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MONTHYEARML15323A2022015-11-19019 November 2015 NRR E-mail Capture - FW: Comanche Peak RAIs (CAC Nos. MF6407-08) Project stage: RAI ML15345A0112015-12-16016 December 2015 Request for Additional Information, License Amendment Request, Revise Emergency Action Levels Based on Nuclear Energy Institute (NEI) 99-01, Revision 6 Project stage: RAI CP-201600048, Response to Request for Additional Information Regarding License Amendment Request 15-003 for Revision to Emergency Action Levels2016-01-27027 January 2016 Response to Request for Additional Information Regarding License Amendment Request 15-003 for Revision to Emergency Action Levels Project stage: Response to RAI CP-201600177, Supplemental to Response to Request for Additional Information Regarding License Amendment Request 15-003 for Revision to Emergency Action Levels2016-03-0303 March 2016 Supplemental to Response to Request for Additional Information Regarding License Amendment Request 15-003 for Revision to Emergency Action Levels Project stage: Supplement ML16137A0562016-06-14014 June 2016 Issuance of Amendment Nos. 166 and 166, Request to Revise Emergency Action Levels Based on Nuclear Energy Institute (NEI) 99-01, Revision 6 Project stage: Approval ML16168A0022016-06-24024 June 2016 Correction of Implementation Date, Issuance of Amendment Nos. 166 and 166, Request to Revise Emergency Action Levels Based on Nuclear Energy Institute (NEI) 99-01, Revision 6 Project stage: Approval 2016-01-27
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Category:Letter
MONTHYEARCP-202400030, License Renewal Application Revision 0 - Supplement 3, Revision 12024-01-31031 January 2024 License Renewal Application Revision 0 - Supplement 3, Revision 1 IR 05000445/20230042024-01-29029 January 2024 Integrated Inspection Report 05000445/2023004 and 05000446/2023004 CP-202400034, (CPNPP) - Core Operating Limits Report (Colr), Unit 2 Cycle 21, (ERX-23-001, Revision 1)2024-01-29029 January 2024 (CPNPP) - Core Operating Limits Report (Colr), Unit 2 Cycle 21, (ERX-23-001, Revision 1) ML24024A2102024-01-29029 January 2024 Summary of Regulatory Audit Regarding a License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors ML24025A0052024-01-25025 January 2024 Review of the Spring 2023 Steam Generator Tube Inspection Report ML24023A0242024-01-24024 January 2024 Correction to Amendment Nos. 185 and 185 Regarding Implementation of Full Spectrum Loss-of-Coolant Accident Methodology ML24018A1072024-01-18018 January 2024 Notification of Commercial Grade Dedication Inspection (05000445/2024012 and 05000446/2024012) and Request for Information ML23159A2082023-12-20020 December 2023 Request for Withholding Information from Public Disclosure ML23319A3872023-12-20020 December 2023 Issuance of Amendment Nos. 185 and 185 Regarding Implementation of Full Spectrum Loss-of-Coolant Accident (Fsloca) Methodology ML23348A2392023-12-19019 December 2023 Nonacceptance of License Amendment Request to Relocate Technical Specification 3.9.3, Nuclear Instrumentation, to the Technical Requirements Manual CP-202300575, (Cpnpp), License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors Supplement 22023-12-13013 December 2023 (Cpnpp), License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors Supplement 2 ML23333A0872023-12-13013 December 2023 Transmittal of Dam Safety Inspection Report - Public CP-202300566, (Cpnpp), Special Report 1-SR-23-001-00, Inoperable Post Accident Monitoring Instrumentation2023-12-12012 December 2023 (Cpnpp), Special Report 1-SR-23-001-00, Inoperable Post Accident Monitoring Instrumentation CP-202300494, License Renewal Application Revision 0, Supplement 32023-12-0606 December 2023 License Renewal Application Revision 0, Supplement 3 ML23313A0732023-12-0606 December 2023 Issuance of Amendment Nos. 184 and 184 Regarding Revision to Technical Specifications to Implement WCAP-17661-P-A, Rev. 1, Improved Roac and CAOC Fq Surveillance Technical Specifications ML23291A4382023-11-30030 November 2023 Notice of Availability of the Draft Plant-Specific Supplement 60, to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Comanche Peak Nuclear Power Plant, Unit Numbers 1 and 2, License Renewal Applica ML23325A0182023-11-30030 November 2023 Schedule Revision for the License Renewal Application Review IR 05000445/20234022023-11-30030 November 2023 NRC Security Inspection Report 05000445/2023402 and 05000446/2023402 CP-202300349, License Amendment Request (Lar) 23-004 Technical Specifications (TS) 3.9.3, Nuclear Instrumentation2023-11-20020 November 2023 License Amendment Request (Lar) 23-004 Technical Specifications (TS) 3.9.3, Nuclear Instrumentation ML23308A0032023-11-17017 November 2023 Letter to R. Nelson, Executive Director; Achp; Re., Comanche Peak Draft Environmental Impact Statement ML23308A0022023-11-17017 November 2023 Letter to M. Wolfe, Executive Director; Shpo; Re., Comanche Peak Draft Environmental Impact Statement ML23317A3002023-11-13013 November 2023 Letter to R. Sylestine, Chairman, Alabama-Coushatta Tribe of Texas Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2972023-11-13013 November 2023 Letter to R. Martin, President, Tonkawa Tribe of Oklahoma Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2872023-11-13013 November 2023 Letter to J. Garza, Chairman, Kickapoo Traditional Tribe of Texas Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2832023-11-13013 November 2023 Letter to D. Dotson, President, Delaware Nation Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2852023-11-13013 November 2023 Letter to E. Martinez, President, Mescalero Apache Tribe Regarding Comanche Peak Draft Environmental Impact Statement ML23306A0302023-11-13013 November 2023 Letter to J. Cernek, Chairman; Coushatta Tribe of Louisiana Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2902023-11-13013 November 2023 Letter to M. Pierite, Chairman, Tunica Biloxi Tribe of Louisiana Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2982023-11-13013 November 2023 Letter to R. Morrow, Town King, Thlopthlocco Tribal Town Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2842023-11-13013 November 2023 Letter to D. Kaskaske, Chairman, Kickapoo Tribe of Oklahoma Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2822023-11-13013 November 2023 Letter to D. Cooper, Chairman, Apache Tribe of Oklahoma Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2962023-11-13013 November 2023 Letter to M. Woommavovah, Chairman, Comanche Nation Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2812023-11-13013 November 2023 Letter to C. Hoskin, Principal Chief, Cherokee Nation; Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2862023-11-13013 November 2023 Letter to J. Bunch, Chief, United Keetoowah Band of Cherokee Indians Regarding Comanche Peak Draft Environmental Impact Statement ML23317A3032023-11-13013 November 2023 Letter to W. Yargee, Chief, Alabama-Quassarte Tribal Town Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2882023-11-13013 November 2023 Letter to L. Johnson, Chief, Seminole Nation of Oklahoma Regarding Comanche Peak Draft Environmental Impact Statement ML23317A3012023-11-13013 November 2023 Letter to S. Yahola, Mekko, Kialegee Tribal Town Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2792023-11-13013 November 2023 Letter to B. Gonzalez, Chairman, Caddo Nation Regarding Comanche Peak Draft Environmental Impact Statement ML23317A3022023-11-13013 November 2023 Letter to T. Parton, President, Wichita and Affiliated Tribes Regarding Comanche Peak Draft Environmental Impact Statement ML23317A2892023-11-13013 November 2023 Letter to L. Spottedbird, Chairman, Kiowa Indian Tribe Regarding Comanche Peak Draft Environmental Impact Statement ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV ML23360A6312023-10-26026 October 2023 FEMA, Submittal of Radiological Emergency Preparedness Final Report for the Comanche Peak Nuclear Power Plant Medical Services Drill Evaluated on August 23, 2023 CP-202300416, Supplemental Information to Facilitate Acceptance of Licensee Amendment Request 23-002, Application Regarding GDC-5 Shared System Requirements2023-10-12012 October 2023 Supplemental Information to Facilitate Acceptance of Licensee Amendment Request 23-002, Application Regarding GDC-5 Shared System Requirements CP-202300432, Response to Request for Additional Information Regarding the Safety Review of the License Renewal Application - Set 42023-10-0404 October 2023 Response to Request for Additional Information Regarding the Safety Review of the License Renewal Application - Set 4 ML23237B4222023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Letter Regarding Order Approving Transfer of Licenses and Draft Conforming License Amendments ML23263A0242023-09-21021 September 2023 Revision of Schedule for the Environmental Review of the Comanche Peak Nuclear Power Plant Units 1 and 2 License Renewal Application 2024-01-31
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML24019A0742024-01-19019 January 2024 NRR E-mail Capture - Comanche Peak - Draft Request for Additional Information - License Amendment Request to Extend the Allowed Outage Time for an Inoperable Emergency Diesel Generator ML24018A1072024-01-18018 January 2024 Notification of Commercial Grade Dedication Inspection (05000445/2024012 and 05000446/2024012) and Request for Information ML23256A1502023-09-11011 September 2023 Request for Additional Information Requests - Comanche Peak - Set 4 ML23256A1492023-09-11011 September 2023 Email from Mark Yoo (NRC) to Ken Peters (Vistra) - Comanche Peak LRA - Request for Additional Information - Set 4 ML23213A2162023-08-0202 August 2023 Vistra Operations Company, LLC Notification of License Renewal Inspection and Request for Information ML23188A0452023-07-0707 July 2023 Request for Additional Information Requests - Comanche Peak - Set 3 ML23188A0442023-07-0707 July 2023 Email from Mark Yoo (NRC) to Ken Peters (Vistra) - Comanche Peak LRA - Request for Additional Information - Set 3 ML23181A0212023-06-29029 June 2023 Request for Additional Information Requests - Comanche Peak - Set 2 ML23181A0202023-06-29029 June 2023 Email from Mark Yoo (NRC) to Ken Peters (Vistra) - Comanche Peak LRA - Request for Additional Information - Set 2 ML23167A0222023-06-14014 June 2023 Email: Request for Additional Information (RAI) Letter for the Review of the Comanche Peak Initial License Renewal Application, Set 1 ML23167A0232023-06-14014 June 2023 Request for Additional Information (RAI) for the Review of the Comanche Peak Initial License Renewal Application (Lra), Set 1 ML23145A2322023-05-25025 May 2023 LRA - Request for Confirmation of Information - Set 2 ML23143A1372023-05-23023 May 2023 LRA - Request for Confirmation of Information - Set 1 ML23132A2542023-05-23023 May 2023 Supplemental Information Needed for Acceptance of Requested Licensing Action LAR to Adopt 10 CFR 50.69,Risk-Informed Categorization & Treatment of Structures,Systems & Components for Nuclear Power Reactors EPID L-2023-LLA-0057 ML23068A0562023-05-0909 May 2023 Request for Additional Information - Comanche Peak License Renewal Application Environmental Review ML23068A0732023-04-13013 April 2023 Requests for Confirmation of Information for the Environmental Review of the Comanche Peak Nuclear Power Plant, Units 1 and 2, Licensed Renewal Application (EPID Number: L-2022-LNE-0004) (Docket Numbers 50-445 and 50-446) ML23103A4682023-04-11011 April 2023 NRR E-mail Capture - Comanche Peak Request for Additional Information - License Amendment Request to Apply the Westinghouse Full Spectrum Loss of Coolant Accident Evaluation Model ML23086B9852023-03-27027 March 2023 NRR E-mail Capture - Comanche Peak Draft Request for Additional Information - Request to Apply the Westinghouse Full Spectrum Loss of Coolant Accident Evaluation Model ML23010A1442023-01-0909 January 2023 Inservice Inspection Request for Information ML22325A2742022-11-21021 November 2022 NRR E-mail Capture - Comanche Peak - Request for Additional Information - Proposed Alternative P-1 Regarding IST of Safeguards Building Sump Pumps ML22318A3102022-11-10010 November 2022 NRR E-mail Capture - Comanche Peak - Draft Request for Additional Information - Proposed Alternative P-1 Regarding IST of Safeguards Building Sump Pumps ML22230B1092022-08-17017 August 2022 NRR E-mail Capture - Comanche Peak Unit 2 - Request for Additional Information - 2RE19 Inspection Summary Report for Steam Generator Tubing ML22220A1942022-08-0808 August 2022 NRR E-mail Capture - Comanche Peak Unit 2 - Draft Request for Additional Information - 2RE19 Inspection Summary Report for Steam Generator Tubing ML22179A3032022-06-28028 June 2022 Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000445/2022401; 05000446/2022401 ML22083A0262022-03-23023 March 2022 NRR E-mail Capture - Comanche Peak - Request for Additional Information - Request to Adopt TSTF 505 Revision 2 ML21286A7912021-10-13013 October 2021 NRR E-mail Capture - Comanche Peak - Request for Additional Information - Request to Adopt TSTF-577 Revision 1 ML21253A2242021-09-0909 September 2021 Request for Information Occupational Radiation Safety Inspection (71124.01, 71124.02, and 71151) from 10/18-22/2021 ML21253A2332021-09-0909 September 2021 Request for Information: Comanche Peak Nuclear Power Plant, Units 1 and 2 (05000445 and 05000446); Occupation Radiation Safety (71124.01, 71124.02, 7511) ML21245A3072021-09-0202 September 2021 Request for Information ML21245A307 ML21166A3382021-06-22022 June 2021 Supplemental Information Needed for Acceptance of Requested Licensing Action LAR to Adopt TSTF-505, Rev. 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b ML21165A1022021-06-13013 June 2021 Pi&R; Request for Information ML21103A3982021-04-13013 April 2021 CP Security Inspection Information Request 2021403 ML20225A0932020-08-12012 August 2020 Notification of Inspection 05000445/2020004 and 05000446/2020004 and Request for Information ML20105A1072020-04-13013 April 2020 NRR E-mail Capture - Comanche Peak - Request for Additional Information - Exigent Amendment Request for One Time Change to Unit 2 Steam Generator Inspection Frequency ML20104A0022020-04-11011 April 2020 NRR E-mail Capture - Comanche Peak Unit 2 - Request for Additional Information - Proposed Alternative to ASME OM Code for Deferral of Snubber Testing (SNB-1) and Visual Examinations (SNB-2) ML20045E3512020-02-13013 February 2020 Information Request February 13, 2020 Notification of Inspection and Request for Information Comanche Peak Unit 2 NRC Inspection Report 05000446/2020002 ML19346B3812019-12-11011 December 2019 NRR E-mail Capture - Comanche Peak RAIs - Quality Assurance Program Reduction in Commitment ML19319A5432019-11-14014 November 2019 NRR E-mail Capture - Draft Comanche Peak RAIs - Quality Assurance Program Reduction in Commitment ML19058A3592019-02-27027 February 2019 NRR E-mail Capture - Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2 - Final Request for Additional Information Concerning License Amendment Request to Revise the Emergency Plan IR 05000445/20170072018-02-0808 February 2018 Notification of Nrc Design Bases Assurance Inspection (Programs) (05000445/2017007 and 05000446/2017007) ML17276B8622017-10-0303 October 2017 Notification of NRC Design Bases Assurance Inspection (Programs)(05000445/2017007 and 05000446/2017007) and Initial Request for Information ML17087A2032017-03-28028 March 2017 NRR E-mail Capture - Comanche Peak, Unit 2 - Final Request for Additional Information Regarding Request No. 2B3-1 ML17066A2372017-03-0707 March 2017 Notification of NRC Triennial Fire Protection Baseline Inspection (05000445/2017008 and 05000446/2017008) and Request for Information ML17048A4172017-02-17017 February 2017 Notification of NRC Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/ Staffing/Multi-Unit Dose Assessment... ML16034A1962016-02-0808 February 2016 Independent Spent Fuel Storage Installation - Request for Additional Information, Application for Order Approving Transfer of Facility Operating Licenses and Conforming Amendment ML16015A0032016-01-14014 January 2016 NRR E-mail Capture - Request for Additional Information - Relief Request 1B3-3 for Comanche Peak Nuclear Power Plant, Unit 1 ML15345A0112015-12-16016 December 2015 Request for Additional Information, License Amendment Request, Revise Emergency Action Levels Based on Nuclear Energy Institute (NEI) 99-01, Revision 6 ML15317A1582015-11-13013 November 2015 Request for Additional Information Email, Relief Request B-15, C-2, and C-4 for Welds in the RPV and Containment Spray and Residual Heat Removal Heat Exchanger Shells, Second 10-year Inservice Inspection Interval ML15317A1482015-11-13013 November 2015 Request for Additional Information Email, Relief Request No. B-9 for Reactor Pressure Vessel Outlet Nozzle Safe End to Piping Welds, Second 10-year Inservice Inspection Interval ML15317A1502015-11-13013 November 2015 Request for Additional Information Email, Relief Request No. B-3 for Reactor Coolant System Pipe to Pipe Flange Weld, Second 10-year Inservice Inspection Interval 2024-01-19
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 16, 2015 Mr. Rafael Flores Senior Vice President and Chief Nuclear Officer Attention: Regulatory Affairs Luminant Generation Company LLC P.O. Box 1002 Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST 15-003 FOR REVISION TO EMERGENCY ACTION LEVELS (CAC NOS. MF6407 AND MF6408)
Dear Mr. Flores:
By letter dated June 30, 2015 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML15191A175), Luminant Generation Company LLC (the licensee) submitted a license amendment request for revision to the Emergency Plan for Comanche Peak Nuclear Power Plant, Units 1 and 2 (CPNPP). The proposed amendment involves upgrading selected CPNPP emergency action levels based on Nuclear Energy Institute (NEI) document NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors."
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the information provided in your application and determined that additional information is required in order to complete its review. A draft copy of the enclosed request for additional information (RAI) was provided to Mr. Tim Hope of your staff via e-mail on November 19, 2015. Mr. Jack Hicks of your staff informed us on December 10, 2015, that a clarification call is is not needed. The licensee agreed to provide the RAI response within 45 days from the date of this letter.
R. Flores If you have any questions, please contact me at 301-415-3016 or balwant.singal@nrc.gov.
Sincerely, "b~t:..81~~
Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446
Enclosure:
Request for Additional Information cc w/enclosure: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST EMERGENCY ACTION LEVEL SCHEME CHANGE COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446 By letter dated June 30, 2015 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML15191A175), Luminant Generation Company LLC (Luminant, the licensee) requested approval for an emergency action level (EAL) scheme change for Comanche Peak Nuclear Power Plant, Units 1 and 2 (CPNPP). Luminant proposed to revise its current CPNPP EAL scheme to one based upon Revision 6 to the Nuclear Energy Institute (NEI) document NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors" (ADAMS Accession No. ML12326A805).
The requests for additional information (RAls) listed below, in regards to Attachment 3, "Emergency Action Level Basis Document," to the letter dated June 30, 2015, are needed to support NRC staff's continued technical review of the proposed EAL scheme change.
RAl-1 Section 2.5, "Technical Basis Information," includes a Plant-Specific (CPNPP) basis section, in addition to a Generic (NEI 99-01) basis section. One of the enhancements provided in Revision 6 to NEI 99-01 is a separation of the developer's notes from the bases information.
This change was made to facilitate the use of bases information for the two distinct purposes, development and classification. Considering that the EAL Technical Basis is provided to support proper emergency classification decision making, please explain why a Generic (NEI 99-01) basis section is provided rather than incorporated into Plant-Specific (CPNPP) basis section.
Specific examples include the following:
- Escalation should refer to CPNPP EAL numbering vice generic NEI 99-01 EAL numbering to facilitate timely assessments by the Emergency Coordinator.
- The Plant-Specific (CPNPP) basis section information should be specific to each EAL provided by the licensee. The following are examples of apparent inconsistencies:
For the proposed RA 1.3, the NEI 99-01 basis discussion includes reference to gaseous radioactivity while the proposed RA 1.3 only applies to liquid effluent samples.
Enclosure
For the proposed RA 1.3 and RA 1.4, the last paragraph of the NEI 99-01 basis discussion includes reference to effluent radiation monitors while the EAL only applies to field survey results.
For the proposed SU8.1, the NEI 99-01 discussion includes reference to ice condenser fans, which is not apparent in the EAL criteria for SU8.1.
RAl-2 Section 4.3, "Instrumentation Used for EALs," to NEI 99-01, Revision 6, states in part, that 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 CPNPP 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.
RAl-3 Section 4.6, "Basis Document," to NEI 99-01, Revision 6, states, in part, that 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 CPNPP EALs," or provide justification for failure to align with NRG-endorsed guidance.
RAl-4 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.
- a. For Section 5.1, "Definitions," please justify the omission of the following definitions, or revise accordingly to include:
- Emergency Classification Level;
- Fission Product Barrier Threshold; and
- b. For NEI 99-01, Revision 6, Section 5.1, "Definitions," the proposed Unusual Event, Alert, Site Area Emergency, and General Emergency definitions read "events are in progress" vice the proposed "events are in process." Provide justification for this difference or revise accordingly.
RAl-5 For EAL RU 1.1, the site-specific basis states, "The noble gas detectors (IX-RE-5567 A, B) can be used as backups to the wide range gas monitors (X-RE-5570A, B)". The UE setpoints for these detectors are included on Table R-1, "Effluent Monitor Classification Thresholds" which is applicable at all times. It is not clear to the staff whether the noble gas detectors should only be used to assess are RU1 .1 if the wide range gas monitors are not available or if the noble gas detectors should be used at all times to assess RU1 .1. Please provide clarification as to when the noble gas detectors (IX-RE-5567A, B) should be used to assess RU 1.1 and, if appropriate, revise the basis document accordingly.
RAl-6 Concerning RU1 .1, RA 1.1, RS1 .1, and RG1 .1, EAL Section R, "Table R-1 Effluent Monitor Classification Thresholds Review" includes the following:
- The assumption that the "[r]eactor has been shut down for one hour" for both the Plant Vent and the Main Steam radiation monitors.
- The assumption that the main steam flow rate will be 120,000 lbm/hr [pound mass per hour].
- Projected doses that are not based on 1 rem [roentgen equivalent man] Total Effective Dose Equivalent (TEDE) or 5 rem thyroid Committed Dose Equivalent (COE) at the CPNPP exclusion area boundary of 1 mile.
- a. For EAL RA 1.1, NEI 99-01, Revision 6, guidance provides for setpoints that correspond to 10 milli rem (mrem) TEDE and 50 mrem thyroid COE at the site-specific dose receptor point. EAL Section R, for the plant vent provides a dose of 13 mrem TEDE and a dose of 61 mrem thyroid COE at the CPNPP dose receptor point of 1 mile. The main steam monitor setpoint corresponds to 4 mrem TEDE and 46 mrem thyroid COE. Please explain why setpoints that correspond to 10 mrem TEDE or 50 mrem thyroid COE were not used for the Plant Vent and Main Steam monitors or revise accordingly.
- b. For EAL RS1 .1, NEI 99-01, Revision 6, guidance provides for setpoints that correspond to 100 mrem TEDE and 500 mrem thyroid COE at the site-specific dose receptor point. EAL Section R, "Table R-1 Effluent Monitor Classification Thresholds Review," for the plant vent provides a dose of 132 mrem TEDE and a dose of 577 mrem thyroid COE at the CPNPP dose receptor point of 1 mile. The main steam monitor setpoints correspond to 41 mrem TEDE and 461 mrem thyroid COE. Please explain why setpoints that correspond to 100 mrem TEDE
or 500 mrem thyroid COE were not used for the plant vent and main steam monitors or revise accordingly.
- c. For EAL RG1 .1, NEI 99-01, Revision 6, guidance provides a setpoint that corresponds to 1,000 mrem TEDE and 5,000 mrem thyroid COE at the site-specific dose receptor point. EAL Section R, for the plant vent provides a dose of 1,320 mrem TEOE and a dose of 5,780 mrem thyroid COE at the CPNPP dose receptor point of 1 mile. The main steam monitor setpoints correspond to 405 mrem TEOE and 4,610 mrem thyroid COE. Please explain why setpoints that correspond to 1000 mrem TEOE or 5000 mrem thyroid COE were not used for the Plant Vent and Main Steam monitors or revise accordingly.
- d. For EALs RU1 .1, RA 1.1, RS1 .1, and RG1 .1, please explain how a release of radioactivity due to steam generator tube leakage could be accurately assessed with the reactor either in operation or shutdown from power operation for less than an hour. Note: in addition to the above assumption that the reactor was shut down for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, Table R-1 contains the note "with the reactor shutdown."
- e. For EALs RA 1.1, RS 1.1, and RG1 .1, please explain how a release of radioactivity due to steam generator tube leakage could be accurately assessed with the assumption that flow rate will be 120,000 lbm/hr for 15 to 60 minutes following the initiation of a steam generator tube leak.
RAl-7 For EALs RA 1.2, RS1 .2, and RG1 .2, Note 3 was included in the EAL. This note was intended to apply to EALs that solely rely on a radiation monitor reading. Please provide justification for including Note 3 for EALs that rely on dose assessment using actual meteorology or revise accordingly.
RAl-8 For EAL RU2.1, site-specific refueling pathway level indication is not provided in the EAL per NEI 99-01, Revision 6. Although the level indications are provided in the CPNPP basis, it is not provided as part of the actual EAL and is not provided on the EAL Wallcharts for CPNPP.
Please provide additional information as to why omitting specific level instrumentation for the EAL and Wallchart would not affect timely and accurate assessment, or revise the EAL to provide applicable site specific level indications.
RAl-9 EAL RA 2.1 states, "Unusual Event," rather than an Alert as indicated in NEI 99-01, Revision 6, for this EAL. Please provide justification for this difference or revise accordingly.
RAl-10 For EALs RA2.3, RS2.1, and RG2.1, please specify where the indications for the enhanced spent fuel pool level are located at and what the timeliness is for obtaining this information for classification.
RAl-11 For EAL CS1 .1, the CPNPP Basis refers to reactor coolant system (RCS) elevations illustrated in Figure C-3, which is not provided in the CPNPP Basis document. Additionally, the NEI Basis refers to EALs CS1 .1 and CS2.2. There is no CS2.2 in the CPNPP proposed EAL scheme.
Please provide clarification for the two discrepancies.
RAl-12 For EAL CU3.1, the proposed EAL contains the condition, " ... due to the loss of decay heat removal capability," which is not consistent with NEI 99-01, Revision 6. This deviation could result in potential misclassification for an event other than a loss of decay heat removal capability that leads to an unplanned RCS temperature to rise. Please provide justification for this deviation, or revise accordingly consistent with NEI 99-01, Revision 6.
RAl-13 For EALs CU3.1 and CU3.2, the proposed EAL CPNPP Basis states, "classification should be based on the RCS pressure increase criteria when the RCS is intact in Mode 5." It was not clear to the NRC staff what pressure increase criteria would be used to assess CU3.1 or CU3.2.
Please provide clarification for the CU3.1 and CU3.2 comments related to classification based on RCS pressure increase.
RAl-14 For EAL CA3.1, the proposed EAL contains the condition, " ... due to the loss of RCS cooling,"
which is not consistent with NEI 99-01, Revision 6. This deviation could result in potential misclassification for an event other than a loss of RCS cooling that leads to an unplanned RCS pressure increase. Please provide justification for this deviation, or revise accordingly consistent with NEI 99-01, Revision 6.
RAl-15 For EALs CA6.1 and SA9.1, the CPNPP Basis includes lake level as a hazardous event. No specific value is provided for either a high or low lake level as part of the EAL. It is not clear to the staff how a timely and accurate assessment could be performed for events related to lake level. Please provide justification for not including high/low lake levels in the appropriate Hazardous Event EAL tables or revise accordingly.
RAl-16 For EAL HU3.2, the proposed CPNPP Basis identifies the Safeguards Building and the Turbine Building as internal flooding areas of concern. Additionally, the CPNPP 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 Safeguards Building and the Turbine Building or revise accordingly.
- b. Please explain why EAL HU3.2 references an EAL that is only applicable in lower modes.
RAl-17 For EAL HU4.1, the "Basis-Related Requirements from Appendix R" discussion provided in NEI 99-01 HU4 was not included in the CPNPP EAL HU4.1 Basis discussion. This discussion clarifies which rooms or areas should be included in the respective EALs. As such, this discussion supports timely and accurate assessments either during training activities or actual event conditions. Please provide further justification for exclusion of this Appendix R basis information, or revise accordingly.
RAl-18 For EALs SS1 .1, SG1 .1, and SG1 .2, Table S-1, "AC Power Sources" were included. These tables are limited to those power supplies that are capable of providing power to the safeguard buses. However, for a Site Area Emergency or a General Emergency, the licensee may establish the capability to power a safeguard bus from an alternate power supply during the additional time that may be potentially available. Please justify including Table S-1 for SS1 .1, SG1 .1, and SG1 .2 or revise accordingly.
RAl-19 For Initiating Condition (IC) Fuel Clad Fission Product Barrier (FC) C.2 Loss, the relevant developer note states:
Add this paragraph (or similar wording) to the Basis if the threshold includes a sample analysis component, "It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete. Nonetheless, a sample-related threshold is included as a backup to other indications."
Please provide justification for not including the above developer guidance in IC FC C.2 or revise accordingly.
RAl-20 For IC Reactor Coolant System Fission Product Barrier (RC) A.2, Potential Loss, the NRC staff could not specifically determine which critical safety function status table (CSFST) Integrity-RED Path was intended by this IC. Please provide clarification as to the specific RED path that should be used to assess this condition.
ML15345A011 *via email dated 11/19/15 OFFICE NRR/DORL/LPL4-1/PM NRR/DORL/LPL4-1 /LA NSIR/DPR/ORLOB/ORLT/BC NAME BSingal JBurkhardt MNorris (A)*
DATE 12/14/15 11/19/15 OFFICE N RR/DORL/LPL4-1 /BC NRR/DORL/LPL4-1 /PM NAME RPascarreli BSingal DATE 12/15/15 12/16/15