ML15142A396
| ML15142A396 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/22/2015 |
| From: | Klos L Plant Licensing Branch IV |
| To: | Elwood T AmerenUE, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML15142A396 (8) | |
Text
NRR-PMDAPEm Resource From: Klos, John Sent: Friday, May 22, 2015 7:45 AM To: Telwood@ameren.com Cc: SMaglio@ameren.com; Klos, John; Johnson, Don; Hoffman, Raymond
Subject:
Requests for Additional Information: Callaway License Amendment upgrade Emergency Action Level scheme adopt NRC-endorsed NEI 99-01, Revision 6 Mr. Elwood By letter dated October 2, 2014 Agencywide Documents Access and Management System (ADAMS)
Accession Number ML14275A435 Ameren Missouri submitted a license amendment request for Callaway Unit 1 to upgrade the Emergency Action Level scheme by adopting NRC-endorsed Nuclear Energy Institute (NEI) 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors.
The Nuclear Regulatory Commission (NRC) staff has been reviewing the submittal and has determined that requests for additional information (RAIs) are needed to complete its review.
The draft questions were sent via electronic transmission on May 14, 2015 to Mr. Tom Elwood. A clarification teleconference was held on May 21, 2015 and determined that 3 questions from the draft list (RAI-CP-13, -19, and -23a) were not necessary for the NRC staff to complete its technical review and make a regulatory finding regarding this license amendment. These questions are omitted in the list below. Additionally, it was agreed that a response would be submitted within 45 days from the date of this email.
If you have any questions, please contact John Klos per the contact information below.
The RAIs are as follows; The following RAIs are in reference to Attachment 3, Emergency Action Level Technical Bases (Draft D), and are needed for the NRC staff to continue the review pursuant to 10 CFR 50 Appendix E, Section IV.B.2.
RAI-CP-01 Section 4.3, Instrumentation Used for EALs, to NEI 99-01, Revision 6, states Scheme developers should ensure that specific values used as EAL setpoints are within the calibrated range of the referenced instrumentation. Please confirm that all setpoints and indications used in the CP EAL scheme are within the calibrated range(s) of the stated instrumentation and that the resolution of the instrumentation is appropriate for the setpoint/indication.
RAI-CP-02 In regards to Section 1, Purpose, of the proposed EAL Technical Basis:
- a. Section 4.6, Basis Document, to NEI 99-01, Revision 6, states A basis document is an integral part of an emergency classification scheme. The material in this document supports proper emergency classification decision-making by providing informing background and development information in a readily accessible format. It can be referred to in training situations and when making an actual emergency classification, if necessary. Please revise Section 1 of the proposed EAL Technical Basis to reflect the intent of the EAL Basis Document, as provided in NEI 99-01, Revision 6, and remove the proposed purpose discussion, to facilitate a review of the Callaway EALs, or provide justification for failure to align with NRC endorsed guidance.
- b. Section 4.6, Basis Document, to NEI 99-01, Revision 6, states Because the information in a basis document can affect emergency classification decision-making Therefore, the NRC staff expects that changes to the basis document will be evaluated in accordance with the provisions of 10 CFR 50.54(q).
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Please incorporate information related to maintaining the technical basis document in accordance with 10 CFR 50.54(q) or provide justification for failure to align with NRC endorsed guidance.
[Emergency Operating Procedure] Setpoints/Criteria, to NEI 99-01, Revision 6, states As reflected in the generic guidance, the criteria/values used in several EALs and fission product barrier thresholds may be drawn from a plants AOPs and EOPs. The NRC staff expects that changes to AOPs and EOPs will be evaluated in accordance with the provisions of 10 CFR 50.54(q). Please incorporate information related to screening changes to AOPs or EOPs to determine if an evaluation pursuant to 10 CFR 50.54(q) is required or provide justification for failure to align with NRC endorsed guidance.
RAI-CP-03 Sections 2.1, Background, and 4.0, References, of the proposed EAL Technical Basis reference an incorrect ADAMS Accession Number (ML110240324). Please verify that the proposed EAL Technical Basis is consistent with NRC endorsed guidance and appropriate ADAMS Accession number is referenced.
RAI-CP-04 For Sections 2.1, Background, and 4.0, References, of the proposed EAL Technical Basis, please provide ADAMS Accession Number that references the endorsed version of NEI 99-01, Revision 6 (ML12326A805).
RAI-CP-05 Section 2.5, Technical Basis Information, of the proposed EAL Technical Basis includes a Plant-Specific basis section, in addition to a Generic basis section. Considering that the EAL Technical Basis is provided to support proper emergency classification decision making, please explain why a Generic basis section is provided or revise accordingly.
RAI-CP-06 Section 2.6, Operating Mode Applicability, of the proposed EAL Technical Basis contains a brief discussion concerning EAL classification during mode changes. However, this discussion is not as clear as that provided in NRC endorsed guidance. Please justify the omission of significant portions of Section 5.4, Consideration of Mode Changes During Classification, of NEI 99-01, Revision 6, or revise accordingly.
RAI-CP-07 In regards to Section 3 of the proposed EAL Technical Basis:
Section 3.1.1, Classification Timeliness, includes a reference to NSIR/DPR-ISG-01, Interim Staff Guidance, Emergency Planning for Nuclear Power Plants, but does not include a discussion, as provided by NEI 99-01, Revision 6, Section 5.2, Classification Methodology, addressing [w]hen assessing an EAL that specifies a time duration for the off-normal condition, the clock for the EAL time duration runs concurrently with the emergency classification process clock. Please justify excluding this information or revise accordingly.
Section 3.1.2, Valid Indications, does not include statement, [t]he validation of indications should be completed in a manner that supports timely emergency declaration, as provided by NEI 99-01, Revision 6, Section 5.1, General Considerations. Please justify excluding this information or revise accordingly.
RAI-CP-08 Appendix B, Definitions, to NEI 99-01, Revision 6, provides definitions for key terms necessary for overall understanding of the NEI 99-01 emergency classification scheme. For Section 5.1, Definitions, please revise accordingly to add definitions for the following or justify excluding:
- CONFINEMENT BOUNDARY,
- EMERGENCY ACTION LEVEL,
- EMERGENCY CLASSIFICATION LEVEL,
- FISSION PRODUCT BARRIER THRESHOLD, and
- INITIATING CONDITION.
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In addition, please consider removing one of the two provided definitions for INDEPENDENT SPENT FUEL STORAGE INSTALLATION to eliminate redundancy.
RAI-CP-09 Section 6.0, Callaway to NEI 99-01 Rev. 6 EAL Cross-Reference, contains the several apparent inconsistencies, as listed below. Please review the Callaway to NEI 99-01, Revision 6, EAL Cross-Reference for accuracy and make corrections as needed.
- a. Callaway emergency action level RA2.3 is not included in the Callaway to NEI 99-01, Revision 6, EAL Cross-Reference matrix.
- b. Callaway emergency action level CG1.1 corresponds to NEI 99-01 Rev. 6 EAL CG1 example 1. The Callaway to NEI 99-01, Revision 6, EAL Cross-Reference indicates example 2.
- c. Callaway emergency action level CG1.2 is not included in the Callaway to NEI 99-01, Revision 6, EAL Cross-Reference.
Callaway to NEI 99-01, Revision 6, EAL Cross-Reference indicates example 1.
- e. The Callaway to NEI 99-01, Revision 6, EAL Cross-Reference includes Callaway EAL SU4.2. EAL SU4.2 could not be located in the Callaway EAL basis document.
- f. Callaway emergency action level SU8.1 is not included in the Callaway to NEI 99-01, Revision 6, EAL Cross-Reference matrix.
- g. The Callaway to NEI 99-01, Revision 6, EAL Cross-Reference includes Callaway EAL SA8.1. EAL SA8.1 could not be located in the Callaway EAL basis document.
- h. Callaway emergency action level SA9.1 is not included in the Callaway to NEI 99-01, Revision 6, EAL Cross-Reference matrix.
- i. Callaway EAL EU 1.1 shows as IU1.1 on the Callaway to NEI 99-01, Revision 6, EAL Cross-Reference. (Note: The E designation is correct.)
RAI-CP-10 For EAL RU1.1, it is not clear how a determination can be made that a 2 X Hi - Hi alarm condition exists.
Please provide justification that a value of two times the alarms identified in Table R-1, Effluent Monitor Classification Thresholds, can be accurately determined in a timely and accurate manner.
RAI-CP-11 For EALs RA1.2, RS1.2, and RG1.2, please explain why the proposed Note 3, which relates to effluent flow past an effluent monitor, should be included for EALs that are based on dose assessments or revise accordingly.
RAI-CP-12 For EALS RA1.1, RS1.1, and RG1.1, there was a substantial change from the previous to the proposed Table R-1 values. The provided calculations did not contain information that could be used to justify this change.
Please provide justification that supports the changes in the Table R-1 values from the previous values to the current values.
RAI-CP-13 Omitted RAI-CP-14 3
For NEI 99-01, Revision 6, EALs AA3 and HA5, CP is proposing two deviations. NEI Initiating Condition (IC)
AA3 example 2, and HA5 example 1 will not be included because a review of CP normal operating and shutdown procedures by Operations Subject Matter Experts concluded that there are no areas external to the Main Control Room that require access to perform a normal plant shutdown and cooldown to Cold Shutdown conditions.
- a. Please verify that all required manipulations to shut down the plant and enter shutdown cooling can be performed from the Main Control Room or revise accordingly.
- b. Please verify that no local breaker operations are required or revise accordingly.
- c. Please provide evidence that an assessment of Control Room availability was performed to support these deviations.
RAI-CP-15 For EAL RU2.1, site-specific refueling pathway level indications are not provided per guidance in NEI 99-01, Revision 6. Additionally, the NEI 99-01 Basis discussion does not include the NEI 99-01, Revision 6, EAL AA2 guidance that This IC applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC E-HU1.
- a. Please provide site specific level indications for EAL RU2.1 that could be used to support timely and accurate assessments, include applicable mode availability for this level instrumentation.
- b. Please justify excluding the NEI 99-01, Revision 6, EAL AA2 guidance that relates to RA2.1, RA2.2, and RA2.3 applicability or revise accordingly.
- c. Please verify that RA2.1 should be an Alert and revise accordingly.
RAI-CP-16 For EAL RA2.2, the logic was changed from NEI 99-01, Revision 6, guidance that uses an increase in radiation monitor readings to determine that irradiated fuel has been damaged to a proposed logic that requires the operator to know that damage has occurred to irradiated fuel AND an there is an increase in radiation monitor indications. Please develop EAL RA2.2 per NEI 99-01, Revision 6, as endorsed or provide further justification for this deviation.
RAI-CP-17 For EAL EU1.1, please explain why symbols were used rather than spelling out gamma and neutron or revise accordingly.
RAI-CP-18 For EAL CA1.1, a BBLI-53 A/B level of 0 inches is provided as an indication that RCS level is lower than the bottom of the RCS hot leg. The Callaway Basis provides that BBLI-53A/B cannot sense level changes in the Reactor Vessel below the elevation of the RCS loop hot leg penetration. Please provide justification that supports using the minimum value of BBLI-53 A/B for EAL classification as this reading may not be readily differentiated from an instrument failure or revise accordingly.
RAI-CP-19 Omitted RAI-CP-20 For EAL CS1.1 and CS1.2, the logic was changed from NEI 99-01, Revision 6, guidance without justification.
As changed, the EAL appears vague and interpretive. Please develop EAL CS1.1 and CS1.2 per NEI 99-01, Revision 6, as endorsed, or provide further justification for deviation.
RAI-CP-21 4
For EALs CS1.3 and CG1.2, CP did not include of sufficient magnitude to indicate core uncovery to the unplanned increase in any sump/tank level to the IC wording. Additionally, CP added Visual observation of UNISOLABLE RCS leakage to the IC wording. As proposed, EALs CS1.3 and CG1.2 could result in unnecessary Site and General Emergency declarations. Please provide further justification or revise EAL CS1.3 and CG1.2 accordingly consistent with NEI 99-01, Revision 6, as endorsed.
RAI-CP-22 For EAL CG1.2 and the Containment Fission Product Barrier Potential Loss D.2, it is not clear how CA-3, Hydrogen Flammability in Containment, can be used to estimate containment atmosphere hydrogen concentration. Please explain how a procedure to determine hydrogen flammability in containment can be used to estimate containment atmosphere hydrogen concentration or remove the reference to CA-3 from Technical Basis.
RAI-CP-23 For EALs CU2.1, CA2.1, SU1.1, SA1.1, SS1.1, SG1.1, and SG1.2, AC power sources are provided by Table C-3. Additionally, the Callaway Basis provides that credit can be taken for additional sources of power if they are capable of carrying an emergency bus.
- a. Omitted
- b. Please justify the addition of Additional sources of offsite power are available from diesel generators such as the Alternate Emergency Power Supply (AEPS) or portable generation sources. Credit can be taken for these sources if they are capable of carrying an NB bus and are aligned within 15 minutes to the Callaway Basis as this statement could potentially be applied to power supplies not listed on Table C-3 or revise according to NRC endorsed guidance.
RAI-CP-24 For EAL CU3.1 and CA3.1, please explain how the addition of due to the loss of decay heat removal capability to EAL CU3.1 and due to a loss of RCS cooling to EAL CA3.1 would not result in potential misclassification for an event other than a loss of decay heat removal that leads to an unplanned RCS temperature and/or RCS pressure rise. Please provide justification or revise accordingly consistent with endorsed guidance.
RAI-CP-25 For EALs CU5.1 and SU7.1, the Sentry Notification System is provided as an offsite response organization (ORO) communication method for the electronic transmission of a notification form to the OROs. Please provide reference to specific section of the site emergency plan that that identifies the Sentry Notification System as a means of timely notification to OROs for a spectrum of potential event responses or revise accordingly.
RAI-CP-26 For EAL CA3.1, Note 10: Begin monitoring hot condition EALs concurrently, was added to the provided EAL Technical Basis. It is not clear to the staff how Note 10 would be applied during an UNPLANNED increase in RCS temperature event. Please provide justification for this difference or revise accordingly.
RAI-CP-27 For EAL CA6.1 and SA9.1, the Callaway Basis discussion for seismic events refers to a discussion under EAL HU2.1. Please include the discussion on seismic events in the EAL CA6.1 and SA9.1 Callaway Basis or provide justification for not including the discussion as this could impact the timeliness of event assessment.
RAI-CP-28 For EAL HU2.1, the proposed EAL may not be consistent with from NEI 99-01, Revision 6, guidance, which provides that site-specific indication that a seismic event met or exceeded OBE [operating basis earthquake]
limits should be based on the indications, alarms, and displays of site-specific monitoring equipment. The proposed EAL appears to base the declaration on implementation of an alarm response manual (OTO-SG-00001). Please provide justification for using OTO-SG-00001 for event classification rather than the appropriate seismic monitoring equipment as provided by NRC endorsed guidance or revise accordingly.
5
RAI-CP-29 For EAL HU3.2, the proposed Callaway Basis identifies the Control Building, Battery Room, and ESF Switchgear Room as internal flooding areas of concern. Additionally, the Callaway Basis for HU3.2, which is applicable for all modes, references CA6.1, which is applicable in modes 5 and 6, for internal flooding affecting one or more safety trains.
- a. Please explain how the statement in EAL HU3.2 that limits flooding areas of concern will not potentially be used to limit a flooding related EAL declaration to only equipment in the Control Building, Battery Room, and the ESF Switchgear Room or revise accordingly.
RAI-CP-30 For EAL HS5.1, please consider the following or provide an explanation how this EAL can be consistently applied:
- Addition of operating mode specificity to the listed safety functions to preclude event classification when these safety functions are no longer needed in accordance with site technical specifications; and
- Including a Clock start time in the Callaway Basis discussion.
RAI-CP-31 For NEI 99-01, Revision 6, EAL SU3.1, CP does not provide an EAL that uses site-specific radiation monitor(s). Please provide additional justification that a Callaway EAL cannot be developed consistent with endorsed guidance or revise accordingly.
RAI-CP-32 For EAL SU4.1, please explain why the proposed wording is different from the NEI 99-01, Revision 6, guidance which clearly states sample analysis indicates that, or revise accordingly.
RAI-CP-33 For EAL SU5.1, please explain how timely declaration can be performed without reliance on a potentially time consuming manual method of performing an RCS inventory balance or revise the Callaway Basis accordingly.
RAI-CP-34 For EAL SU6.1, please provide a justification for including a subsequent automatic trip to the EAL condition or revise accordingly.
RAI-CP-35 For EALs SU6.1, SU6.2, SA6.1, and SS6.1, please provide further justification as to why greater than or equal to fire percent reactor power was added or revise accordingly. (Note: Westinghouse EOPs do not solely rely on Reactor Power level to determine the status of reactor criticality.)
Thank you, John Klos DORL Callaway Project Manager U.S. NRC, Office of Nuclear Reactor Regulation, Division of Operating Reactor Licensing NRC/NRR/DORL/LPL4-1, O7G1, Washington, DC 20555-0001 301.415.5136, 301.415.3313 (fax)
MS O8B1, John.Klos@NRC.gov 6
7 Hearing Identifier: NRR_PMDA Email Number: 2101 Mail Envelope Properties (94A2A4408AC65F42AC084527534CF41601C0386841F0)
Subject:
Requests for Additional Information: Callaway License Amendment upgrade Emergency Action Level scheme adopt NRC-endorsed NEI 99-01, Revision 6 Sent Date: 5/22/2015 7:44:43 AM Received Date: 5/22/2015 7:44:45 AM From: Klos, John Created By: John.Klos@nrc.gov Recipients:
"SMaglio@ameren.com" <SMaglio@ameren.com>
Tracking Status: None "Klos, John" <John.Klos@nrc.gov>
Tracking Status: None "Johnson, Don" <Don.Johnson@nrc.gov>
Tracking Status: None "Hoffman, Raymond" <Raymond.Hoffman@nrc.gov>
Tracking Status: None "Telwood@ameren.com" <Telwood@ameren.com>
Tracking Status: None Post Office: HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 19694 5/22/2015 7:44:45 AM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
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