ML110410176

Email, Request for Additional Information, Request to Implement Emergency Action Level Schemes Based on NEI 99-01, Revision 5

ML110410176
Person / Time
Site:	Waterford
Issue date:	02/10/2011
From:	Kalyanam K Plant Licensing Branch IV
To:	Steelman W Entergy Operations
Kalyanam N, NRR/DORL/LPL4, 415-1480
References
TAC ME4726
Download: ML110410176 (4)

Text

From: Kalyanam, Kaly Sent: Thursday, February 10, 2011 10:28 AM To: 'wsteelm@entergy.com' Cc: Lent, Susan; Burkhardt, Janet

Subject:

RAI on the proposed revision to the Emergency Plan (EP) Emergency Action Levels (EALs)

The SUNSI information as follows:

Plant: Waterford Steam Electric Station, Unit 3 Docket No.: 50/382

Subject:

RAI on the proposed revision to the Emergency Plan (EP) Emergency Action Levels (EALs) Using NEI 99-01 Revision 5 Scheme TAC Nos.: ME4726 SUNSI Review Done: Yes. Publicly Available, Normal Release, Non-sensitive, From: N. Kalyanam To: W. Steelman Mr. Steelman, By letter dated September 16, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102630124), Entergy Operations, Inc. submitted a request for Nuclear Regulatory Commission (NRC) review and approval of revisions to the Emergency Plan (EP) Emergency Action Levels (EALs) for Waterford Steam Electric Station, Unit 3.

The proposed EP changes would incorporate EALs based on the NRC-endorsed methodology in Nuclear Energy Institute (NEI) 99-01, Revision 5, Methodology for Development of Emergency Action Levels, dated February 22, 2008 (ADAMS Accession No. ML080450149). To complete its review, the Nuclear Regulatory Commission (NRC) staff requests responses to the following request for additional information. Please note that the majority of the questions request a justification for a deviation from the wording in NEI 99-01, Revision 5.

When responding to these questions, you may propose to revise the wording in accordance with the endorsed guidance in lieu of providing the requested justification.

Information Requests Related to Attachment 3 to W3F1-2010-0052, Proposed Regarding EAL Technical Bases Document:

Thanks Kaly

DRAFT REQUEST FOR ADDITIONAL INFORMATION WATERFORD STEAM ELECTRIC STATION, UNIT 3 EMERGENCY ACTION LEVEL SCHEME CHANGE TO NEI 99-01, REVISION 5 DOCKET NO. 50-382

1. To prevent confusion with classification, and to ensure site-specific terminology is used when appropriate, please provide site-specific definitions for Protected Area and Vital Area.

2. Regarding EALs CU8 and SU8, the list of offsite communication methods in Tables C2 and M2 should include only the communications systems that can be used to readily perform required notifications for license event classification and protective action recommendations to State and local response agencies, as well as the NRC. Provide documentation the supports the conclusion that the stated list of offsite communication systems can perform as expected.

3. Regarding EAL CS1, justify why the following EAL from the endorsed guidance is not included:

With CONTAINMENT CLOSURE established RCS/RPV level less than (site specific level for TOAF).

4. Regarding EAL CG1, justify why the following EAL from the endorsed guidance is not included:

RCS/RPV level less than (site specific level of TOAF) for 30 minutes or longer.

AND

Any containment challenge indication (see Table).

5. Regarding EAL E-HU1, the example EAL introduces the phrase resulting in radiation readings > 10 times normal levels. While EAL E-HU1 in Revision 5 to NEI 99-01 specifies declaration of an Unusual Event involving any damage to a loaded cask, the additional phrase could result in failure to classify such an event depending on the extent of damage to the cask. Either revise the EAL E-HU1 to follow the guidance in Revision 5 to NEI 99-01 or provide additional justification for the changes in wording of the EAL.

6. Justify why a table corresponding the PWR EAL Fission Product Barrier Table in Revision 5 to NEI 99-01 has not been provided.

7. It is understood that Waterford 3 does not use Critical Safety Function Status Trees (CSFSTs) and that the guidance Revision 5 to NEI 99-01 states that the CSFST EALs only apply to PWRs that use Critical Safety Function Status Trees monitoring and functional restoration procedure. However, licensees are to describe the functional equivalent of the CSFSTs used at Waterford 3. In addition, justify why this equivalent methodology is not used in the fission product barrier degradation EAL.

8. Regarding EAL SG1, one of the site-specific EAL examples of an indication of the continuing degradation of core cooling is FA1 entry conditions met. Discuss what those entry conditions are and justify why they are not included in the example EAL. In order to ensure 10 CFR 50.54(q) requirements are maintained, EAL thresholds must be documented within the emergency plan.

9. The guidance in Revision 5 to NEI 99-01 states in part that the site-specific list of areas within the protected area should be limited to buildings and areas in actual contact with or immediately adjacent to Vital Areas or other areas significant buildings or areas. Immediately adjacent implies that the area contains, or may contain, equipment or cabling that could impact equipment located in Vital Areas or the fire could damage equipment inside the Vital Areas or that precludes access to Vital Areas. Describe how the list of areas in EALs HU2 and HA4 were determined. In addition, the areas must be identical for these two EALs.

10. The guidance in Revision 5 to NEI 99-01 states that the site-specific areas impacted by internal flooding should include those areas that contain systems required for safe shutdown of the plant, which are not designated to be partially or fully submerged. Describe how the list of areas in EALs HU6 and HA6 were determined.

11. The Recognition Categories other than Cold Shutdown/Refueling System Malfunction EALs contain a note in the EAL section that states:

The Emergency Coordinator should not wait until the applicable time has elapse, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

The corresponding note in Revision 5 to NEI 99-01 includes the phase has exceeded, or will likely exceed after condition. The justification provided for deleting the phrase is that the phrase is not used in the Recognition Category Cold shutdown/Refueling System Malfunction and is used in other Recognition Categories for clarity and consistency. Either provide additional justification to support the elimination of the phrase has exceeded, or will likely exceed, or revise the notes to follow the standard classification scheme in Revision 5 to NEI-99-01.