ML112070459

Draft Request for Additional Information EAL Upgrade

ML112070459
Person / Time
Site:	Columbia
Issue date:	04/26/2011
From:	Dante Johnson Office of Nuclear Security and Incident Response
To:	Linda Williams Energy Northwest
Thadani M, NRR/DLPM, 415-1476
Shared Package
ML112070405	List: ML112070415 ML112070426 ML112070459
References
TAC ME4589
Download: ML112070459 (2)

Text

Columbia Generating Station U.S. Nuclear Regulatory Commission Request for Additional Information (RAI)

Emergency Action Level Scheme Change to NEI 99-01, Revision 5 Format DRAFT RAI # EAL Question Due to recurring issues within the industry, please confirm that all stated values, set points, and indications provided are within the 1 General calibrated range of the applicable instrumentation and that the instrumentation is appropriate for the specific EAL.

Please provide documentation on the two new 618-11 site-specific Emergency Action Levels that were approved for addition to the 2 General site emergency plan as outlined in License Amendment No.218 in response to the licensees application dated April 28, 2010.

This section does not contain information on the treatment of Section 2.0 multiple events and classification upgrading as outlined in the 3

Discussion endorsed guidance. Please provide justification for this inconsistency, or revise accordingly per endorsed guidance.

Initiating Condition lists Unexpected rise in plant radiation which is inconsistent with the endorsed guidance that lists this Initiating 4 RU2.1 Condition as Unplanned rise in plant radiation. Please provide justification for this inconsistency, or revise accordingly per endorsed guidance.

Initiating Condition in Technical Bases document lists Unexpected rise in plant radiation which is inconsistent with the endorsed 5 RU2.2 guidance that lists this Initiating Condition as Unplanned rise in plant radiation. Please provide justification for this inconsistency, or revise accordingly per endorsed guidance.

Emergency Action Level lists Any unexplained RPV leakage indication, Table C-1 which is inconsistent with the endorsed 6 CG3.2 guidance that lists this EAL as Unplanned level rise in (site specific sump or tank). Please provide justification for this inconsistency, or revise accordingly per endorsed guidance.

The Emergency Action Level states, Multi Purpose Container (MPC) CONFINEMENT BOUNDRY breach. As worded this EAL would require an actual breach of the boundary versus damage to 7 EU1.1 the confinement boundary for EAL declaration. Please provide justification for this inconsistency, or revise accordingly per endorsed guidance.

Columbia Generating Station U.S. Nuclear Regulatory Commission Request for Additional Information (RAI)

Emergency Action Level Scheme Change to NEI 99-01, Revision 5 Format DRAFT Clarify if Table C-4/S-2, Communications Systems, includes the CU5.1 8 Health Physics Network, communication systems as required by SU6.1 the endorsed guidance.

HU1.4 HU2.1 HA1.2 Table H-1 uses the term in vicinity of associated with the 9 HA1.4 referenced structures which is inconsistent with endorsed HA1.3 guidance. Please provide justification for this inconsistency, or HA1.5 revise accordingly per endorsed guidance.

HA2.1 HA3.1 Clarify the process / instrumentation used to perform the calculation to subtract reactor building closed cooling water from 10 SU8.1 the unidentified leakage total and the timeliness of this process.

The Initiating Condition uses the term Security Defined Owner IC HA4 Controlled Area which is inconsistent with the endorsed guidance.

11 Please provide justification for this inconsistency, or revise EAL HA4.1 accordingly per endorsed guidance.

1. Fuel Clad Barrier L.1 lists PC flooding required (SAG entry) due to either: which is inconsistent with the endorsed guidance. Please provide justification for this inconsistency, or revise accordingly per endorsed guidance

2. Containment Barrier PL.1 lists PC flooding required (SAG Fission entry) due to either: and lists two entry requirements which 12 Product is inconsistent with the endorsed guidance. Please provide Barrier justification for this inconsistency, or revise accordingly per Matrix endorsed guidance.

3. Containment Barrier L.3 removed the endorsed guidance wording after primary containment isolation signal which is inconsistent with the endorsed guidance. Please provide justification for this inconsistency, or revise accordingly per endorsed guidance.