LR-N11-0249, Supplemental Response to Requests for Additional Information (Rals) for Emergency Action Level Changes
| ML112370143 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/25/2011 |
| From: | Burgin D Public Service Enterprise Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LR-N11-0249 | |
| Download: ML112370143 (19) | |
Text
PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 OPSEG Nuclear LLC 10 CFR 50, Appendix E LR-N11-0249 August 25, 2011 Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354 Salem Nuclear Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and 75 NRC Dockets Nos. 50-272 and 50-311
SUBJECT:
Supplemental Response to Requests for Additional Information (RAls) for Emergency Action Level Changes
References:
(1) Letter LR-N1 0-0355, Thomas Joyce to US NRC Document Control Desk, "EMERGENCY ACTION LEVEL CHANGES," dated October 14,2010.
(2) e-mail from Richard Ennis, NRC Project Manager, to Paul Duke, PSEG Licensing Manager, "Draft RAI - Hope Creek and Salem EAL Scheme Change," dated April 20, 2011.
(3) Letter LR-N11-0217, David Burgin to US NRC Document Control Desk, "Response to Requests for Additional Information (RAls) for Emergency Action Level Changes," dated July 14, 2011.
(4) e-mail from Richard Ennis, NRC Project Manager, to Paul Duke, PSEG Licensing Manager, "Salem/Hope Creek EAL Upgrade -
Questions re: RAI Responses," dated August 2, 2011.
In the reference 1 letter, PSEG Nuclear LLC (PSEG) submitted a request for Nuclear Regulatory Commission (NRC) approval for the adoption of revised Emergency Action Levels (EALs) for use at the Hope Creek Generating Station (HCGS) and Salem
Document Control Desk LR-N11-0249 Page 2 Nuclear Generating Station (SGS) in accordance with 10 CFR 50, Appendix E, Section IV(B)(1) and 10 CFR 50.4(b)(5). Subsequent to that submittal, the NRC provided RAls (reference 2) related to the reference 1 submittal. PSEG submitted a response to the RAls with the reference 3 letter. Subsequent to the reference 3 submittal the NRC contacted PSEG (reference 4) with a request to discuss one of the RAI responses. As a result of that discussion, PSEG has decided to amend two Hope Creek and two Salem EAL Technical Basis Documents (HA2.1 and HA2.2) and the RAI response submitted in Attachment 1 of reference 3.
PSEG hereby submits the amended response to RAI #16 as Attachment 1 and the amended EAL Technical Basis Documents HA2.1 and HA2.2 for Hope Creek and Salem in Attachments 2 and 3 respectively and requests that they serve as supplements to the corresponding documents provided in the reference 3 submittal.
This letter contains no new commitments and no revisions to existing commitments.
Should you have any questions concerning this letter, or require additional information, please contact Lee Marabella at (856) 339-1208 or Craig Banner at (856) 339-1157.
Sincerely, j!)-e/J~
David BUrg~O Manager - Emergency Preparedness Attachments (3) : Amended Salem/Hope Creek Generating Stations Response to U.S.
NRC Request For Additional Information (RAI) Emergency Action Level Scheme Change to NEI 99-01, Revision 5 for RAI #16 : HCGS Emergency Action Level Technical Bases Documents HA2.1 and HA2.2 : SGS Emergency Action Level Technical Bases Documents HA2.1 and HA2.2
Document Control Desk LR-N11-0249 Page 3 C (with attachments)
Project Manager, Hope Creek Generating Station, Salem Units 1 and 2 and Hope Creek, USNRC Regional Administrator, Region I, USNRC NRC Resident Inspector, Hope Creek, USNRC NRC Resident Inspector, Salem Units 1 & 2, USNRC C (without attachments)
Corporate Commitment Tracking Coordinator Manager, NJ Bureau of Nuclear Engineering Manager, Delaware Emergency Management Agency
ATTACHMENT 1 Salem/Hope Creek Generating Stations Amended Salem/Hope Creek Generating Stations Response to U.S. NRC Request for Additional Information (RAI) Emergency Action Level Scheme Change to NEI 99-01, Revision 5 for RAI #16
LR-N 11-0249 ATTACHMENT 1 Amended Salem/Hope Creek Generating Stations Response to U.S. Nuclear Regulatory Commission Request for Additional Information (RAI)
Emergency Action Level Scheme Change to NEI 99-01, Revision 5 for RAI #16 EAL HA2.1: Please explain why a timing Deleted the HA2.1 15 minute timing requirement.
requirement was added for this EAL. The justification The revised HA2.1 and HA2.2 bases wording includes both provided for adding a timing requirement to this EAL the VISIBLE DAMAGE and DEGRADED PERFORMANCE is not of sufficient detail and erroneously assumes threshold criteria which is in alignment with the generic that the timing basis for EAL HU2 is applicable to this EAL scheme in NEI 99-01, Rev. 05.
EAL. In addition, the necessary requirement for assessing for visible damage or degraded performance is not incorporated in this EAL (and HA2.2). Please provide further justification for these deviations, or revise this EAL to align with the generic EAL scheme development guidance.
16 I HA2.1
ATTACHMENT 2 Hope Creek Generating Stations (HCGS)
HCGS Emergency Action Level Technical Bases Document HA2.1 and HA2.2
HCGS ECG - EAL Technical Bases EP-HC-111-208 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 2 - Fire or Explosion Initiating Condition: FIRE or EXPLOSION in a VITAL AREA affecting the operability of plant safety systems required to establish or maintain safe shutdown OPCON Applicability: All EAL# & Classification Level: HA2.1 - ALERT EAL:
FIRE in ANY Table H-1 plant structure AND Resulting in ANYone of the following:
- VISIBLE DAMAGE to ANY plant structure in Table H*1
- VISIBLE DAMAGE to ANY safety system components within a Table H*1 structure
- Control Room indication of DEGRADED PERFORMANCE of a Safety System within a Table H*1 structure Table H*1 Plant Structures Containing Safe Shutdown Systems or Components
- Reactor Building
- Control/Auxiliary Building
- Service Water Intake Structure
- Service/Radwaste Building Hope Creek Page 1 of 3 Rev. 0 (RAI-2)
EAL#: HA2.1
HCGS ECG - EAL Technical Bases EP-HC-111-208 Basis:
VISIBLE DAMAGE is used to identify the magnitude of the FIRE and to discriminate against minor FIRES.
The reference to structures containing safety systems or components is included to discriminate against FIRES in areas having a low probability of affecting safe operation. The significance here is not that a safety system was degraded but the fact that the FIRE was large enough to cause damage to these systems.
The use of VISIBLE DAMAGE should not be interpreted as mandating a lengthy damage assessment prior to classification. The declaration of an Alert and the activation of the Technical Support Center will provide the Emergency Director with the resources needed to perform detailed damage assessments.
Escalation of this emergency classification level, if appropriate, will be based on EALs in Category S, System Malfunctions, Category F, Fission Product Barrier Degradation, or Category R, Abnormal Rad Levels / Rad Effluent.
Explanation/Discussion/Definitions:
The Table H-1 Plant Structures Containing Safe Shutdown Systems or Components include those plant structures identified as Seismic Category I.
Definitions:
FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.
EXPLOSION: A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components.
VITAL AREAS: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation.
PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center.
Hope Creek Page 2 of 3 Rev. 0 (RAI-2)
EAL#: HA2.1
HCGS ECG - EAL Technical Bases EP-HC-111-208 OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA.
VISIBLE DAMAGE: Damage to equipment or structure that is readily observable without measurements, testing, or analysis. Damage is sufficient to cause concern regarding the continued operability or reliability of the affected structure, system, or component. Example damage includes: deformation due to heat or impact, denting, penetration, rupture, cracking, and paint blistering. Surface blemishes (e.g., paint chipping, scratches) should not be included.
DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability (e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability:
- Electrical faults on power supplies
- Normally closed breakers in tripped position
- System annunciators activated
- System warning lights lit
- Insufficient system pressure from keep-fill pumps
- Elevated area temperatures or radiation levels
- 2. UFSAR Table 3.2-1 HCGS Classification of Structures, Systems and Components Hope Creek Page 3 of 3 Rev. 0 (RAI-2)
EAL#: HA2.1
HCGS ECG - EAL Technical Bases EP-HC-111-208 EAL Category: H - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 2 - Fire or Explosion Initiating Condition: FIRE or EXPLOSION in a VITAL AREA affecting the operability of plant safety systems required to establish or maintain safe shutdown OPCON Applicability: All EAL# & Classification Level: HA2.2 - ALERT EAL:
EXPLOSION in ANY Table H-1 plant structure AND Resulting in ANYone of the following:
- VISIBLE DAMAGE to ANY plant structure in Table H-1
- VISIBLE DAMAGE to ANY safety system components within a Table H-1 structure
- Control Room indication of DEGRADED PERFORMANCE of a Safety System within a Table H-1 structure Table H-1 Plant Structures Containing Safe Shutdown Systems or Components
- Reactor Building
- Control/Auxiliary Building
- Service Water Intake Structure
- Service/Radwaste Building Basis:
VISIBLE DAMAGE is used to identify the magnitude of the EXPLOSION and to discriminate against minor EXPLOSIONS.
Hope Creek Page 1 of 3 Rev. 0 (RAI-2)
EAL#: HA2.2
HCGS ECG - EAL Technical Bases EP-HC-111-208 The reference to structures containing safety systems or components is included to discriminate against EXPLOSIONS in areas having a low probability of affecting safe operation. The significance here is not that a safety system was degraded but the fact that the EXPLOSION was large enough to cause damage to these systems.
The use of VISIBLE DAMAGE should not be interpreted as mandating a lengthy damage assessment prior to classification. The declaration of an Alert and the activation of the Technical Support Center will provide the Emergency Director with the resources needed to perform detailed damage assessments.
The Emergency Coordinator also needs to consider any security aspects of the EXPLOSION.
Escalation of this emergency classification level, if appropriate, will be based on EALs in Category S, System Malfunctions, Category F, Fission Product Barrier Degradation, or Category R, Abnormal Rad Levels / Rad Effluent.
Explanation/Discussion/Defin itions:
If the EXPLOSION is determined to be hostile in nature, the event is classified under EAL HS4.1.
The Table H-1 Plant Structures Containing Safe Shutdown Systems or Components include those plant structures identified as Seismic Category I.
Definitions:
FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.
EXPLOSION: A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components.
VITAL AREAS: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation.
PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center.
Hope Creek Page 2 of 3 Rev. 0 (RAI-2)
EAL#: HA2.2
HCGS ECG - EAL Technical Bases EP-HC-111-208 OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA.
VISIBLE DAMAGE: Damage to equipment or structure that is readily observable without measurements, testing, or analysis. Damage is sufficient to cause concern regarding the continued operability or reliability of the affected structure, system, or component. Example damage includes: deformation due to heat or impact, denting, penetration, rupture, cracking, and paint blistering. Surface blemishes (e.g., paint chipping, scratches) should not be included.
DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability (e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability:
- Electrical faults on power supplies
- Normally closed breakers in tripped position
- System annunciators activated
- System warning lights lit
- Insufficient system pressure from keep-fill pumps
- Elevated area temperatures or radiation levels
- 2. UFSAR Table 3.2-1 HCGS Classification of Structures, Systems and Components Hope Creek Page 3 of 3 Rev. 0 (RAI-2)
EAL#: HA2.2
ATTACHMENT 3 Salem Generating Stations (SGS)
SGS Emergency Action Level Technical Bases Document HA2.1 and HA2.2
SGS ECG - EAL Technical Bases EP-SC-111-208 EAL Category: C - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 2 - Fire or Explosion Initiating Condition: FIRE or EXPLOSION in a VITAL AREA affecting the operability of plant safety systems required to establish or maintain safe shutdown Mode Applicability: All EAL# & Classification Level: HA2.1 - ALERT EAL:
FIRE in ANY Table H-1 plant structure AND Resulting in ANYone of the following:
- VISIBLE DAMAGE to ANY plant structure in Table H-1
- VISIBLE DAMAGE to ANY safety system components within a Table H-1 structure
- Control Room indication of DEGRADED PERFORMANCE of a Safety System within a Table H-1 structure Table H-1 Plant Structures Containing Safe Shutdown Systems or Components
- Auxiliary Building
- Service Water Intake Structure
- Control Point Area
- Inner/Outer Penetration Areas
- Containment
- Fuel Handling Building
- Service Building
- RWST, PWST, and AFWST Area Salem Page 1 of 3 Rev. 0 (RAI-2)
EAL#: HA2.1
SGS ECG - EAL Technical Bases EP-SC-111-208 Basis:
VISIBLE DAMAGE is used to identify the magnitude of the FIRE and to discriminate against minor FIRES.
The reference to structures containing safety systems or components is included to discriminate against FIRES in areas having a low probability of affecting safe operation. The significance here is not that a safety system was degraded but the fact that the FIRE was large enough to cause damage to these systems.
The use of VISIBLE DAMAGE should not be interpreted as mandating a lengthy damage assessment prior to classification. The declaration of an Alert and the activation of the Technical Support Center will provide the Emergency Director with the resources needed to perform detailed damage assessments.
Escalation of this emergency classification level, if appropriate, will be based on EALs in Category S, System Malfunctions, Category F, Fission Product Barrier Degradation, or Category R, Abnormal Rad Levels / Rad Effluent.
Explanation/Discussion/Definitions:
The Table H-1 Plant Structures Containing Safe Shutdown Systems or Components include those plant structures identified as Seismic Category I.
Definitions:
FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantitils of smoke and heat are observed.
EXPLOSION: A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components.
VITAL AREAS: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center.
Salem Page 2 of 3 Rev. 0 (RAI-2)
EAL#: HA2.1
SGS ECG - EAL Technical Bases EP-SC-111-208 OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classification, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA.
VISIBLE DAMAGE: Damage to equipment or structure that is readily observable without measurements, testing, or analysis. Damage is sufficient to cause concern regarding the continued-operability or reliability of the affected structure, system, or component. Example damage includes: deformation due to heat or impact, denting, penetration, rupture, cracking, and paint blistering. Surface blemishes (e.g., paint chipping, scratches) should not be included.
DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability (e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability:
- Electrical faults on power supplies
- Normally closed breakers in tripped position
- System annunciators activated
- System warning lights lit
- Insufficient system pressure from keep-fill pumps
- Elevated area temperatures or radiation levels
- 2. UFSAR 3.2 Classification of Structures, Components and Systems Salem Page 3 of 3 Rev. 0 (RAI-2)
EAL#: HA2.1
SGS ECG - EAL Technical Bases EP-SC-111-208 EAL Category: C - Hazards & Other Conditions Affecting Plant Safety EAL Subcategory: 2 - Fire or Explosion Initiating Condition: FIRE or EXPLOSION in a VITAL AREA affecting the operability of plant safety systems required to establish or maintain safe shutdown Mode Applicability: All EAL# & Classification Level: HA2.2 - ALERT EAL:
EXPLOSION in ANY Table H-1 plant structure AND Resulting in ANYone of the following:
- VISIBLE DAMAGE to ANY plant structure in Table H-1
- VISIBLE DAMAGE to ANY safety system components within a Table H-1 structure
- Control Room indication of DEGRADED PERFORMANCE of a Safety System within a Table H-1 structure Table H-1 Plant Structures Containing Safe Shutdown Systems or Components
- Auxiliary Building
- Service Water Intake Structure
- Control Point Area
- Inner/Outer Penetration Areas
- Containment
- Fuel Handling Building
- Service Building
- RWST, PWST, and AFWST Area Salem Page 1 of 3 Rev. 0 (RAI-2)
EAL#: HA2.2
SGS ECG - EAL Technical Bases EP-SC-111-208 Basis:
VISIBLE DAMAGE is used to identify the magnitude of the EXPLOSION and to discriminate against minor EXPLOSIONS.
The reference to structures containing safety systems or components is included to discriminate against EXPLOSIONS in areas having a low probability of affecting safe operation. The significance here is not that a safety system was degraded but the fact that the EXPLOSION was large enough to cause damage to these systems.
The use of VISIBLE DAMAGE should not be interpreted as mandating a lengthy damage assessment prior to classification. The declaration of an Alert and the activation of the Technical Support Center will provide the Emergency Director with the resources needed to perform detailed damage assessments.
The Emergency Coordinator also needs to consider any security aspects of the EXPLOSION.
Escalation of this emergency classification level, if appropriate, will be based on EALs in Category S, System Malfunctions, Category F, Fission Product Barrier Degradation, or Category R, Abnormal Rad Levels / Rad Effluent.
Explanati on/Discussion/Defi n itions:
If the EXPLOSION is determined to be hostile in nature, the event is classified under EAL HS4.1.
The Table H-1 Plant Structures Containing Safe Shutdown Systems or Components include those plant structures identified as Seismic Category I.
Definitions:
FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.
EXPLOSION: A rapid, violent, unconfined combustion, or catastrophic failure of pressurized/energized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components.
VITAL AREAS: Typically any site specific areas, normally within the PROTECTED AREA, that contains equipment, systems, components, or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation.
Salem* Page 2 of 3 Rev. 0 (RAI-2)
EAL#: HA2.2
SGS ECG - EAL Technical Bases EP-SC-111-208 PROTECTED AREA (PA): A security controlled area within the OWNER CONTROLLED AREA (OCA) that is enclosed by the security perimeter fence and monitored by intrusion detection systems. Access to the PA requires proper security clearance and is controlled at the Security Center.
OWNER CONTROLLED AREA (OCA): Property owned, maintained and controlled by PSEG Nuclear as part of the Salem & Hope Creek Generating Station complex. For the purpose of emergency classifiGation, area from the PSEG Nuclear access road checkpoint and inward towards the stations is considered the OCA.
VISIBLE DAMAGE: Damage to equipment or structure that is readily observable without measurements, testing, or analysis. Damage is sufficient to cause concern regarding the continued operability or reliability of the affected structure, system, or component. Example damage includes: deformation due to heat or impact, denting, penetration, rupture, cracking, and paint blistering. Surface blemishes (e.g., paint chipping, scratches) should not be included.
DEGRADED PERFORMANCE: Assessment of degraded safe shutdown system performance includes examination of systems in standby status as well as those in operation. When a safe shutdown system is in operation, its performance can be directly observed and compared to its design capability (e.g., rated flow is required but cannot be achieved). When an operating safe shutdown system cannot fulfill its design function, its performance is degraded. When a safe shutdown system is in standby, its performance capability may not be readily determined. One or more of the following can provide indirect indication of its performance capability:
- Electrical faults on power supplies
- Normally closed breakers in tripped position
- System annunciators activated
- System warning lights lit
- Insufficient system pressure from keep-fill pumps
- Elevated area temperatures or radiation levels
- 2. UFSAR 3.2 Classification of Structures, Components and Systems Salem Page 3 of 3 Rev. 0 (RAI-2)
EAL#: HA2.2