFICANT TRANSIENT is in progress AND Compensatory indications are unavailable Table 7.3 Control Room Annunciator Panels A I AA D E F G Note 1: The Emergency Coordinator should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

NUMARG4-G-Inability to monGitor a Sigi nificant transient in arosr ith rWith -anor coolant - 0o.r 2-00 FPB losslpotential loss:

N/A Mode Applicability:

1-Power operations, 2-startup, 3-hot shutdown, 4-hot standby ATTACHMENT (1)

Page 1-7

Basis:

This EAL recognizes the inabiity cof the Control Room staff to monitor the plant response to a tiansieS I moinificnt rnion yt"m opuecraton.Ap5onso tof anutomaticors minudllfinitedasls f tof6 tuhe 8c Itisfrthrnc rubck nvolin grhatmost thant de5%n phrmovi saetysyse indecationeo ereduhanto A Site Area thwermel Emergency promweproc is considered ateuionterpc ofwe 1uples to exist if the Control Room staff cannot monitor safety orilgreueater.rgprtono functions needed for protection of the public t Annunciators for this EAL should be limited to include those identified in the Abnormal Operating Procedures, in the CSFST's and Emergency Operating Procedures, and in other EALs (e. g., monitors, etc.).

ATTACHMENT (1)

Page 1-8

Indications needed to monitor critical safety functions necessary for protection of the public must include Control Room indications, computer generated indications and dedicated annunciation capability. The specific indications should be those used to determine such functions as the ability to shut down the reactor, maintain the core cooled and in a coolabl gem*etry, - to romo'-

heat from the cre., to maintain the reactor coolant system intact, m and to maintain containment intact.

"Planned" actfiene are excud--ed- from the &ALI sAince the los%of in'RAUmentation of this magnitude is of rucwh signicance during a transient that the causme of the loss not An amloatig fa~ctor.

"Compensatoryl~ indications" *1in* th 1isllI cnetl Iinclue comp*u1ter base informaion suc as P PEG

Reference:

NI9-1Rvso5:SS6.1 Basis Reference(s):

None ATTACHMENT (1)

Page 1-9

ATTACHMENT (2)

Clean Copy of the Proposed Ginna EAL Technical Basis Document R.E. Ginna Nuclear Power Plant, LLC May 14, 2010

7.0 Equipment Failures 7.3 Loss of Indications /Alarms /

Communication Capability 7.3.1 Unusual Event Unplanned loss of the following for 15 minutes or longer:

6 or more Control Room Annunciator Panels listed in Table 7.3 OR An approximate 75% reduction in Control Room safety system indications Table 7.3 Control Room Annunciator Panels A I AA I B I C D E F G NOTE 1: The Emergency Coordinator should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

NEI 99-01 Rev., 5 IC:

Unplanned loss of safety system annunciation or indication in the control room for 15 minutes or longer.

FPB loss/potential loss:

N/A Mode Applicability:

1-Power operations, 2-startup, 3-hot shutdown, 4-hot standby Basis:

This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment. Recognition of the availability of computer based indication equipment is considered (PPCS and SAS).

"Planned" loss of annunciators or indicators includes scheduled maintenance and testing activities.

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indications are lost, there is an increased risk that a degraded plant condition could go undetected.

It is not intended that plant personnel perform a detailed count of the instrumentation lost but the use of judgment by the Shift Manager as the threshold for determining the severity of the plant conditions.

A 75% loss of annunciators is defined as loss of 6 of the 8 annunciator panels listed on Table 7.3. Loss of 75% of Control Room safety indications is loss of 75% of the indications on the center and left sections of the main control board indications.

ATTACHMENT (2)

Page 2-1

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptable power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification.

The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the Unusual Event is based on EAL 7.1.1, Inability to Reach Required Shutdown Within Technical Specification Limits.

Annunciators or indicators for this EAL must include those identified in the Abnormal Operating procedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.).

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Due to the limited number of safety systems in operation during cold shutdown, refueling, and defueled modes, this EAL is not applicable during these modes of operation.

This Unusual Event will be escalated to an Alert based on a concurrent loss of compensatory indications or if a SIGNIFICANT TRANSIENT is in progress during the loss of annunciation or indication.

PEG Reference NEI 99-01 Revision 5: SU3.1 Basis Reference(s):

None ATTACHMENT (2)

Page 2-2

7.0 Equipment Failures 7.3 Loss of Indications /Alarms I Communication Capability 7.3.3 Alert Unplanned loss of the following for 15 minutes or longer:

6 or more Control Room Annunciator Panels listed in Table 7.3 OR An approximate 75% reduction in Control Room safety system indications AND EITHER A SIGNIFICANT TRANSIENT is in progress OR Compensatory indications are unavailable Table 7.3 Control Room Annunciator Panels A 1AA I B I C I D E F G NOTE 1: The Emergency Coordinator should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

NEI 99-01 Rev. 5 IC:

Unplanned loss of safety system annunciation or indication in the control room with either (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicators unavailable.

FPB loss/potential loss:

N/A Mode Applicability:

1-Power operations, 2-startup, 3-hot shutdown, 4-hot standby Basis:

This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a SIGNIFICANT TRANSIENT. Recognition of the availability of computer based indication equipment is considered (PPCS, SAS, etc.).

"Planned" loss of annunciators or indicators includes scheduled maintenance and testing activities.

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Manager be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation. A 75% loss of annunciators is defined as loss of 6 of the 8 ATTACHMENT (2)

Page 2-3

annunciator panels listed on Table 7.3. Loss of 75% of Control Room safety indications is loss of 75% of the indications on the center and left sections of the main control board indications.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptable power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification.

The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10CFR50.72. If the shutdown is not in compliance with the Technical Specification action, the Unusual Event is based on EAL 7.1.1 "Plant is not brought to required operating mode within Technical Specification LCO Required Action Completion Time."

Annunciators or indicators for this EAL should be limited to those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e. g., area, process, and/or effluent rad monitors, etc.).

"Compensatory indications" in this context includes computer based information such as PPCS and SAS If both a major portion of the annunciation system and all computer monitoring are unavailable, the Alert is required.

SIGNIFICANT TRANSIENT: An UNPLANNED event involving one or more of the following: (1) automatic turbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than 25% full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5) power.

thermal power oscillations greater than 10% of rated thermal Due to the limited number of safety systems in operation during cold shutdown, refueling and defueled modes, no EAL is indicated during these modes of operation.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

This Alert will be escalated to a Site Area Emergency if the operating crew cannot monitor the transient in progress due to a concurrent loss of compensatory indications with a SIGNIFICANT TRANSIENT in progress during the loss of annunciation or indication.

PEG

Reference:

NEI 99-01 Revision 5: SA4.1 Basis Reference(s):

None ATTACHMENT (2)

Page 2-4

7.0 Equipment Failures 7.3 Loss of Indications Alarms /

Communication Capability 7.3.4 Site Area Emergency Loss of the following for 15 minutes or longer:

6 or more Control Room Annunciator Panels listed in Table 7.3 OR An approximate 75% reduction in Control Room safety indications AND A SIGNIFICANT TRANSIENT is in progress AND Compensatory indications are unavailable Table 7.3 Control Room Annunciator Panels A I AA I B I C I D E F G NOTE 1: The Emergency Coordinator should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

NEI 99-01 Rev. 5 IC:

Inability to monitor a SIGNIFICANT TRANSIENT in progress.

FPB loss/potential loss:

N/A Mode Applicability:

1-Power operations, 2-startup, 3-hot shutdown, 4-hot standby Basis:

This EAL recognizes the threat to plant safety associated with the complete loss of capability of the Control Room staff to monitor the plant response to a SIGNIFICANT TRANSIENT.

"Planned" and "UNPLANNED" actions are not differentiated since the loss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not an ameliorating factor.

Quantification is arbitrary.; however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Manager be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation. A 75% loss of annunciators is defined as loss of 6 of the 8 annunciator panels listed on Table 7.3. Loss of 75% of Control Room safety indications is loss of 75% of the indications on the center and left sections of the main control board indications.

ATTACHMENT (2)

Page 2-5

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification.

The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. Ifthe shutdown is not in compliance with the Technical Specification action, the UE is based on EAL 7.1.1 "Plant is not brought to required operating mode within Technical Specification LCO Required Action Completion Time."

A Site Area Emergency is considered to exist if the Control Room staff cannot monitor safety functions needed for protection of the public while a significant transient is in progress.

Annunciators for this EAL should be limited to include those identified in the Abnormal Operating Procedures, in the CSFST's and Emergency Operating Procedures, and in other EALs (e. g., area, process, and/or effluent rad monitors, etc.).

SIGNIFICANT TRANSIENT: An UNPLANNED event involving one or more of the following: (1) automatic turbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than 25% full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5) thermal power oscillations greater than 10% of rated thermal power.

Indications needed to monitor critical safety functions necessary for protection of the public must include Control Room indications, computer generated indications and dedicated annunciation capability. The specific indications should be those used to determine such functions as the ability to shut down the reactor, maintain the core cooled, to maintain the reactor coolant system intact, maintain the spent fuel cooled, and to maintain containment intact.

"Compensatory indications" in this context includes computer based information such as PPCS and SAS.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Due to the limited number of safety systems in operation during cold shutdown, refueling and defueled modes, no EAL is indicated during these modes of operation.

PEG

Reference:

NEI 99-01 Revision 5: SS6.1 Basis Reference(s):

None ATTACHMENT (2)

Page 2-6

ATTACHMENT (3)

Red-line of NEI 99-01 Revision 5 R.E. Ginna Nuclear Power Plant, LLC May 14, 2010

SU3 iklatinga ConditioInV - iNOTIFiCATION OF iJNUSJAL iVENTI 7.0 Equipine.. Failures 7.3 Lose of Indications / Alarms / Communications Capability 7.3.1 UNUSUAL EVENT

-UNPLANNED loss of safety system annunciation or indication in the control room for 15 minutes or longer.

Operating Mode Applicability: 1 Power Operation, 2 Startup, 4 Hot Standby, 3Hot Shutdown Example Emergency Action Level:

R I60 Ti.k emrruge~y L:-p:~tur Ji:u

,,RiCAOt w...tit U : ieap

• i Iiczblc time has elapsed, but shouild dpclarcp thc c':ent zz 69oR 29 it A~ dcterPMincd that thp ro.,ndition ha;^crlccdcd9,r Will likely emeced, the applicabic time.

47UNPLANNED Loss of grceter than approx~m.tely 75% of the following for 15 minutes or longer:

a- (Site ze-ifie; cn-reol room safety; *ystem iRR;*n;*tin) 6 or more Control Room Annunciator Panels listed in Table 7.3 OR 49 Sit1e, spee ific contro! room saifety systcl I~EN~GaVR)

An approximate 75% reduction in Control Room safety system indications Table 7.3 Control Room Annunciator Panels I

ATTACHMENT (3)

Page 3-1

B C1 NOTE 1: The Emergency Coordinator should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

Basis:

This IGC aRnd it; aaSScatd EAL arc intcndcd to recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment.

Recognition of the availability of computer based indication equipment is considered [eg,-POS-P "Planned" loss of annunciators or indicators includes scheduled maintenance and testing activities.

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10CFR50.72. If the shutdown is not in compliance with the Technical Specification action, the NOUU is based on 6U 7 "Inability to Reach Required Shutdown Within Technical Specification Limits."

[Site &pesi& &Annunciatorsor indicatorsfor this EAL must include those identified in the Abnormal Operating Procedures,in the Emergency Operating Procedures,and in other EALs (e.g., area, process, and/oreffluent rod monitors, etc.)4 Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

JDue to the limited number of safety systems in operation during cold shutdown, refueling, and defueled modes, no X is indic'tcdk t during these modes of operation.4 ATTACHMENT (3)

Page 3-2

This PIQU n a t will be escalated to an Alert based on a concurrent loss of compensatory indications or if a SIGNIFICANT TRANSIENT is in progress during the loss of annunciation or indication.

PEG Reerence ATTACHMENT (3)

Page 3-3

SA4 iniliiring naiiion

- AW0"%:

m.

qimntFiue

-UNPLANNED Loss of safety system annunciation or indication in the control room with EITHER (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicators unavailable.

Oper-ati-.. Mode Applicability: I- Power Operation, 2. Startup, 4 - Hot Standby, 3 Hot Shutdown Example-Emergency Action Level:

Notc The Emergcncy Director. shoul d not wait until the applica-ble timcl has elapsed, but shoul'd declare the event as soon as it isdeteFrmind that the conAd-itin has excccedcd, or Will Iifcly exced, the as~licable time-.

UNPLANNED loss Of fgreate ;An

,, roxiac *!;'75% of the following for 15 minutes or longer:

0 (Site specific conrol1 room safety system an~nuniation) 0 (Site specific control- re-Am. safiety system indication)

OR b, ANEITHER ef the fiellewng:

• A SIGNIFICANT TRANSIENT is in progress.

ATTACHMENT (3)

Page 3-4

0 Compensatory indications are unavailable.

NOTE 1: The Emergency Coordinator should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

Basis:

This IC-s .nte.dcdto recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a SIGNIFICANT TRANSIENT.

{Recognition of the availabilityof computer based indicationequipment is considered SP, P eremput~efr-,ek-e4 ( Aec "Planned" loss of annunciators or indicators includes scheduled maintenance and testing activities.

Quantification is arbitrary; however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift .pe..e. be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the NO Un a is based on SIU2 "Inability ATTACHMENT (3)

Page 3-5

tA ReaEh "Plant is not brought to Required Sh-tdewOea.M Within Technical Specification Im~ tI LCO R ."

[.eSite6peeife nnunciatorsor indicatorsfor this EAL should be limited those identified in the Abnormal OperatingProcedures,in the Emergency OperatingProcedures,and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.).]

"Compensatory indications" in this context includes computer based information such as SPD a SA.[This sheuld inrdk d Pill eorn puticr sycstens 'alkibie foF this use depending on spcecifi pient design and subsqu*nct etrofit-.] If both a major portion of the annunciation system and all computer monitoring are unavailable, the Alert is required.

{Due to the limited number of safety systems in operation during cold shutdown, refueling and defueled modes, no 4 E is indicatedduring these modes of operation.4 Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

This Alert will be escalated to a Site Area Emergency if the operating crew cannot monitor the transient in progress due to a concurrent loss of compensatory indications with a SIGNIFICANT TRANSIENT in progress during the loss of annunciation or indication.

ATTACHMENT (3)

Page 3-6

886 Initiating Condition -IT 7.0 ailure ARE6-AEMRGENCY Equpment

-Inability to monitor a SIGNIFICANT TRANSIENT in progress.

OpiratinWgMode Applicability: I- Power Operation, 2 - Startup, 4 Hot Standby, 3- Hot Shutdown fiample Emergency Action Level:

Notei The Emergcnce; Dircctor she, d not wAMit un'til the applicable tome has elapsed, but -hou Id deecarc the eve'nt as s9on as it isdctcrMincd thait the conRditio-n has e,~cccdcd, or wilI likely cxcced, the appliczible timc.

i. a. Loss of grfeacr thn a ^" %of the following for 15 minutes or longer:

• p,,,,a*,eIm'

" (Site spccific contro room saifety system zlnnunciztien)

OR

" (Site spccifie control room Safety system indieatien)

OR AND b9. A SIGNIFICANT TRANSIENT is in progress AND ATTACHMENT (3)

Page 3-7

e-. Compensatory indications are unavailable.

NOTE 1: The Emergency Coordinator should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

Basis:

This ICi: intndcd to recognize the threat to plant safety associated with the complete loss of capability of the Control Room staff to monitor plant response to a SIGNIFICANT TRANSIENT.

"Planned" and "UNPLANNED" actions are not differentiated since the loss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not an ameliorating factor.

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift -pe,-seMage be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the NQU U is based on SC2I"- li*l,,,

to Refph Required Shutdown Within Technical Specification Pm4ts ATTACHMENT (3)

Page 3-8

A Site Area Emergency is considered to exist if the control room staff cannot monitor safety functions needed for protection of the public while a significant transient is in progress.

• ....pe.-" 4nnunciators for this EAL should be limited to include those identified in the Abnormal Operating Procedures,i in the Emergency OperatingProcedures,and in other EALs (.g.,

area,process, and/oreffluent radmonitors, etc.)j Sete eeife4

.. ndications needed to monitor safety functions necessary for protection of the public must include control room indications, computer generated indications and dedicated annunciation capability.

JThe specific indicationsshould be those used to determine such functions as the ability to shut down the reactor,maintain the core cooled, to maintain the reactorcoolant system intact, maintain the spentfuel cooled, and to maintaincontainment intact.4 "Compensatory indications" in this context includes computer based information such as 6PDa S . This should include all computer systems available for this use depending on specific plant design and subsequent retrofits.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

fDue to the limited number of safety systems in operation during cold shutdown, refueling and defueled modes, no X EAL is indicatedduring these modes of operation.j PEG Reennce ATTACHMENT (3)

Page 3-9

ATTACHMENT (4)

Clean Copy of Proposed Ginna EALs R.E. Ginna Nuclear Power Plant, LLC May 14, 2010

7.3 Loss of Indications/Alarm/Communication Capability GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT PROCEED TO EPIP-1-4 PROCEED TO EPIP-1-3 PROCEED TO EPIP-1-2 PROCEED TO EPIP-1-1 7.3.4 7.3.3 7.3.1 Loss of the following for Unplanned loss of the following Unplanned loss of the following 15 minutes or longer: for 15 minutes or longer: for 15 minutes or longer:

6 or more of the following 6 or more of the following 6 or more of the following Control Room Annunciator Control Room Annunciator Control Room Annunciator Panels Panels Panels

-A -A -A

-AA -AA -AA

-B -B -B

-C -C -C

-D -D -D

-E -E -E

-F -F -F

-G -G -G OR OR OR An approximate 75% reduction An approximate 75% reduction An approximate 75% reduction in Control Room safety system in Control Room safety system in Control Room safety system indications indications indications AND AND EITHER (See Note 1)

A significant transient in A significant transient in Mode Apolicability:

progress progress - (1) Power Operations AND OR - (2) Startup Compensatory indications are Compensatory indications are - (3) Hot Shutdown unavailable] unavailable - (4) Hot Standby (See Note 1) (See Note 1)

Mode Applicability: Mode Applicability:

- (1) Power Operations - (1) Power Operations

- (2) Startup - (2) Startup

- (3) Hot Shutdown - (3) Hot Shutdown

- (4) Hot Standby - (4) Hot Standby I .1. I NOTE 1: The Emergency Coordinator should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

ATTACHMENT (4)

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ATTACHMENT (5)

Plant-Specific EAL Guideline Cross Reference R.E. Ginna Nuclear Power Plant, LLC May 14, 2010

ATTACHMENT (5)

Plant-Specific EAL Guideline Cross Reference This Attachment compares the Plant-Specific EAL Guideline (PEG) references between NUMARC/NESP-007 and NEI 99-01 Revision 5 Ginna EAL NUMARC/NESP-007 PEG NEI 99-01 Revision 5 PEG 7.3.1 SU3.1 SU3.1 7.3.3 SA4.1 SA4.1 7.3.4 SS6.1 SS6.1 ATTACHMENT (5)

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ATTACHMENT (6)

EAL Differences and Deviations R.E. Ginna Nuclear Power Plant, LLC May 14, 2010

ATTACHMENT (6)

EAL Differences and Deviations This Attachment lists the differences and deviations for each EAL. NRC Regulatory Issue Summary (RIS) 2003-18 Supplement 2 defines Difference and Deviation for EAL changes.

Difference and Deviation A difference is an EAL change where the basis scheme guidance differs in wording but agrees in meaning and intent, such that classification of an event would be the same, whether using the basis scheme guidance or the site-specific proposed EAL. Examples of differences include the use of site-specific terminology or administrative reformatting of site-specific EALs.

A deviation is an EAL change where the basis scheme guidance differs in wording and is altered in meaning or intent, such that classification of the event could be different between the basis scheme guidance and the site-specific proposed EAL. Examples of deviations include the use of altered mode applicability, altering key words or time limits, or changing words of physical reference (protected area, safety-related equipment, etc.).

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Current Ginna EAL NEI EAL Revised Ginna EAL 7.3.1 SU3.1 7.3.1 Unplanned loss of annunciators UNPLANNED Loss of greater than Unplanned loss of the following or indications on any of the approximately 75% of the for 15 minutes or longer:

following Control Room Panels following for 15 minutes or 6 or more of the following for greater than 15 minutes longer: Control Room Annunciator A,AA,B,C,D,E,F,G (Site specific control room safety panels A,AA,B,C,D,E,F,G AND system annunciation) OR increased surveillance is OR An approximate 75% reduction required for safe plant operation (Site specific control room in Control Room safety system

, safety system indication) indications Site Specific 0 Added site specific annunciators that have safety system annunciation.

0 Defined safety system indications as the center and left sections of the main control board.

Difference None Deviation None ATTACHMENT (6)

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Current Ginna EAL NEI EAL Revised Ginna EAL 7.3.3 SA4.1 7.3.3 Unplanned loss of annunciators UNPLANNED loss of greater than Unplanned loss of the following or indications on any of the approximately 75% of the for 15 minutes or longer:

following Control Room Panels following for 15 minutes or 6 or more of the following for greater than 15 minutes longer: Control Room Annunciator A,AA,B,C,D,E,F,G (Site specific control room safety panels A,AA,B,C,D,E,F,G AND system annunciation) OR increased surveillance is (Site specific control room safety An approximate 75% reduction required for safe plant operation system indication) in Control Room safety system AND EITHER EITHER of the following: indications A plant transient in progress

• A SIGNIFICANT TRANSIENT is AND EITHER OR in progress. A significant transient in PPCS is unavailable

• Compensatory indications progress are unavailable. OR Compensatory indications are unavailable Site Specific 0 Added site specific annunciators that have safety system annunciation.

• Defined safety system indications as the center and left sections of the main control board.

Difference None Deviation None ATTACHMENT (6)

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Current Ginna EAL NEI EAL Revised Ginna EAL 7.3.4 SS6.1 7.3.4 Loss of annunciators or Loss of greater than Loss of the following for 15 indications on any of the approximately 75% of the minutes or longer:

following Control Room Panels following for 15 minutes or 6 or more of the following A,AA,B,C,D,E,F,G longer: Control Room Annunciator AND (Site specific control room safety panels A,AA,B,C,D,E,F,G Complete loss of ability to system annunciation) OR monitor any critical safety OR An approximate 75% reduction function status (Site specific control room safety in Control Room safety system AND system indication) indications A plant transient in progress AND AND A SIGNIFICANT TRANSIENT is in A significant transient in progress. progress AND AND Compensatory indications are Compensatory indications are unavailable, unavailable Site Specific 0 Added site specific annunciators that have safety system annunciation.

• Defined safety system indications as the center and left sections of the main control board.

Difference None Deviation None ATTACHMENT (6)

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