ML102080252
| ML102080252 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 07/22/2010 |
| From: | Plant Licensing Branch III |
| To: | |
| DiFrancesco N, NRR/DORL/LPL3-2, 415-1115 | |
| Shared Package | |
| ML102080238 | List: |
| References | |
| Download: ML102080252 (4) | |
Text
Exelon EAL Upgrade Project NRC Request for Additional Information Three Mile Island TMIDraftRAIs pg.1 RAI #
EAL Question GENERIC It is expected that licensees adhere to endorsed guidance, particularly for Initiating Conditions and Definitions, with no differences or deviations other than those related to a licensees particular design. This is to ensure regulatory stability of the 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. As such, where applicable, the NRC staff will be identifying areas where it recommends that the endorsed guidance be used to ensure implementation of a standard scheme based upon industry and NRC staff experience with issues related to a particular EAL.
In addition, when inconsistent formatting is perceived to result in potential misunderstanding, an RAI will be developed to obtain additional information in support of the deviation.
1 GENERAL
- 1. Confirm that all stated values, set points, and indications provided are within the calibrated range of the applicable instrumentation and that the instrumentation is appropriate for the EAL.
- 2. Off-scale high or low thresholds are usually not within the calibrated range of instrumentation. Explain how the EALs that use one or the other of these thresholds will not be confused with failed instrumentation.
- 3. Correct the following errors on the NEI Initiating Condition (IC) Cross-Reference Table, or provide further clarification for apparent errors, to ensure a quality EAL Technical Basis Document:
- a. MU2 (Exelon) not reflected as CU3 (NEI), and
- b. HS4 (Exelon) incorrectly referenced versus HS2 (Exelon).
- 4. 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. Clarify whether these sections will be incorporated into the document, or document in the technical basis why information should be incorporated.
- 5. Provide missing EAL Basis Document pages 3-10 through 3-26 to support the staffs review of the entire EAL Technical Basis Document and supporting information.
- 6. The entire paragraph from Section 3.1 related to EALs are for unplanned events is not in accordance with staff expectations nor in accordance with the standard EAL scheme (Section 3.9) endorsed by the NRC. Revise accordingly to incorporate the endorsed guidance, or provide technical justification to support the deviation.
- 7. The NRC staff requests that ADAMS Accession No. ML080450149 be used to reference NEI 99-01, Revision 5, to ensure that the multiple draft copies of this document that are in ADAMS are not inadvertently referenced.
Exelon EAL Upgrade Project NRC Request for Additional Information Three Mile Island TMIDraftRAIs pg.2 RAI #
EAL Question 2
SECT 4.0 To ensure implementation of a standard emergency classification and action level scheme, it is expected that definitions are verbatim from the endorsed guidance, with the exception of terms specifically defined by the licensee,
- 1. As noted above, please provide the site-specific definitions for the following terms rather than the generic wording used in the endorsed guidance:
- a. Containment closure
- b. Protected area
- c. Vital area
- d. Owner controlled area
- 2. Specify whether site has an independent spent fuel storage facility (ISFSI),
and if so, provide the definition per endorsed guidance.
- 3. Clarify whether the term faulted is used at this site? If so, provide the definition as per endorsed guidance.
3 RG1 Explain how Offscale is an appropriate EAL threshold, since use of term could lead to confusion with degraded instrumentation and or possible untimely classification.
4 RS1 The 2nd paragraph from the endorsed guidance is not considered by the staff to be EAL Developer information. Incorporate this information to ensure consistency in understanding or provide further basis to justify this information.
5 RG1 RS1 RA1 RU1
- 1. Explain the resolution for the stated indicators, to ensure ability to read accurately on a typical logarithmic scale.
- 2. [RA1] Explain whether the value for RM-G-24 provides enough differentiation from the RS1 value.
6 RA2 RU2 Explain, in detail, why there are not other available thresholds for Operating Modes 1-4.
7 RA1 RU1 The IC states Radiological Effluent Technical Specifications/ODCM. Verify that the wording aligns with your sites document, since typically licensees use one or the other, but not both.
8 RA3 Explain why the Secondary Alarm Station (SAS) is listed in Table R2, since typically it is either CAS or SAS, but not both.
Exelon EAL Upgrade Project NRC Request for Additional Information Three Mile Island TMIDraftRAIs pg.3 RAI #
EAL Question 9
RU3 The standard EAL scheme required by 10 CFR 50.47(b)(4), and endorsed by the NRC (NEI 99-01 Revision 5), has this EAL as SU4. Explain justification for why EAL deviates from the guidance document or revise accordingly.
10 FISSION BARRIER MATRIX
- 1. Provide the Fission Barrier Matrix Table as it is part of the standard EAL scheme required by 10 CFR 50.47(b)(4) and NEI 99-01 Revision 5.
- 2. Reference lists the incorrect table from the endorsed guidance for FU1, FA1, FS1, and FG1.
11 MA2, MU3, MU4, MA5, MU5, MG8, MS8, MA8, MU8, MU9, MU10/MU6*
The standard EAL scheme required by 10 CFR 50.47(b)(4), and endorsed by the NRC (NEI 99-01 Revision 5), has these EALs in their own unique table, and own unique IC designation, for Cold/Refuel EALs. *MU10 and MU6 were also combined for Cold and Hot Operating Modes. Provide justification for this deviation from endorsed guidance, or revise accordingly.
12 MG1, MS1, MA1, MA2, MU2 Explain how the EG-Y-4 SBO Diesel Generator (DG) is addressed in your Technical Specifications, and specifically, how is this DG controlled such that it can be relied upon as part of this EAL set.
13 MU3 Explain the statement This EAL is satisfied when corrective actions are required in response to an unplanned sustained positive startup rate to mitigate the positive startup rate, since this is not from the endorsed guidance and may lead to errors in meeting staff expectations for EAL classification.
14 MU8 Explain deviation from the endorsed guidance related to restore and maintained in the Basis information, since the expectation is that level must be back above the procedurally established limit.
15 MS8 This EAL is not in alignment with the endorsed guidance and results in EAL classification that does not meet staff expectations. Provide more supporting justification for the deviation or revise accordingly to reflect the use the endorsed guidance.
16 MA8 EAL 2.a should reflect greater than or equal. Revise accordingly per endorsed guidance to correct discrepancy.
17 MU10 Explain how satellite phones can work in the plant (for onsite communications) and how the dedicated notification line can be used notify the NRC (for offsite communications) per endorsed guidance.
18 HU3 The standard EAL scheme required by 10 CFR 50.47(b)(4), and endorsed by the NRC (NEI 99-01 Revision 5), has the explosion EAL without the damage caveat. Provide justification for deviation from the endorsed guidance, or revise the threshold and Basis accordingly.
Exelon EAL Upgrade Project NRC Request for Additional Information Three Mile Island TMIDraftRAIs pg.4 RAI #
EAL Question 19 HA5 The Basis information is considered to be a deviation from the endorsed guidance and contrary to the regulatory requirement for a standard EAL scheme. The information from the endorsed guidance, particularly the 3rd paragraph, states the staffs expectations for this EAL. The 3rd and 4th paragraphs in your submittal conflict with that expectation. Please provide sufficient justification for the deviation or revise accordingly per endorsed guidance.
20 HU5 The 4th and 7th paragraphs of your Basis information are a deviation from the endorsed guidance. Please further justification, revise accordingly.