ML112093555

Draft RAI on the Proposed Revision to the Emergency Action Levels

ML112093555
Person / Time
Site:	Cook
Issue date:	07/27/2011
From:	Tam P Plant Licensing Branch III
To:	Etheridge H, Scarpello M, Waters J American Electric Power
Tam P
References
TAC ME5666, TAC ME5667
Download: ML112093555 (5)

Text

Accession No. ML112093555 From: Tam, Peter Sent: Wednesday, July 27, 2011 10:09 AM To: Etheridge, Helen <hletheridge@aep.com>; Joe Waters (jrwaters@aep.com);

mkscarpello@aep.com Cc: Anderson, Joseph; Norris, Michael

Subject:

D.C. Cook 1 and 2 - Draft RAI on the proposed revision to the EAL (TAC ME5666, ME5667)

Helen:

By letter dated February 8, 2011, Indiana Michigan Power Company (I&M) requested prior approval of a revised emergency action level (EAL) scheme for Donald C. Cook Nuclear Power Plant, Unit Nos. 1 and 2 (CNP).

I&Ms letter stated that the current CNP EAL scheme is based on generic development guidance from NUMARC/NESP-007, Methodology for Development of Emergency Action Levels, Revision 2, dated January 1992 (ADAMS Accession No. ML041120174). Since 1992, numerous enhancements and clarification efforts have been made to the generic EAL development guidance, resulting in the latest document, Nuclear Energy Institute (NEI) 99-01, Revision 5, Methodology for Development of Emergency Action Levels (ADAMS Accession No. ML080450149), which was found to be acceptable for use as generic EAL development guidance by the NRC staff by letter dated February 22, 2008 (ADAMS Accession No. ML080430535).

The proposed EAL schemes were developed using the generic development guidance from NEI 99-01, Revision 5, with numerous differences and deviations based upon design criteria applicable to the site as well as licensee preferences for terminology, format, and other licensee-desired modifications to the generic EAL scheme provided in NEI 99-01 Revision 5.

The Office of NSIR, Division of Preparedness and Response, Operating Reactor Licensing and Outreach Branch staff has reviewed I&Ms submittal and has developed the following draft RAI questions. You may choose to accept this e-mail as a formal RAI and formally respond to the questions (below) within 45 days of receipt of this e-mail, or request to discuss these questions with the NRC staff in a teleconference. If a teleconference is held, we will discuss, among other things, a mutually acceptable schedule for responding to these questions.

1. GENERAL: NEI 99-01, Revision 5 includes a timing Note with certain EALs regarding when the Emergency Director should declare an event. This has been included as a footnote in the DC Cook submittal, but not included as a note in the applicable EAL. For human factors considerations and timeliness, this note is included in the appropriate EALs in the generic guidance document. Please clarify why this timing note has not been included in the applicable EALs, or revise accordingly to include as applicable.

2. Definitions: Please provide site-specific definitions for the following:

a. Containment Closure,

b. Protected Area, and

c. Vital Area.

Additionally, EAL RG1 provides a site-specific definition of Site Boundary. If this is to be used as a defined term, clarify why the term is not included in the list of defined terms, or revise the list accordingly to include this term.

3. Table H-1: Please confirm that the areas as listed in Table H-1 are the areas CNP will use for EALs. The areas of concern should be limited to those that must be entered for safe operation or safe shutdown/cooldown. If access to the area is unnecessary to operate said equipment, then the table does not need the area listed. Additionally, clarify whether the emergency diesels are located in one of the listed Table H-1 areas.

4. Tables F-1 and F-2 have the radiation monitors with the designation VRS, while the EALs have the designation VRA. Please verify correct designation, or revise accordingly to remove any inconsistency.

5. EAL FC2(L): PMP-2080-EPP-101, Rev. 14 indicates an EAL threshold of Assessment of core damage greater than 5% clad failure with an associated NRC commitment #7991. However, this is not indicated in the proposed EAL change.

Please provide an explanation about the commitment and why this EAL should not be included under proposed EAL changes, or revise accordingly to reflect a proposed EAL change.

6. EAL CT8(PL): PMP-2080-EPP-101, Rev. 14 indicates an EAL threshold of Containment hydrogen concentration greater than 0.5 % AND any hydrogen control equipment (Containment air recirculation/hydrogen skimmer systems, electric hydrogen recombiner OR igniters) inoperable. However, this is not indicated in the proposed EAL change. Please clarify why this EAL should not be included under proposed EAL changes, or revise accordingly to reflect a proposed EAL change.

7. EALs RA1 and RU1: Site-specific Basis EAL #2 has a statement related to discharges performed by different flowpaths other than those used normally. Please clarify why this was not included in the EAL as a note to ensure timely and accurate classifications, or revise accordingly.

8. EAL RA1: Site-specific Basis EAL #2 has a statement regarding the offscale high meter for 15 minutes or longer. This information should be included in the EAL as a note to ensure timely and accurate classifications. Additionally, please explain how offscale high reading will be differentiated from instrument error and how determination could be made in a timely manner.

9. EAL RA2: Site-specific Basis EAL #2 provides that VRS-5000 detector has a sensitivity range from 0.01 mR/hr to 100 mR/hr, but remains operational to 10 R/hr.

Please clarify if the detector is accurate enough at 1 R/hr to be used for event classification. Additionally, clarify where indication for this meter is provided.

10. EAL RU2: Please clarify how and where the site-specific water level is read.

11. EAL RA3: Please clarify whether there are site-specific area radiation monitors used to provide this indication, and if so, why they are not referenced in the EAL.

Additionally, both the CAS and SAS are listed. Typically, if the site can function adequately with only CAS, then only CAS needs to be reflected in this EAL. Please explain why both facilities are needed, or revise to reflect CAS or SAS as appropriate.

12. EAL HG1.2: Please explain why the text freshly off-loaded reactor core in pool was eliminated from the EAL, or revise accordingly to include, since it is information included in the site-specific Basis EAL #2.

13. EAL HA1: Please explain why the note regarding communication between the Security Shift Supervision and the Control Room has been eliminated from the basis statement, or revise accordingly to address. Additionally, explain why information related to the ISFSI is not included in the basis, or revise accordingly.

14. EALs HS2 and HA2: Site-specific Basis provides information that could be used to determine the applicability of this EAL. Please clarify why this information is not included as a note to the EAL to facilitate timely and consistent classification.

15. EAL HA3.1a: The generic guidance discusses that this EAL is an escalation from HU3 due to visible damage to plant structures containing equipment necessary for safe shutdown or has caused damage to safety systems as evidenced by control indication of degraded system response or performance. The site-specific EAL is a confirmed seismic event that requires a reactor trip or shutdown. Site-specific Basis EAL #1 discusses that a reactor trip is required if reactor or turbine operation is not normal. It also discusses the determination of this event in other operating modes. Please explain how this determination would be performed and associated timeliness considering the reactor and turbine are shut down in the other listed modes.

Additionally, please provide a technical basis to justify that the EAL, as written, meets the intent of the endorsed guidance.

16. EALs HA3.2 and HU3.2: Please explain that 90 mph is within the calibrated range of the instrumentation available in the Control Room.

17. EALs HA3.4 and HU3.4: Please identify where and how lake level is read.

18. EAL HU3.1.b: Additional qualifying information power block (not office buildings) is not consistent with the endorsed guidance. Please provide a technical basis to justify the addition of this qualifier, or revise accordingly consistent with endorsed guidance.

19. EAL HA5: Please explain why the Initiating Condition was revised from the language in NEI 99-01 Rev 5, since this revised wording could affect the declaration, or revise accordingly to address endorsed guidance.

20. EAL HU8: The endorsed guidance has this ISFSI-specific EAL as a stand-alone EAL.

The submittal proposes to incorporate this EAL into one of the pre-existing categories.

Please provide technical justification for this deviation from the endorsed guidance and explain: (1) why the Hazards Category was chosen in lieu of Abnormal Radiation Category, and (2) why the use of this category will not cause an unnecessary delay in classification. Additionally, explain why the basis does not include the language related to security events for the ISFSI.

21. EAL SS2: Please verify that the cited basis references are correct. (Note: The text refers to SD-DCC-PS104; the cited reference is SD-DCC-NEEP-104, 250 VDC System.)

22. EALs SU3 and CU3: Site-specific Basis includes intermediate range channels and neutron flux wide range instruments. Please clarify whether or not instrumentation cited provides startup rate indication.

23. EAL SS4: Please provide technical justification as to why language related to planned and unplanned actions contained in NEI 99-01(Rev. 5) was not included, or revise accordingly to address endorsed guidance.

24. EAL SS4, SU4: Please provide technical justification as to why the paragraph on Planned and Unplanned actions contained in NEI 99-01 (Rev. 5) was omitted from the generic basis discussion in the current DC Cook submittal, or revise accordingly to address endorsed guidance.

25. EAL SA4: Please provide technical justification as to why the discussion of Planned loss of annunciators or indicators contained in NEI 99-01 (Rev. 5) was omitted from the generic basis discussion in the current DC Cook submittal, or revise accordingly to address endorsed guidance.

26. EALs SU6 and CU6: The list of communication options for offsite communications must be limited to communication systems that can readily perform required notifications for licensee event classification and protective action recommendations to State and local response agencies, as well as the NRC. Please provide documentation that supports the conclusion that the stated list of offsite communication systems can perform as expected.

27. EAL CU7: Site-specific Basis provides information that could be used to determine the applicability of this EAL. Please explain why this information was not included as a note to the EAL to support timely and consistent classification.

28. EAL CA10.2: Table C-2 has durations listed as >60 minutes. NEI 99-01 (Rev. 5) has these durations listed as >60. Please explain this deviation, or revise accordingly to address endorsed guidance.

29. EAL CA10, CU10: Please verify that the cited basis references are correct. (Note: It appears that 1(2)-OHP-4022-001 should be 1(2)-OHP-4022-004 based on writeups on page 157 and 160.)

30. EAL CU10: Please explain why the Initiating Condition was revised from the language in NEI 99-01 Rev 5, since this revised wording could affect the declaration, or revise accordingly to address endorsed guidance.

Peter S Tam, Senior Project Manager (for D. C. Cook and Monticello)

Plant Licensing Branch 3-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Tel. 301-415-1451