ML17059A361

Emergency Action Level Verification & Validation Rept.

ML17059A361
Person / Time
Site:	Nine Mile Point, Indian Point, Ginna, FitzPatrick
Issue date:	07/06/1994
From:	Bram S CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:
Shared Package
ML17059A362	List: ML17059A361 ML18041A029
References
NUDOCS 9407210069
Download: ML17059A361 (332)

Text

OSSI 93-402A-10-IP2 IP-2 EAI Verificatio & VaIIdation Report, Rev. 0 Emer enc Action Level Verification R Validation Re ort R vision 0 New York Power Authori J. A. Fitzpatrick Nuclear Power Plant Indian Point Nuclear Power Plant Unit 3 Nia ara Mohawk Power Co oration Nine Mile Point Unit I Nine Mile Point Unit 2 ConsoHdated Edison Com an Indian Point Station Unit 2 Rochester Gas and Electric Com an R E. Ginna Nuclear Power Station Operations Support Services, Inc.

233 Water Street 2nd Floor Plymouth, MA 02360 94072i00b9 9'4070b PDR ADOCK 05000220 F. PDR )(

J OSSI 93-402A-10-IP2 IP-2 EAL Verification & Validation Report. Rev. 0 Table of Contents Section ~Pa e 1 Introduction .. ~,......~.......~... ~ ~....~....~.......,.. ............. ~........... .,.. .,.........................,... 1

~ ~ ~ ~

2. Preparations . ~.....~...... ~ .~.....,. ~ ~ ~ ~ .. . .. . ~,...........~..........

~ ~ ~ ~ ....... ...... .~....~......... ......

~ ~ ~ ~ 1 3 Process ~ ~ ~ ~~ ~ os ~ os ~o~o ~ oo ~ oooo ~ ~ oo 4 3 .1 Verification Activities ...~.... ~ .,...........................~.....................~....................4 3 2

~ Validation ActiviGes ...............,.............................,.......,....................... 5 4, Comment Resolution ...~..........~... .~.......

~ ~ ~ ~~~~~~~~o~~~~o~o~~~~~~ oooooooo 9 5 References ....~...................................~....,........ ~ .~....................,.....~......,........................ 9 Attachment 1 EAL Verification Checklists ....,........................,................,................,..............,.1 1 Attachment 2

, EAL Verification Comment Database ~ ~ ..,......~....,................, ~ ..,.. ~ ~ ~ ..............~...2-1 Attachment 3 EAL Validation Scenarios. ~ ~~ ~ o ~ ~ o ~ o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~o~~~~~~~~~o~ ~~ 3 Attachment 4 EALValidation Summary Sheets...~....~........... ~ ~ .. ~ ~ ~~ ~ ~ ~ os ~ oo4 1 Attachment 5 EALValidation Exercise Checklists.............................................................,...........5-1 Attachment 6 EAL Validation Comment Database ..~...... ...... ~.....~.....

~ ~ ~ ..........,.... ..,....,........~...... .6

~ ~ 1

OSSI 93-402A-10-IP2 IP-2 EAI VeriAcation & Validation Report, Rev. 0 1..Introduction The verification process was performed to ensure the IP-2 Emergency Action Levels (EALs) and classification procedures are written correctly and are technically correct. The IP-2 EAL verification was conducted prior to the EAL validation exercises. Verification activities were completed according to Reference l.

The validation process was performed to ensure that the IP-2 EALs and classification procedures are usable and operationally correct, and to ensure that responsible emergency response organization personnel are able to arrive at consistent interpretations of EALs under varying conditions. The IP-2 EAL validation exercises were conducted on October 21, 1993 at the Indian Point Unit 2 Training Center. Validation activities were completed according to Reference 2.

The IP-2 EAL verification/validation was one of six verification/validations conducted by OSSI at each of the six participating plants in the NYPA EAL Upgrade Project.

2 ~2 Mr. C. K. Walker (OSSI) was assigned EAL verification and validation team leader. For EAL verification, he was responsible for:

~ Determining the extent to which the EAL documentation is verified.

~ Selecting team members to conduct EAL verification reviews,

OSSI 93-402A-10-IP2 IP-2 EAL Verfffcatfon & Vaifdatfon Report, Rev. 0

~. Providing appropriate source documents so team members can conduct verification reviews.

~ Coordinating resolutions to any verification review comments.

~ Coordinating update of EAL program documentation consistent with the resolution of verification review comments.

~ Determining the extent to which each selected EAL is validated.

For EAL validation, Mr. Walker was responsible for:

~ Selecting team members to participate as validation exercise observers and as emergency response organization personnel during EAL validation exercises.

~ Preparing a validation exercise test plan and schedule. (EALs selected for validation are documented on the Validation Summary Sheet which served as the validation test plan,)

~ Obtaining appropriate scenarios to test emergency response organization classification activities while using the EALs.

~ Coordinating resolutions to validation exercise comments.

~ Coordinating update of EAL program documentation consistent with the resolution of validation exercise comments.

Mr. M. C. Daus (OSSI) was assigned to the verification team and was responsible for:

~ Becoming familiar with appropriate verification source documents and the IP-2 EALs to be verified.

~ Performing assigned EAL verification reviews.

OSSI 93-402A-10-IP2 IP-2 EAL Verification R Validation Report, Rev. 0

~ Completing verification checklists for technical accuracy and written correctness reviews.

~ Assisting in the preparation of resolutions to verification review comments.

Mr. J. P. Staley (OSSI) and Mr. W. Kessler (ConEd) were assigned EAL validation exercise observers. They were responsible for:

~ Becoming familiar with appropriate IP-2 EAL development documents and the EALs to be validated.

~ Observing emergency response organization participants using the EALs while responding to simulated emergency events.

~ Completing the validation exercise checklists

~ Assisting in the preparation of resolutions to validation exercise comments.

Several members of the IP-2 plant staff were also assigned to the validation team to play the role of emergency response organization positions. Their names and titles are listed on the EAL Validation Summary sheets (Attachment 4). They were responsible for:

~ Becoming familiar with the EALs to be validated.

~ Using the EALs while responding to simulated emergency events.

~ Completing the validation exercise checklists.

OSSI 93-402A-10-IP2 IP-2 EAL Verification & Validation Report, Rev. 0

3. Process 3.1 Verification Activities The technical accuracy and written correctness of the upgraded EALs were verified through table-top reviews which addressed the following EAL attributes:

Written Correc ne Human engineering factors of the EAL Writer's Guide Format, appearance and terminology consistent, to the extent possible, among BWR and PWR plants involved in the NYPA EAL Upgrade Project EAL structure EAL terminology is clear and well defined Technical Accurac Technical completeness and appropriateness for each classification level Potential for classification upgrade only when there is an increased threat to public health and safety Logical progression in classification for combinations of multiple events Consistency of EALs, to the extent possible, among BWR and PWR plant designs The EALs were reviewed in terms of the evaluation criteria embodied in the checklists for technical accuracy and written correctness (Attachments 1 and 2 of Reference 1). EAL verification reviews for technical accuracy and written correctness were accomplished by a comparative Table-Top evaluation of the following:

OSSI 93-402A-10-IP2 IP-2 EAL Verification & Validation Report, Rev. 0

~ . Written correctness of the EALs including human factors guidance of the EAL writer's guide.

~ Technical accuracy of the EALs compared to the EAL Technical Basis, EAL Fission Product Barrier Evaluation, Plant-Specific EAL Guideline, EAL Binning Document, and NUMARC NESP-007, Revision 2 (including NUMARC/NRC Questions and Answers).

~ Compatibility of the EALs with the plant.

~ Numerical values, quantitative and calculated information, The Walk-thru method of verification was performed during EAL validation where necessary EAL references to equipment, indications and instrumentation were checked against control room hardware as represented in the simulator control room.

h Verification reviews were performed using the applicable sections of the EAL verification checklists (Attachment 1). All discrepancies were documented on EAL Comment Forms in the EAL Verification Comment Database. A printout of this database is provided in Attachment 2.

3.2 Validation Activities The usability and operational correctness of the upgraded EALs were validated through observation of emergency response organization personnel responding to simulated emergency events using the EALs. The group of EALs selected for validation were sufficiently representative to test that the EALs possess the following attributes:

~Usabilt

~ User friendliness

~ Ease of place-finding

OSSI 93-402A-10-IP2 IP-2 EAL Verification 8c Valtdation Report, Rev. 0

~ Ease of place-keeping

~ Ease of upgrading and declassifying 0 erational Correctness Potential for classification upgrade only when there is an increased threat to public health and safety Technical completeness and appropriateness for each classification level A logical progression in classification for combinations of multiple events EALs not selected for validation were compared to the validation checklist criteria at the conclusion of the validation exercises.

The EALs were validated in terms of the evaluation criteria embodied in the checklist for EAL evaluation. EAL validation exercises were conducted using the Table-Top method. Scenarios were developed and used in the performance of the Table-Top method of validation (Attachment 3). The scenarios provided the means for validation team observers to view emergency response organization personnel consulting the EALs for proper emergency classification.

In the classroom, members of the EAL validation team were introduced to the upgraded EALs by the team leader. ClassiQcation categories and subcategories were discussed as were the technical basis for individual EAL conditions. This served to familiarize all validation team participants with the content of the new EALs and their relationship to the existing classification procedures. Members of the validation team were also briefed on the validation process described in Reference 2. Copies of the upgraded EALs were made available to team members during the validation exercises.

The EAL validation test plan is given on the EAL Validation Summary Sheets in Attachment 4. For each EAL validation scenario, the following activities were performed:

OSSI 93-402A-10-IP2 IP-2 EAL Verification & Validation Report, Rev. 0

1. The validation team members assumed the emergency response organization roles they were expected to fulfill during an actual emergency.

2. The team leader described the initial plant conditions.

3. When emergency response organization personnel were familiar with initial plant conditions, the team leader announced the start of the scenario exercise and described changes in key plant parameters.

4. The emergency response organization personnel described the actions they would perform.

5. The emergency response organization personnel consulted the upgraded EALs according to Emergency Plan procedures and made appropriate classifications.

6. The team observers occasionaly asked questions of the emergency response organization personnel during the exercise.

7. When final plant conditions were reached, the validation team leader stopped the exercise and held a post scenario briefing during which:

~ Team members jointly discussed problems and comments noted during the=exercise.

~ Team members jointly completed the EAL Validation Exercise Checklists (Attachment 5).

~ Possible reasons for noted problems and comments were discussed.

OSSI 93-402A-10-IP2 IP-2 EAL VeriQcation & Validation Report, Rev. 0

~ In some cases, portions or all of the exercise were reperformed to gain a better perspective of noted problems and comments, The validation team leader ensured the following information was recorded on each Validation Exercise Checklist:

Date and plant name Validation team member names and titles EAL identification number of EALs validated Scenario description Validation method Following each post-scenario briefing, team members compared observations and determined if any problems and comments noted thus far required modification of the test plan to achieve validation objectives.

When all validation exercises were completed, the team leader, with the assistance of the team members, consolidated all exercise problems and comments by:

~ Reviewing every problem and comment recorded on the EAL Validation Exercise Checklists.

~ Recording problems and comments in the EAL Validation Comment Database. A printout of this database is provided in Attachment 6.

~ Recording EAL Comment numbers on the EAL Validation Exercise Checklists.

OSSI 93-402A- IO-IP2 IP-2 EAL Vertfication & Valldatton Report, Rev. 0 4..Comment Resolution Mr. Walker and Mr. Staley evaluated each verification and validation comment recorded in the EAL comment databases. They reviewed the comment discrepancies and determined the accuracy of the discrepancy.

Reference materials in EAL development were used to identify the scope, of the discrepancy and to prepare appropriate solutions.

They prepared resolutions to the discrepancies, determined the impact the final resolutions have on EAL Program documentation, determined the impact the final resolutions have on the plant, and identified any required follow-up actions.

Results of the verification and validation comment resolution process were documented in the EAL Verification Comment Database (Attachment 2) and the EAL Validation Comment Database (Attachment 6), respectively.

5. References

l. OSSI 92-402A-6, Emergency Action Level Verification, Revision 0

2. OSSI 92-402A-7, Emergency Action Level Validation, Revision 0

OSSI 93-402A-10-IP2 IP-2 EAL Verification & Validation Report, Rev. 0 Attachment 1 EAL Veri6cation ChecMists

OSSI 92-402A-6-IP2 EAI. Verification Procedure, Rev. 0 Attachment 1 Technical Accuracy Plant: IP2 Date: 9 20 9 Verifier M. C. Daus EALU ade Pro t En in er name title Yes ~N NA

1. Plant-specific EAL Guideline (PEG) comparison to NESP-007, Revision 2, including NRC reviewed questions and answers:

1.1 Does each NESP-007 initiating condition have a corresponding PEG initiating condition that reflects the meaning of the NESP-007 IC'? ~ Q Q 1.2 Does the operating mode applicability of each PEG initiating condition agree with the NESP-007 operating mode applicability' ~ Q Q 1.3 Is each PEG EAL derived from a corresponding NESP-007 example EAL applicable to plant specific design' ~ Q Q 1.4 Do PEG EALs reflect the intent of the NESP-007 example EALs'? Q ~ Q 1.5 Does the PEG EAL bases reflect the intent of the NESP-007 EAL bases which are applicable to plant specific design' Q ~ Q

OSSI 92-402A-6-IP2 EAL Verification Procedure, Rev. 0 Attachment 1 Technical Accuracy Yes No NA 1.6 Are the PEG EALs complete and appropriate (i. e., is additional information needed, should any information be deleted)' 0 ~ 0 1.7 Is each applicable PEG fission product barrier EAL properly considered in the fission product barrier evaluation for this plant' ~ Q CI 1-2

OSSI 92-402A-6-IP2 EAL Verification Procedure, Rev. 0 Attachment 1 Technical Accuracy Yes No NA

2. EAL Technical Basis (TB) comparison to the Plant-Specific EAL Guideline (PEG), Fission Product Barrier Evaluation (FPBE) and EAL Binning Document:

2.1 Does the set of TB categories and subcategories satisfactorily reflect the set of PEG initiating conditions as defined in the EAL Binning Document' ~ 0 0 2,2 Is each TB EAL derived from one or more corresponding PEG EALs as defined by the FPBE and EAL Binning Document' 0 ~ 0 2.3 Do TB EALs reflect the intent of the PEG EALs from which they are derived' 0 ~ 0 2.4 Does the operating mode applicability of each TB EAL agree with the corresponding PEG EAL operating mode applicabilityV ~ 0 0 2.5 Does the TB EAL bases reflect the intent of the PEG EAL bases and FPBE'? 5 0 0 2.6 Are the references listed for each TB EAL appropriate and consistent with the PEG:

~ PEG Reference(s)'? 0 ~ 0

~ Basis Reference(s)'? 0 ~ 0 1-3

OSSI 92-402A-6-IP2 EAI- Verificatfon Procedure, Rev. 0 Attachment 1 Technical Accuracy Yes No NA 2.7 Are the TB EALs complete and appropriate (i. e., is additional information needed, should any information be deleted)'? ~ Q Q 2.7 Does each "Remark" in Tables A through D of the fission product barrier evaluation for this plant satisfactorily explain the reason a PEG EAL or combination of PEG EALs is nttn needed for event classification' ~ Q Q 2.8 Are the resultant fission product barrier evaluation EALs for this plant properly addressed in the TB at the appropriate classification level:

~ Unusual Event' r Q Q

~ Alert' ~ Q Q

~ Site Area Emergency' ~ Q Q

~ General Emergency' Q ~ Q 2.9 Does the potential exist for classification upgrade only when there is an increased threat to public health and safety' Q Q 2.10 Is there a logical progression in classification for combinations of multiple events within a category' ~ Q Q 1-4

OSSI 92-402A-6-IP2 EAL Verification Procedure, Rev. 0 Attachment 1 Technical Accuracy Y~ ~N NA

3. EAL comparison to the EAL Technical Basis (TB):

3.1 Does the set of EAL categories and subcategories agree with the TB categories and subcategories, respectivel+ ~ Q Q 3.2 Is each EAL condition derived from a corresponding TB EAL condition' ~ Q Q 3.3 Does the operating mode applicability of each EAL agree with the corresponding TB EAL operating mode applicability' ~ Q Q

4. EAL comparison to the plant Control Room (Simulator):

4.1 Are as-labeled designations used to identify specific components, alarms, controls, and instruments to the extent practicable'? r Q Q 4.2 Is each EAL adequately supported by plant instruments, approved instructions, or other appropriate sources of information' ~ Q Q 1-5

OSSI 92-402A-6-IP2 EAL Verlffcation Procedure, Rev. 0 Attachment 1 Technical Accuracy Y~e No NA 4.3 Where EAL conditions specify numerical values, are the units of measurement the same as those'presented on the respective plant panel instruments, approved instructions, or other sources of information' ~ Q Q 4.4 Where EAL conditions specify numerical values, are the values expressed to a precision consistent with the accuracy and precision of the respective instrumentation' ~ Q Q All discrepancies have been recorded on EAL Comment Forms and forwarded to the Verification Team Leader.

Signature: Date: 9 20 93 1-6

OSSI 92-402A-6 EAL Verification Procedure, Rev. 0 Attachment 2 Written Correctness Plant: IP2 Date: 9 20 93 Verifier: M.C.D u Pro ectEn ine r name title Yes No NA

l. EAL Organization:

1.1 Is each EAL assigned to one of nine categories' ~ Q Q 1.2 Is each subcategory clearly associated with its category'.

EAL Identification:

2.1 Is each EAL identified with a unique three digit number whose first digit corresponds to the category number, second digit the subcategory number, and third digit the EAL sequence number' ~ Q Q 2,2 Do EAL sequence numbers increase in magnitude as classifications change from Unusual Event, to Alert, to Site Area Emergency, and to General Emergency' ~ Q Q 2-1

OSSI 92-402A-6-IP2 EAL Verification Procedure, Rev. 0 Attachment 2 Written Correctness Yes ~N NA 2.3 Where an EAL condition does not exist in a category/subcategory for a given emergency classification, has "NA" been entered in place of the EAL identification numbers Q ~ Q

3. EAL Length and Content:

3.1 Is each EAL clear and concise' ~ Q Q 3.2 Have verbs and articles been deleted from EALs where technical accuracy and reading clarity permit' ~ Q Q 3.3 Are EALs consisting of multiple conditions formatted such that each condition and its relationship to other conditions are easily understood' 5 Q Q 3.4 Is wording and abbreviations/ acronyms used in the EALs consistent with the deAnitions provided in Attachments 1 and 2 of the EAL Writer's Guide' ~ Q Q 3.5 Are EAL conditions expressed quantifiably where possible' ~ Q Q 3.6 Where used, do limit modifiers (<, >, 5, 2) simplify presentation of EAL conditions' ~ Q Q 2-2

OSSI 92-402A-6-IP2 EAL Verification Procedure, Rev. 0 Attachment 2 Written Correctness Y~e ~N NA 3.7 Are annunciator setpoints not given in EALs when the setpoint is common operator knowledge or the setpoint is subject to frequent adjustment (e. g., area radiation monitor alarm setpoints, offgas radiation monitor alarms, etc.)'? ~ Q Q

4. Use of Logic Terms:

4.1 When an EAL must express a combination of two conditions, are the conditions joined by the logic term AND'? ~ Q Q 4.2 When an EAL must express an alternate combination of two conditions, are the conditions joined by the logic term OR' 0 Q Q 4.3 Is the use of AND and OR within the same EAL avoided where possibleV A Q Q 4.4 Is each EAL condition clear and concise' ~ Q Q 2-3

OSSI 92-402A-6-IP2 EAI Verification Procedure, Rev. 0 Attachment 2 Written Correctness Yes No NA

5. Presentation of information in tables:

5.1 Is each table presented in a rectangular enclosure with a table number and title printed above the table entries' ~ Q Q 5.2 Are column headings with applicable engineering units provided for tables with multiple columns of information' Q 5 Q 5.3 Where vertical lines separate columns of information, is readability improved' ~ Q Q 5.4 If an entry is not required in a table cell, is the abbreviation "N/A" used' ~ Q Q

6. Mechanics of style:

6.1 Is the use of hyphens minimized, and ~no used to break words between lines' ~ Q Q 6.2 Is punctuation used only as necessary to aid reading and prevent misunderstandingV S Q Q 6.3 Are parentheses used to enclose location information in EALs and to visually separate supplemental/qualifying information from the primary information being stated' r Q Q 2-4

OSSI 92-402A-6-IP2 EAL Verification Procedure, Rev. 0 Attachment 2 Written Correctness Y~s No NA 6.4 Is word usage consistent among the EALs'? 5 Q Q 6.5 Are numbers in the EALs printed in Arabic numerals' ~ Q Q 6.6 Are EAL limits specified in such a way that addition and subtraction by the user is avoided' ~ Q Q 6.7 Are EAL limits expressed to a precision consistent with the intent of the EAL as specified in the TB and PEG'? r Q Q

7. EAL format:

7.1 Are three or more multiple items (systems, plant conditions, etc.) for which there is no preference or priority arranged in a list format with each item prefaced by a bullet' 5 Q Q 7.2 Are EAL limit values, value modifiers and value engineering units printed in bold print' ~ Q Q All discrepancies have been recorded on EAL Comment Forms and forwarded to the Verification Team Leader, Signature Date: ~920 93 2-5

OSSI 92-402A-6-IP2 EAL Verification Procedure, Rev. 0 Attachment 3 Inter-Plant EAL Comparison Plants: Indian Point 2 Date: 9 20 93 Indian Point 3 Ginna Verifier: M.C. Daus EAL Pro ect En ineer name title Yes No NA

1. Within the constraints of BWR and PWR plant design, is each plant type EALs composed of the same categories' ~ Q Q

2. Within the constraints of BWR and PWR plant design, is each plant type EALs category composed of the same subcategories'

3. Within the constraints of BWR and PWR plant design, does the operating mode applicability of each EAL the same for each plant? Q Q

4. Where individual plant design permits, are the condition(s) of each EAL the same for each plant' Q S Q 3-1

OSSI 92-402A-6 EAL Verification Procedure, Rev. 0 Attachment 3 Inter-Plant EAL Comparison Yes No NA

5. Where individual plant design permits, are the limit value(s) of each EAL condition the same for each plant' Q 5 Q

6. Within the constraints of BWR and PWR plant design, is EAL word usage the same for each plant' ~ Q Q All discrepancies have been recorded on EAL Comment Forms and forwarded to the Verification Team Leader.

Signature Date: ~920 93 3-2

OSSI 93-402A-10-IP2 IP-2 EAI- Ver1ffcatton Bc Validation Report, Rev. 0 Attachment 2 EAL Vexi6cation Comment Database 2-1

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~ ~ ~ ~ ~

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Record No. 1 Date 9/20/93 Name M. C. Daus Orlglnating Site Impact IP-2 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-3 Q EAL E Technical Bases Q Validation Q Deviation Q None Ginna sit A II bllit" Q AF Q IP3 Q NMP2 Q Generic BWR 8 General Q IP-2 Q NMP-1 Q Ginna Q Generic PWR cat. Hazards Ic¹ 2 No. 1 Emer. Class. Site Al'ea Comment HS2 (verification question 1.6): The NESP-007 IC and example EAL specify ".:. plant control cannot be established" but the PEG IC and EAL specify "... core cooling cannot be established." The basis should provide justification for the difference. Consider addition of the following statement to the basis discussion:

Resolution Added above wording to PEG bases of all plants.

status 0 Open 0 Resolved/Awaiting Disposition Oe Closed Record No 2 Date 9/20/93 Name M. C. Daus Orlglnatlng Site Impact IP-2 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-3 Q EAL H Technical Bases Q Validation . Q Deviation Q None Ginna

" Q Q NMP-2 Q Generic BWR Q General JAF Q IP-3 Q IP-2 Q NMP-1 Q Ginna El Generic PWR ca t. System Malf. Ic¹ 1 No. 1 Emer. Class. Alert Comment PEG SA2 (verification question 3 in Attachment 3): The wording of this IC for Ginna differs from that of IP2/3. The reason for the difference is not apparent. Should they be worded the same?

Resolution Ginna PEG revised to be consistant with IP2/IP3 status 0 Open 0 Resolved/Awaiting Disposition Oi Closed

Record No 3 Date 9/20/93 Name M. C. Daus Originating Site Impact Q NUMARC-007 Q Procedure p Verification Q Training Q Hardware Q EAL H Technical Bases Q Validation Q Deviation Q None Ginna

" o Q NMP-2 Q Generic BWR Q General JAF Q IP-3 Q IP-2 P NMP-1 P Ginna HGeneric PWR ca t. System Malf. Ic¹ 1 No. 1 Emer. Class. Site Al'ea Comment PEG SS2 (verification question 3 in Attachment 3): The wording of this IC for Ginna differs from that of IP2/3. The reason for the difference is not apparent. Should they be worded the same?

Basis for IP2/3 does not explain reason for difference from NESP-007. Should include wording in Basis section similar to that in SA2.

Resolution Revised PEGs to reflect same IC and bases to reflect EAL The bases now reads:

Zhh SttnditiE1 addrassas'ag manual tan ar autftnuuia ttia sianal hlhmad hit a manual tna tithe Iaifs tn shut shun tba raaatttchHQ Haaatttr ttntttar ~F/

Automatic and manual scram are not considered successful if action away from the reactor control console was required to scram the reactor.

EKED Suharithalitx:BED uath h antarad hasad m Iailura al uatar ranaa indfaatittn tn daaraasa haifm Flulallmimt araaatur tnL 3'tttian al tba EhL addrassas amt manual ttia ar autnmath im sianal tffnMtad hy. a manual Itin tttbich hih tn shut dann tba raaatttr h m atttant that tha raactnr h uradmintt atria haat Iliad fx tttbiah tba salable stfstams um dasignad.

%Vie nnndiann innar otoe foihtm nf Ivy tho oiitnmoan onrl inomiol nrntor tinn eoetame tn trin the mcuHnr in ~itic tinn takh o foQ<iro nf oltornoto hnrotinn status 0 Open 0 Resolved/Awaiting Disposition Oo Closed Record No. 4 Date 9/20/93 Name M. C. Daus Originating Site Impact IP-2 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-3 g EAL H Technical Bases Q Validation Q Deviation Q None Ginna iicabiiit" Q JAF Q IP-3 P NMP-2 Q Generic BWR Ql General Q IP-2 Q NMP-1 Q Ginna I31 Generic PWR ca t. Barrier I C¹ ** No. ** Emer. Class. **

Comment PEG PC2.1 (verification question 3 in Attachment 3): NESP-007 states "Rapid or unexplained ...";

the PEG "Rapid unexplained ...". The reason "or" is missing from the PEG is not explained. EAL TB 4.1.2 is also missing the word "or".

Resolution Table in NUMARC Q&A 6/93 states "rapid or unexplained'ut this is wrong. No change required.

status 0 Open 0 Resolved/Awaiting Disposition 0+ Closed

Record No 5 Date 9/20/93 Name M. C. DauS Originating Site Impact IP-'2 HNUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-3 Q EAL Q Technical Bases Q Validation Q Deviation Q None Ginna Site A licabllit" Q JAF Q IP-3 Q NMP-2 Q Generic BWR I I General Q IP-2 Q NMP-1 Q Ginna IHI Generic PWR cat. Barrier I C¹ ** No. ** Emer. Class. **

Comment NESP-007 Table 4 Item 3 Questions and Answers: The conditions under the loss and potential loss columns are still displaced and are not correct. The PEGs are correct. NUMARC should be notified that the table remains inaccurate.

Resolution status 0 Open 0 Resolved/Awaiting Disposition 0 Closed Record No. 6 Date 9/20/93 Name M. C. DauS Originating Site Impact IP-2 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-3 Q EAL QTechnical Bases QValidation g Deviation QNone Ginna sit A II JAF Q IP-3 blllt"QIP-2 Q NMP-2 Q Generic BWR H General QNMP-1 QGinna QGenericPWR cat. Abnorm. Rad. Ic¹ 2 No. 4 Emer. Glass. Unusual Event Comment (Attachment 1 question 1.5): Basis discussion of AU2.4 does not provide reason for addition of the word "sustained" to this EAL. Suggest adding the following sentence to the basis:

"Only prolonged ARM readings are considered in this EAL to avoid unnecessary emergency declaration due to momentary and temporary radiation levels that briefly exceed 100 times the Resolution Revised all plants PEGs to reflect comment wording.

sta~us OOpen OResolved/Awaiting Disposition OClosed

Record No 7 Date 9/2Q/93 Name M. C. Daus Originating Site Impact IP-2 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-3 Q EAL Q Technical Bases Q Validation Q Deviation Q None sit A II blllt"glP-2 JAF El II' QINMP-2 QGeneric BWR QGeneral QNMP-1 QGinna QGenericPWR 1

ca t. Abnorm. Rad. I c¹ 1 No. 1 Emer. Class. Alert Comment (Attachment 1 question 1.4): The condition "... ~nLhhr ~h~ng~fili~r+~il @ ..." has been added to example EAL AA1-1 without justification. The added condition has not been included in the EAL TB. Suggest deleting the added condition.

Resolution Deleted added wording from IP2 and IP3 status OOpen OResolved/Awaiting Disposition OClosed Record No. 8 Date 9/2Q/93 Name M. C. Daus Originating Site Impact IP-2 QNUMARC-007 QProcedure QVerification QTraining QHardware IP-3 Q EAL Q Technical Bases Q Validation Q Deviation Q None Ginna

" Q JAF Q IP-3 Q NMP-2 Q Generic BWR g General Q IP-2 Q NMP-1 Q Ginna Q Generic PWR cat. Abnorm. Rad. Ic¹ 2 No. 1 Emer. Class. Alert Comment (Attachment 1 question 1.5): Th'e word "Confirmed ..." has been added to example EAL AA2-1 without justification. Suggest adding the following sentence to the basis discussion:

The radiation monitor alarm associated with this EAL must be confirmed to avoid unnecessary declaration of an emergency due to a spurious alarm signal.

Resolution Added the following statement to the PWR PEGs:

The radiation monitor alarm associated with this EAL must be confirmed to avoid unnecessary declaration of an emergency due to a spurious alarm signal ~

senatus OOpen OResolved/Awaiting Disposition OiClosed

t)g Record No 9 Date 9/20/93 Name M. C. Daus Orig lnatlng Site Impact Q NUMARC-007 0 Procedure 0 Verification 0 Training 0 Hardware 0 EAL 0 Technical Bases 0 Validation Q Deviation 0 None sit A II blllt" 0 JAF 0 IP-3 0 NMP-2 j Generic BWR IHI General I

Q IP-2 Q NMP-1 0 Ginna Q Generic PWR cat. Abnorm. Rad. IC¹ 2 No. 2 Emer. Class. Alert Comment (Attachment 1 question 1.4): The phrase "... gr at~@~b~n~vl~r in Lhh ~FI p~~l." has been added to IP3 PEG EAL AA2.2 without justification in the basis. The phrase "... jl~Eugl~~,"

has been added to IP2 PEG EAL AA2.2 without justification in the basis. Besides being inconsistent between two nearly identical plants, this does not agree with NESP-007 intent to address fuel that may be uncovered in the cavity or tranfer canal. Suggest deleting the added words from the PEGs.

Resolution Deleted unjustified wording from IP2 and IP3 PEG.

status 0 Open 0 Resolved/Awaiting Disposition Oi Closed Record No. 10 Date 9/20/93 Name M. C. Daus Originating Site impact IP-2 0 NUMARC-007 0 Procedure 0 Verification 0 Training 0 Hardware IP-3 0 EAL 0 Technical Bases 0 Validation H Deviation 0 None Ginna

" 0 JAF 0 IP-3 0 NMP-2 IGeneric BWR H General I

0 IP-2 0 NMP-1 0 Ginna 0 Generic PWR cat. Abnorm. Rad. IC¹ 3 No. 2 Emer. Class. Alert Comment (Attachment 1 question 1.5): Basis discussion of AA3.2 does not provide reason for addition of the word "sustained" to this EAL. Suggest adding the following sentence to the second to last paragraph of the basis:

"Only prolonged ARM readings are considered in this EAL to avoid unnecessary emergency Resolution Added the following statement to all PEGs:

"Only prolonged ARM readings are considered in this EAL to avoid unnecessary emergency declaration due to momentary and temporary radiation levels that briefly 8 R/hr."

Added word "sustained" to NMP1 and NMP2 PEG EAL.

status 0 Open 0 Resolved/Awaiting Disposition Oe Closed

Record No. 11 Date 9/20/93 Name M. C. Daus Originating Site Impact IP-2 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware Q EAL Q Technical Bases Q Validation 8 Deviation Q None 4 II blllt" Q JAF Q IP 3 Q NMP-2 Q Generic BWR Q General g IP-2 Q NMP-1 Q Ginna Q Generic PWR ca t. Hazards Ic¹ 1 No. 1 Emer. Class. UnuSual EVent Comment (Attachment 1 question 1.5): Basis discussion of PEG EAL HU1.1 does not explain addition of condition that earthquake is sensed on U3 instrumentation. Suggest adding the following sentence to the basis discusssion of HU1.1:

"IP2 does not have seismic instrumentation and is dependent on U3 instrumentation to confirm an Resolution Added the following statement to IP2 PEG basis:

"IP2 does not have seismic instrumentation and is dependent on U3 instrumentation to confirm an earthquake event."

status 0 Open 0 Resolved/Awaiting Disposition Oe Closed Record No. 12 Date 9/20/93 Name M. C. DauS Origlnatlng Site Impact IP-2 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware Q EAL g Technical Bases Q Validation g Deviation Q None o JAF Q IP-3

" E IP-2 Q Q NMP-2 Q Generic BWR Q General NMP-1 Q Ginna Q Generic PWR cat. Hazards lc¹ 1 No. 7 Emer. Class. Unusual Event Comment (Attachment 1 question 2.3): IP2 PEG HU1.7 states: "Flood level equal to or greater than at site. River level less than -4.5'OMSL) at site". IP2 EAL TB states:

13.9'OMSL)

"River level 2 [later] (OMSL)

OR Resolution Changed PEG EAL HU1.7 to agree with wording of IP2 EAL TB shown above.

Note that another EAL comment identifies the need to provide water levels for this EAL.

status 0 Open 0 Resolved/Awaiting Disposition 0 Closed

Record No. 14 Date 9/20/93 Name M. C. Daus Orlglnatlng Site Impact IP-3 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-2 IHI EAL IHI Technical Bases Q Validation Q Deviation Q None Ginna Appllcablllt" Q JAF I I IP-3 I I NMP-2 I I Generic BWR I l General QIP-2 QNMP-1 QGinna HGenericPWR cat. Hazards lc¹ 1 No. 6 Emer. Class. Alert Comment (Attachment 1 question 2.2): PEG EAL HA1.6 is not included in the PWR EAL TBs. Suggest adding the following EAL as 7.2.2 and renumber those EALs that follow:

Turbine failure generated missiles result in any visible structural damage to plant vital equipment Resolution EAL TB and binning document for PWRs have been updated as suggested above.

sta~us 00pen 0 Resolved/Awaiting Disposition 0+ Closed Record No. 16 Date 9/20/93 Name M. C. Daus Orlglnatlng Site Impact IP-2 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware Q EAL IHITechnical Bases QValidation IHIDeviation QNone "Q Q NMP-2 I I Generic BWR Q General JAF Q IP-3 SIP-2 QNMP-1 QGinna QGenericPWR ca t. Hazards Ic¹ 1 No. 7 Emer. Class. Alert Comment (Attachment 1 question 2.3): IP2 PEG HA1.7 states: "River water level rises above 15 ft". IP2 EAL TB states:

"River level 2 [later] (OMSL)

OR Resolution IP2 PEG has been updated to agree with the EAL TB wording.

Note that another EAL comment identifies the need to provide water levels for this EAL.

senatus 00pen 0 Resolved/Awaiting Disposition Oi Closed Ie

Record No. 17 Date 9/20/93 Name M. C. Daus Or Iglnatlng Site Impact IP-2 p NUMARC-007 p Procedure O Verification p Training p Hardware O EAL pTechnical Bases OValidation ODeviation ONone Sit. A pll-blllt OJAF pip-3 ONMP-2 OGenericBWR OGeneral El IP-2 P NMP-1 O Ginna P Generic PWR cat. System Malf. lc¹ 1 No. 2 Emer. class. UnuSual Event Comment (Attachment 1 question 1.4): IP2 PEG SU2.1 adds the phrase "... (hot or cold shutdown) ...". There is no justification for it in the basis. The IP2 EAL TB does not mention the phrase. Suggest deleting the phrase to conform with NESP-007.

Resolution Deleted the phrase to conform with NESP-007 as suggested.

status Q Open 0 Resolved/Awaiting Disposition OI Closed Record No 18 Date 9/20/93 Name M. C. DauS Originating Site impact IP-2 p NUMARC-007 O Procedure O Verification O Training O Hardware IP-3 O EAL O Technical Bases p Validation O Deviation O None Ginna sit A Il blllt" P JAF OIP 3 ONMP-2 OGeneric BWR OGeneral O IP-2 O NMP-1 P Ginna H Generic PWR cat. System Malf. lc¹ 1 No. 1 Emer. Class. Alert Comment (Attachment 1 question 1.4): PEG EAL SA1.1 states loss of power "... for greater than 15 minutes" in part a of the EAL. There is no corresponding time limit in the NESP-007 EAL. Suggest deleting the time limit from part a in the PEG EAL.

Resolution Changed as suggested. The 15 min. time limit is associated with part c of the EAL where power is restored.

sta~us OOpen OResolved/Awaiting Disposition 0+Closed

Record No. 20 ate 9/20/93 Name M. C. DauS Originating Site Impact Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware Q EAL Q Technical Bases Q Validation Q Deviation Q None Ginna "QQ JAF Q IP-3 Q NMP-2 Q Generic BWR Q General IP-2 Q NMP-1 Q Ginna 8 Generic PWR cat. System Malf. IC¹ 1 No. 1 Emer. Class. Site AI'ea Comment (Attachment 1 question 1.4): PEG EAL SS1.1 states loss of power "... for greater than 15 minutes" in part a of the EAL. There is no corresponding time limit in the NESP-007 EAL. Suggest deleting the time limit from part a in the PEG EAL.

Resolution Changed as suggested. The 15 min. time limit is associated with part c of the EAL where power is restored.

status 0 Open 0 Resolved/Awaiting Disposition 0+ Closed Record No 22 Date 9/20/93 Name M. C. DauS Orig lnatlng Site Impact IP-2 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-3 Q EAL Q Technical Bases Q Validation Q Deviation Q None "gQ JAF g IP-3 Q NMP-2 QI Generic BWR QI General IP-2 Q NMP-1 QGinna QGeneric PWR ca t. System Malf. Ic¹ 2 No. 1 Emer. Class. Site Al'ea Comment (Attachment 1 question 2.3): PEG EAL SS2.1 does not state "RED path in F-0.1 Subcriticality".

IP2/3 EAL TB 1.5.2 uses this statement. The PEG should probably reflect the EAL TB with an explanation provided in the PEG basis for the difference from NESP-007.

Resolution Revised PEG to include basis for this EAL.

status 0 Open 0 Resolved/Awaiting Disposition 0 Closed

Record No. 23 oate 9/20/93 Name M. C. DauS originating Site Impact IP-2 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-3 Q EAL Q Technical Bases Q Validation Q Deviation Q None bllit" Q JAF Q IP-3 Q NMP-2 Q Generic BWR IHI General Q IP-2 Q NMP-1 Q Ginna Q Generic PWR ca t. Barrier I C¹ ** No. ** Emer. Class.

Comment (Attachment 1 question 1.7): PEG EAL RCS3.1 and RCS3.2 are listed in the FPBE Table on page 3 as RCS3a and RCS3b. The table indicates with a "Yes" that there is no plant conditions assigned to RCS3b (i. e., RCS3.2) and that there exists a Loss and a Potential Loss condition for RCS3a (i e.,~

RCS3.1). The PEG only lists a Loss condition for RCS3.1 and a Potential Loss condition for RCS3.2. Thus, there should be a "No" under the Potential Loss column for RCS3a and a "Yes" Re so lut ion Agree with comment. Note that references to RCS3a pot loss in the FPBE tables should be compared to PEG EAL RCS3.2 potential loss.

Revised the FPBE as stated.

status 0 Open 0 Resolved/Awaiting Disposition 0+ Closed Record No. 24 oats 9/20/93 Name M. C. Daus Originating Site Impact IP-2 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-3 Q EAL Q Technical Bases Q Validation Q Deviation Q None Ginna ppllcablilty "

IP 3 Q NMP 2 Q Generic BWR Q General Q IP-2 Q NMP-1 QGinna IHIGeneric PWR ca t. Barrier I C¹ ** No. ** Emer. Class. **

Comment (Attachment 1 question 1.7): PEG EAL RCS5 is listed as "None". The table on page 3 of the FPBE indicates with a "Yes" that there is a plant condition assigned to RCS5. The FPBE tables A through D correctly show that RCS5 is not supported by a plant condition. Therefore, the table on page 3 should be changed to a "No" in the Loss column for RCS5.

Resolution Agree with comment. Changed "Yes" to a "No" in the table on page 3 of the FPBE.

status 0 Open 0 Resolved/Awaiting Disposition Oi Closed

i lt V

Record No 25 Date 9/20/93 Name M. C. Daus Originating Site Impact IP-2 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware Ginna Q EAL QTechnical Bases QValidation Q Deviation Q None QJAF QIP-3 QNMP-2 QGenericBWR IHIGeneral QIP-2 QNMP-1 QGinna QGenericPWR cat. Barrier I C¹ ** No. ** Emer. Class.

Comment (Attachment 1 question 1.7): The FPBE Table on page 3 lists EALs for PC2a, 2b and 2c with loss and potential loss. These do not line up with the corresponding nomenclature in the PEG for PC EALs. There is an inconsistency in the way the FPBE identifies EALs and the PEG. This is due to the fact that the format for the FPBE was prepared before the PEGs were prepared. Note that PC2a loss is PC2.1, PC2b loss is PC2.2, PC2c loss is NA, PC2a pot loss is PC2.3, PC2b pot loss is Resolution Agree with comment.

Revise Table in FPBE for each plant the PEG EAL number that corresponds to each "Yes" response in the Table. Replace each EAL listed in Tables A through D with the PEG EAL number.

status 0+ Open 0 Resolved/Awaiting Disposition 0 Closed Record No. 26 Date 9/20/93 Name M. C. Daus Originating Site Impact IP-2 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-3 Q EAL QTechnical Bases QValidation QDeviation QNone Ginna sit Ap II blllt" Q JAF Q IP-3 Q NMP-2 Q Generic BWR E General QIP-2 QNMP-1 QGinna QGenericPWR cat c¹ ** No. * **

~ Barrier I Emer. Class.

Comment (Attachment 1 question 1.7): PEG EAL PC7.2 is listed as "None". The table on page 3 of the FPBE indicates with a "Yes" that there is a plant condition assigned to PC7 pot loss. The FPBE tables A through D correctly show that PC7 pot loss is not supported by a plant condition. Therefore, the table on page 3 should be changed to a "No" in the Potential Loss column for PC7.

Resolution Agree with comment. Changed "Yes" to a "No" in the table on page 3 of the FPBE.

status 0 Open Q Resolved/Awaiting Disposition 0+ Closed

Record No. 27 Date 9/20/93 Name M. C. Daus Originating Site Impact g IP-2 Ginna Q NUMARC-007 Q Procedure Q EAL Q JAF Q IP-3 Q Verification Q Training Q Hardware QTechnical Bases QValidation QDeviation QNone Q NMP-2 Q Generic BWR Q General site A licablllt" Q IP-2 Q NMP-1 Q Ginna 8 Generic PWR cat. System Malf. Ic¹ 2 No. 1 Emer. Glass. Genei'al Comment (Attachment 1 question 2.3): It is not clear how the condition "Functional restoration procedures ..."

was derived from either of the two referenced PEG EALs (FC1.1 and SG2.1). The basis needs to describe the correlation between the PEG and the TB EAL.

Re so lut ion PWR EAL TB 1 1.2 were revised to reference PC6.1 and PC6.2. PWR FPBEs were revised to show

~

PC6.1 and PC6.2 each as a General Emergency. PWR Binning document was revised to show PC6.1 and PC6.2 under subcategory 1.1.

s~a~us OOpen OResolved/Awaiting Disposition 0+Closed Record No 28 Date 9/20/93 Name M. C. DauS Originating Site Impact IP-2 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-3 Q EAL QTechnical Bases QValidation QDeviation QNone Ginna

" Q JAF Q IP-3 QI NMP-2 Q Generic BWR Q General Q IP-2 Q NMP-1 Q Ginna H Generic PWR cat.'ystem Malf. Ic¹ 2 No. 1 Emer. Class. GBRBral Comment (Attachment 1 question 2.3): It is not clear how the condition "Red path subcriticality ..." meets the PEG SG2.2.a requirement for an indication that core cooling is extremely challenged. "Red path subcriticality" seems to be an indication that automatic and manual xcram were not successful which is the condition for PEG SG2.1.

Resolution Revised all PWR PEGs to reflect F-0.2 CORE COOLING vs. F-0.1. Added CORE COOLING bases s~a~us 0 Open 0 Resolved/Awaiting Disposition Oe Closed

L Record No 30 Date 9/20/93 Name M. C. DauS Originating Site Impact g Ip-3 Ginna 0 NUMARC-007 0 Procedure 0 EAL 0 Verification 0 Training 0 Hardware 0 Technical Bases 0 Validation 0 Deviation Q None site A llcabilit" 0 JAF I:j 0 NMP-2 0 Generic BWR Q General IP-3 0 IP-2 0 NMP-1 Q Ginna 8 Generic PWR ca t. System Malf. Ic¹ 2 No. 1 Emer. Class. Alert Comment (Attachment 1 question 2.3): IP2/3 PEG EAL SA2.1 includes the condition " ... emergency boration is required" but it is not explained in the basis. IP2/3 EAL TB 1.5.1 appears to agree with the PEG EAL.

~aul~

REG PEG EAL SA2.1 lists Orange path criticality but does not include "emergency boration is Resolution gg gdPWRPEEEAIEA211 d"QESBQE~ ERIES

~Br.ALIIn @ ~rior Added to the basis reference to emergency boration status O Open O Resolved/Awaiting Disposition Oe Closed Record No 31 Date 9/20/93 Name M. C. DauS Originating Site Impact IP-3 0 NUMARC-007 0 Procedure 0 Verification 0 Training 0 Hardware IP-2 0 EAL 0 Technical Bases Q Validation Q Deviation 0 None Ginna site Applicability

" I I JAF I I IP-3 0 NMP-2 0 Generic BWR General I I Q IP-2 0NMP-1 0Ginna IHIGeneric PWR ca t. System Malf. Ic¹ 2 No. 1 Emer. Class. Site Area Comment (Attachment 1 question 2.3): IP2/3 PEG EAL SS2.1 does not include Red path Subcriticality as listed in IP2/3 EAL TB 1.5.2.

REG PEG EAL SS2.1 lists Red path Subcriticality but does not include "Emergency boration is inoperative OR Power range not < 5% within 15 min. of initiation of emergency boration" as does Resolution Revised all PWR PEGs to reflect TBs.

status O Open O Resolved/Awaiting Disposition Oe Closed

Record No. 32 Date 9/20/93 Name M. C. DauS Originating Site Impact Ginna Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-2 CI EAL CITechnical Bases QValidation QDeviation QNone IP-3 JAF Q IP-3 I NMP-2 Q Generic BWR Q General

" Q I QIP-2 QNMP-1 QGinna IHGenericPWR C¹ ** ** **

cat. Barrier I Emer. Class.

Comment (Attachment 1 question 2.3): PEG EAL FC2.1 lists activity in pCi/cc; TB EAL 2.1.2 lists activity in pCI/gm.

Resolution Changed EAL TB to pCi/cc to agree with PEG.

status 0 Open 0 Resolved/Awaiting Disposition Oe Closed Record No. 35 Date 9/20/93 Name M. C. DauS Originating Site Impact IP-3 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-2 CI EAL QTechnical Bases QValidation QDeviation QNone Ginna JAF QIP-3 QNMP-2 QGenericBWR HGeneral "QIP-2 QNMP-1 QGinna IHIGenericPWR cat. Abnorm. Rad. Ic¹ 2 No. 4 Emer. Class. UnuSual EVent Comment (Attachment 1 question 2.3): PEG EAL AU2.1 includes the statement "... with all irradiated fuel assemblies remaining covered by wateV'. TB 2.4.1/2.3.1 are missing this phrase.

Suggest adding to the EAL basis in the TB the reason it has been deleted.

Resolution Changed PEG EAL wording to agree with EAL TB wording and explained reason for deleting wording from the PEG in the PEG basis as follows: "The words "with all irradiated fuel assemblies remaining covered by water" were deleted as it is unecessary. AA2.2 requires declaration of an Alert if the fuel becomes uncovered."

senatus 0 Open 0 Resolved/Awaiting Disposition 0+ Closed

Record No 36 Date 9/20/93 Name M. C. Daus Orlglnatlng Site Impact y IP-3 Ginna C3 0

NUMARC-007 EAL 0 Procedure P Technical Bases C3 JAF 0 IP-3 0 Verification CI Validation I I NMP-2 0 CJ Training 0 Deviation Generic BWR I 0

C3

't Hardware None General "HIP-2 PNMP-1 CJGinna HGenericPWR C¹ ** ** **

cat. Barrier I Emer. Class.

Comment (Attachment 1 question 2.3): REG PEG EAL RCS2.2 requires declaration on "unisolable" leakage, the TB states "Primary system leakage ...".

IP2/3 PEG EAL RCS2.2 requires declaration on "known unisolable" leakage, the TB states "Primary system leakage ...".

Resolution Changed PEG EAL wording to agree with that of the EAL TB.

status 0 Open 0 Resolved/Awaiting Disposition 0 Closed Record No. 37 Date 9/20/93 Name M. C. Daus Orlglnatlng Site Impact IP-3 0 NUMARC-007 Q Procedure 0 Verification 0 Training C] Hardware IP-2 0 EAL H Technical Bases Q Validation 0 Deviation CJ None oJAF HIP-3 QNMP-2 QGenericBWR QGeneral

" 0 IP-2 0 NMP-1 CI Ginna g Generic PWR cat. Barrier I c¹ ** No. ** Emer. Class. **

Comment (Attachment 1 question 2.3): PEG EAL FC4.1 requires declaration on various combinations of RCPs running as well as no RCPs running. EAL 3.1.3 only states no RCPs running. The reason the EAL TB differs from the PEG is not explained. Suggest rewording the PEG EAL to agree with the EAL TB.

Resolution Changed PEG EAL wording to agree with that of the EAL TB.

status 0 Open 0 Resolved/Awaiting Disposition 0+ Closed

"l Record No. 41 Date 9/20/93 Name M. C. DauS orlglnatlng Site Impact Il tP-3 Ginna Q NUMARC-007 Q EAL Q Procedure QTechnical Bases Q Verification Q Training Q Hardware QValidation QDeviation QNone 8 IP-3 QI NMP-2 QI Generic BWR Q General 4 II b lilt" QI JAF H IP-2 Q NMP-1 H Ginna Q Generic PWR cat. Barrier IC¹ ** Emer. Class.

Comment (Attachment 1 5AI 44.5 t t 5 t I psig with less than one full train of containment spray operating". Which one is correct?

t2<<

question 2.3 and 2.6): IP2/3 PEG EAL PC2.5 states "agIII~EhmhimIluihnmmlnifhhu

>>25I28 REG PEG EAL PC2.5 states "Za~~aaahar~azay ~Sar Rgltarallttgaaaaa~tttarmmrtt2:Swig.

Resolution See resolution to PWR verification comment record 038.

status 0 Open 0 Resolved/Awaiting Disposition 0+ Closed Record No 42 Date 9/20/93 Name M. C. DauS Orlglnatlng Site Impact IP-3 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-2 Q EAL IHL Technical Bases Q Validation Q Deviation Q None Ginna Q JAF Q IP-3 Q NMP-2 Q Generic BWR QI General "QIP-2 QNMP-1 QGinna HGenericPWR cat. Barrier Ic¹ ** No. ** Emer. Class.

Comment (Attachment 1 question 2.3 and 2.6): IP2/3 PEG EAL FC3.2 states "Greater thaQcQ~ci~ Z{}o>'nd IP2/3 PEG EAL FC4.1 states "~Ltd 5giLLII}QfglllgflgQQRf3gg IR52 iJ3RQ 3R'la ElitlQQ, BEER

~rnntn ...". Why aren't these conditions represented in Table 4.2?

REG PEG EAL FC3.2 states Greater tha~t p ~ ZzZ" and FC4.1 states "~~~

Resolution The PEG conditions are subsets of the EAL TB Table 4.2 Core Cooling-ORANGE. Added to PEG basis a statement of the relationship of the conditions to the Core Cooling orange path.

status 0 Open 0 Resolved/Awaiting Disposition Oe Closed

II -

Record No. 43 9/20/93 Name M. C. Daus Originating Site Impact IP-3 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-2 Q EAL Q Technical Bases Q Validation Q Deviation Q None

" Q JAF QI IP-3 Q NMP-2 Q3 Generic BWR QI General Q IP-2 Q NMP-1 Q Ginna H Generic PWR c¹ ** No. **

• cat. Barrier I Emer. Class.

Comment (Attachment 1 question 2.3 and 2.6): IP2/3 TB EAL 4.2.1 references "E-3 "Steam Generator Tube Rupture"". IP2/3 PEG RCS3.2 does not mention this procedure, either as a reference or in the example EAL.

This procedure appears to be applicable to REG only.

Resolution PEG EAL RCS3.1 has been made consistent with the TBs so that the procedure E-3 is added.

PEG EAL RCS3.2 has been made consistent with the TBs so that the procedure E-3 is added with the wording related to the primary to secondary leak.

sta tus 0 Open 0 Resolved/Awaiting Disposition Oi Closed Record No. 44 Date 9/20/93 Name M. C. Daus Originating Site Impact IP-3 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-2 Q EAL Q Technical Bases Q Validation Q Deviation Q None Ginna Sit Appll billty" Q JAF H IP-3 Q NMP-2 Q Generic BWR Q General 8 IP-2 Q NMP-1 8 Ginna Q Generic PWR ca t. Barrier IC¹ ** N

• • Emer. Class.

Comment (Attachment 1 question 2.3): The first condition of EAL 4.2.2 should be formatted and phrased to be consistent with EAL 3.2.1 (i. e., delete "technical specifications allowable ...").

Re so I ut Ion Formatted first condition of 4.2.2 to be the same as 3.2.1.

status 0 Open 0 Resolved/Awaiting Disposition Oi Closed

Record No. 45 Da<<9/20/93 Name M. C. Daus Originating Site Impact IP-3 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-2 Q EAL Q Technical Bases Q Validation Q Deviation Q None JAF g IP-3 Q NMP-2 Q Gen<<ic BWR Q General

" Q g IP-2 Q NMP-1 Q Ginna Q Generic PWR cat. Abnorm. Rad. ic¹ 1 No. 1 Emer. class. Unusual Event Comment (Attachment 1 question 2.3): EAL 5.1.1 Table 5.1 NUE values in TB are not listed in PEG AU1.1.

IP2 /3 PEG lists 2xalarm, IP3 TB Table 5.1 lists "lateV'.

IP2 TB Table 5.1 lists rad monitors R27, 44, 54, 29: IP2 PEG lists rad monitors R27, 44, 48, 49. PEG should probably be changed to agree with TB.

Re so lut ion Changed PEG to agree with TB.

status 0 Open 0 Resolved/Awaiting Disposition OI Closed Record No. 46 Date 9/20/93 Name M. C. DauS Originating Site Impact IP-3 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-2 Q EAL Q Technical Bases Q Validation Q Deviation Q None Ginna JAF H IP-3 Q NMP-2 Q Generic BWR Q General "QH IP-2 Q NMP-1 Q Ginna Q Generic PWR cat. Abnorm. Rad. lc¹ 1 No. 1 Emer. Glass. Unusual Event Comment (Attachment 1 question 2.3): REG EAL 5.1.2 Table 5.1 Alert values are "later" instead of values listed in EAL AA1.1.

IP2 TB Table 5.1 lists rad monitors R27, 44, 54, 29: IP2 PEG lists rad monitors R27, 44, 48, 49. PEG should probably be changed to agree with TB.

Resolution Changed IP2/3 PEG to agree with TB.

Comment concerning REG needs to be checked.

status Oe Open 0 Resolved/Awaiting Disposition 0 Closed

Record No. 47 Date 9/20/93 Name M. C. Daus Originating Site Impact y IP-2 Q NUMARC-007 Q EAL Q Procedure QTechnical Bases JAF 8 IP-3 Q Verification Q Training Q Hardware QValidation QDeviation QNone Q NMP-2 Q Generic BWR Q General sit A il blilt"glP-2 QNMP-1 QGinna QGenericPWR ca t. Abnorm. Rad. IC¹ 1 No. 1 Emer. Class. UnuSual EVent Comment (Attachment 1 question 2.3): EAL 5.1.1 Table 5.1 SAE values in TB are not listed in PEG AS1.1.

IP2 TB Table 5.1 lists rad monitors R27, 44, 54, 29: IP2 PEG lists rad monitors R27, 44, 48, 49. PEG should probably be changed to agree with TB.

Resolution Changed PEG to agree with TB.

status OOpen 0 Resolved/Awaiting Disposition Oo Closed Record No. 48 Date 9/20/93 Name M. C. Daus Originating Site Impact IP-3 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware Ginna Q EAL QTechnical Bases QValidation Q Deviation Q None IP-2 "Q

JAF I IP-3 I Q NMP-2 I I Generic BWR E General Q IP-2 Q NMP-1 Q Ginna Q Generic PWR cat. System Malf. IC¹ 3 No. 1 Emer. Class. UnuSual EVent Comment (Attachment 1 question 2.3): IP3 EAL 7.3.1 does not include the PEG condition QQPJ25 are te available".

"QEI~ ~

IP2 EAL 7.3.1 does not include the PEG condition " ~ are m available".

Resolution Reference to these conditions are not needed in the TB EAL because escalation to the Alert level would be required if these conditions became applicable. A statement in the PEG basis for EAL SU3.1 has been added to explain this.

status 0 Open 0 Resolved/Awaiting Disposition Oi Closed

Record No 49 Date 9/20/93 Name M. C. DauS Orlglnatlng Site Impact IP-3 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-2 g EAL g Technical Bases Q Validation Q Deviation Q None Ginna "QQ JAF QI IP-3 Q NMP-2 QI Generic BWR 8 General IP-2 Q NMP-1 Q Ginna Q Generic PWR ca t. Hazards Ic¹ 3 No. 1 Emer. Class. UnuSual Event Comment (Attachment 1 question 2.3): PEG EAL and TB basis states that toxic gases that affect safe plant operation warrant emergency declaration. The EAL wording does not include safe operation; it only addresses personnel health.

Resolution Added the phrase "... safe plant operation" to the wording of the EAL TB and EAL matrices.

This comment is a NMP-1 validation comment as well ~

status 0 Open 0 Resolved/Awaiting Disposition Oi Closed Record No 50 Date 9/20/93 Name M. C. Daus Orlglnatlng Site Impact IP-3 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware Ginna Q EAL Q Technical Bases Q Validation Q Deviation Q None IP-2 Q JAF Q IP-3 QJ NMP-2 Q Generic BWR E General pp(l blllty

" Q IP-2 Q NMP-1 Q Ginna Q Generic PWR ca t. Hazards Ic¹ 3 No. 2 Emer. Class. Alert Comment (Attachment 1 question 2.3): IP2 PEG HA3.2 states "... i'~m~ ~I'll~~Kg ~

ig, effect the safe operation of the plant", EAL 8.3.5 states "impede access to plant vital areas". Why the difference?

IP3 PEG HA3.2 states "...

Resolution jmg~gg~@~Zg!alt~ ~ forefeet the safe operation of the Changed EAL from "... impede access to plant vital areas" to "... impede access to equipment needed for safe plant operation".

status 0 Open 0 Resolved/Awaiting Disposition 0 Closed

h I

Record No 51 Date 9/20/93 Name M. C. DaUS Originating Site Impact IP-3 0 NUMARC-007 0 Procedure 0 Verification 0 Training 0 Hardware Ginna 0 EAL 0 Technical Bases 0 Validation Q Deviation 0 None IP-2 "Q0 JAF lP-3 0 NMP-2 Generic BWR lal General I I I I IP-2 0 NMP-1 Q Ginna Q Generic PWR ca t. Barrier I C¹ ** No. ** Emer. Class. UnuSual EVent Comment (Attachment 1 question 2.6): PEG reference to PC6.1 in EAL 9.1.2 should be PC8.1.

Resolution Changed EAL TB PEG reference to PC8.1.

status 0 Open 0 Resolved/Awaiting Disposition O~ Closed Record No. 52 Date 9/20/93 Name M. C. DauS Originating Site Impact IP-3 0 NUMARC-007 0 Procedure 0 Verification 0 Training 0 Hardware Ginna 0 EAL Q Technical Bases 0 Validation 0 Deviation 0 None IP-2 sit A II blllt" 0 JAF 0 lP-3 0 NMP-2 0 Generic BWR H General Q IP-2 0 NMP-1 0Ginna QGeneric PWR ca t. Barrier Ic¹ ** No. ** Emer. Class. Alert Comment (Attachment 1 question 2.6): PEG reference to FC5.1 in EAL 9.1.4 should be FC7.1.

Resolution Changed EAL TB PEG reference to FC7.1 ~

status 0 Open 0 Resolved/Awaiting Disposition 0+ Closed

Record No. 53 Date 9/20/93 Name M. C. DauS Originating Site Impact IP-3 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware Ginna Q EAL H Technical Bases Q Validation Q Deviation Q None IP-2 "QQ JAF QI IP-3 Q NMP-2 Q Generic BWR 8 General IP-2 Q NMP-1 Q Ginna Q Generic PWR C¹ ** ** Alert ca t. Barrier I No. Emer. Class.

Comment (Attachment 1 question 2.6): PEG reference to HS3.1/HG2.1 in EAL 9.1.6/9.1.8 does not appear to be correct. Should it be FC7.1, RCS6.1 and PC8.1?

Resolution It be FC7.1, RCS6.1 and PC8.1 for PWRs and FC5.1, RCS6.1 and PC6.1. Corrected appropriate PEG references in category 9 of the PEGs. Also, corrected same EAL references in the PWR and BWR binning documents.

status 0 Open 0 Resolved/Awaiting Disposition OI Closed Record No. 54 Date 9/20/93 Name M. C. Daus Originating Site Impact IP-3 Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware IP-2 Q EAL Q Technical Bases Q Validation Q Deviation Q None Ginna

" Q JAF Q IP-3 Q NMP-2 Q Generic BWR gl General Q IP-2 Q NMP-1 Q Ginna Q Generic PWR ca t. Barrier Ic¹ ** No. ** Emer. Class. General Comment (Attachment 1 question 2.8): FPBE states RCS3.1-loss + ANY:

-FC1.2-pot loss

-FC1.3-pot loss

-FC2.1-loss

-FC3.2-pot loss Resolution Yes, this is represented by 4.2.2 butwas not adequately documented in TB and binning documents.

Revised all PWR TBs and binning documents.

status 0 Open 0 Resolved/Awaiting Disposition 0 Closed

OSSI 93-402A-10-IP2 IP-2 EAL Verification Bc VaBdation Report, Rev. 0 Attachment 3 EAL Validation Scenarios 3-1

OSSI 92-402A-7A-Ginna EAI Validation Procedure. Rev. 0 Attachment 2 VaHdation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: ~ Table-Top: 0 Scenario ¹1 Scenario Description(s):

Initial Conditions: Reactor power 100%, no equipment OOS.

With the plant at 100% power, loss of all main and auxiliary feed.

Reactor trip. ATWS w/ reactor power > 5% (SAE 1.5.1)

S/G levels all < 8 % w/ < 400 gpm flow (SAE 1.2.1) (GE 1.2.2),

Station and Unit Auxiliary transformers and 13.8 KV gas turbine fail when the generator trips (UE 6.1.1). EDGs start and energize vital busses, CETs > 700 'F (SAE 1,1.1).

CETs > 1200 'F (GE 1.1.2).

2-1

OSSI 92-402A-7A-Ginna EAL Validation Procedure, Rev. 0 Attachment 2 Validation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: ~ Table-Top: Q Scenario 8 2 Scenario Description(s):

Initial Conditions: Reactor power 100% for past 3 months, small steam leak from one turbine throttle valve, plant to shutdown tomorrow With the plant at 100% power and a small steam leak on turbine throttle valve, a dropped control rod results in fuel clad failure.

Reactor trip with failure of some control rod assemblies to insert. Reactor power - 1% (Alert 1.5.1). Containment radiation monitors R-25/R-26 reading 25 R/hr.

S/G tube leak of 80 gpm (Alert 3.1.2) (UE 3.2.1) (SAE 3.2.2) (GE 4.2.2)

ARM readings exceed 100 x alarm (UE 5.3.1). Turbine Building area radiation measured at 10 R/hr (Alert 5.3.3)

Offsite radioactivity release gradually increases to the General Emergency level (UE 5.1.1, Alert 5.1, 2, SAE 5.1.3, GE 5.1.4).

2-2

OSSI 92-402A-7A-Gonna EAL Validation Procedure, Rev. 0 Attachment 2 Validation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: 0 Table-Top: 0 Scenario ¹3 Scenario Description(s):

Initial Conditions: Reactor power 60%, return to power delayed with feedwater heater problems.

Earthquake is felt inplant and confirmation by Unit 3 (8.4.1).

Small LOCA into containment, unidentified leakage >10 gpm (UE 3.1.1).

Containment Radiation reading 25 R/hr (SAE 2.2.2).

Large LOCA resulting in containment pressure of 30 psig with failure of containment spray (GE 4.1.5). Failure of all containment recirc, fans (GE

4. 1.4),

Rapid unexplained drop in containment pressure (SAE 4.1.2) (GE 4.1.6).

2-3

OSSI 92-402A-7A-Ginna EAL Validation Procedure. Rev. 0 Attachment 2 Va1idation Exercise Scenario Checldist No.:

Plant: IP2 Simulator: ~ Table-Top: Q Scenario 8 4 Scenario Description(s):

Initial Conditions: Reactor power 100%, no equipment OOS.

S/G fault results in uncontrollled RCS cooldown (Alert 1.3.1).

S/G tube rupture (SAE 1.3.2) (SAE 4.2.1)

Failure of all SI. Loss of subcooling (Alert 3.3.1).

RVLIS drops < top of fuel (SAE 3.1.3).

2-4

QSSI 92-402A-7A-Glnna EAL Validation Procedure, Rev. 0 Attachment 2 VaHdation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: 5 Table-Top: 0 Scenario ¹5 Scenario Description(s):

Initial Conditions: Reactor power 100%.

LOCA inside containment with 100% ATWS. Containment pressure requiring entry into RED path F-0.5 CONTAINMENT (GE 1,4.1).

Failure of CVI which provides downstream pathway to the environment (SAE 4.1.3) (GE 4.1.7).

Emergency boration fails (SAE 1.5.2).

Containment radiation 100 R/hr (Alert 2.2,1) (SAE 2.2.2) (GE 2.2.3).

Containment hydrogen concentrations 6% (GE 4.3.1).

2-5

OSSI 92-402A-7A-Ginna EAL Validation Procedure. Rev. 0 Attachment 2 VaHdation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: ~ Table-Top: Cl Scenario 8 6 Scenario Description(s):

Initial Conditions: Reactor power 100%,

Loss of all offsite power (UE 6.1.1).

Failure of EDG 21 and 22 (Alert 6.1.3).

Numerous Control Room annunciator panels are de-energized for > 15 min.

(UE 7.3.1).

A reactor trip occurs (Alert 7.3.3) ~

Failure of EDG 23 (SAE 6.1.4). If plant had been in cold shutdown'? (Alert 6.1.2). If an emergency bus not restored within 1 hrV (GE 6.1.5).

Loss of all vital DC power for >15 min. (SAE 6.2,2) (SAE 7.3.4). If plant had been in cold shutdown'? (UE 6.2.1) 2-6

OSSI 92-402A-7A-Ginna EAL Validation Procedure, Rev. 0 Attachment 2 VaHdation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: 0 Table-Top: ~

Scenario ¹7 Scenario Description(s):

Reactor coolant samples indicate coolant activity of 90/E bar pCi/gm total specific activity. (UE 2.1.1)

Following reactor shutdown and depressurization, coolant samples are taken indicating 390 pCi/gm I-131 eq. (Alert 2.1.2) 2-7

OSSI 92-402A-7A-Ginna EAL Validation Procedure, Rev. 0 Attachment 2 VaHdation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: 0 Table-Top: ~

Scenario ¹8 Scenario Description(s):

The plant is operating at 100%. Both containment airlock doors are inadvertantly both opened and found unattended (UE 4,1.1).

2-8

OSSI 92-402A-7A-Ginna EAL Validation Procedure, Rev. 0 Attachment 2 Validation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: 0 Table-Top: 0 Scenario 8 9 Scenario Description(s):

A HP Technician performing routine surveys measures Control Room area radiation levels of 20 mR/hr (Alert5.3.2).

It is reported that an unshielded radiography source is in the Auxiliary Building. General area radiation levels in areas of the Auxiliary Building are approximately 20 R/hr (Alert 5.3.3).

2-9

OSSI 92-402A-7A-Ginna EAL Validation Procedure, Rev. 0 Attachment 2 Validation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: 0 Table-Top: ~

Scenario ¹ 10 Scenario Description(s):

Refueling operations are in progress and a major RCS leak causes the refueling cavity and SFP level to drop. The SFP low level alarm is recieved (UE 2,3.1),

A fuel bundle is raised on the grapple when the refuel floor is evacuated (Alert 2.3.3) (SAE 3.1.3).

The containment area radiation monitor R-2 go offscale high (Alert 2.3.2) 2-10

OSSI 92-402A-7A-Ginna EAL Validation Procedure, Rev. 0 Attachment 2 VaHdation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: 0 Table-Top: 8 Scenario 8 11 Scenario Description(s):

Chemistry reports Auxiliary Building vent effluent analysis indicates that effluents have been approximately 3 times Tech. Spec. allowed limits for the last 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (UE 5,2.1).

300 times Tech. Spec. for the last 20 minutes (Alert 5.2.2) 2-11

OSSI 92-402A-7A-Ginna EAL Validation Procedure. Rev. 0 Attachment 2 VaHdation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: 0 Table-Top: ~

Scenario 8 12 Scenario Description(s):

Field survey teams report whole body dose rates at the site boundary of 20 mR/hr (Alert 5.2.3).

200 mR/hr (SAE 5,2.4)

Dose projections indicate child thyroid doses of 7200 mR (GE 5.2.5) 2-12

OSSI 92-402A-7A-Ginna EAL Validation Procedure. Rev. 0 Attachment 2 Validation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: Q Table-Top: ~

Scenario 8 13 Scenario Description(s):

The plant has entered a 24 LCO action statement at 0700 due to EDG operability. At 1800 a plant shutdown is initiated. At 0700 the following day, coolant temperature is still 220 'F while attempting to initiate Residual Heat Removal (UE 7.1.1)

RHR cannot be established due to a valve failure. Reactor temperature cannot be reduced to 200 'F (Alert 7.2.3) 2-13

OSSI 92-402A-7A-Ginna EAL Validation Procedure, Rev. 0 Attachment 2 VaHdation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: 0 Table-Top: ~

Scenario 8 14 Scenario Description(s):

A tanker carrying ammonia gas overturns on the access road releasing ammonia gas. The plume crosses onto the site, incapacitating numerous site personnel (UE 8.3.3)

The gas then enters the control room requiring the control room to be evacuated (Alert 8.3.5) (Alert 7.2.2).

Control of core cooling is not acheived after 30 minutes (SAE 7.2.4).

2-14

OSSI 92-402A-7A-Glnna EAL Validation Procedure, Rev. 0 Attachment 2 VaHdation Exercise Scenario Checklist No.:

Plant; IP2 Simulator: 0 Table-Top: ~

Scenario 0 15 Scenario Description(s):

A severe storm causes a loss of all telephone systems offsite. No radios respond to attempts to call offsite (UE 7.3.2).

Meteorological tower stripchart indicate sustained wind speeds of 95 mph (Alert 8.4.6).

The roof is ripped off of the turbine building (Alert 8.4.7).

2-15

OSSI 92-402A-7A-Ginna EAL Validation Procedure, Rev. 0 Attachment 2 VaHdation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: CI Table-Top: ~

Scenario ¹ 16 Scenario Description(s):

A bomb threat is recieved. A search reveals a bomb in the Auxiliary Building at a remote shutdown panel (UE 8.1.1),

An unauthorized individual is recognized to have scaled the Protected Area fence (Alert 8.1.2).

The individual is tracked into the auxiliary building (SAE 8.1.3).

The bomb explodes destroying the remote shutdown panel (GE 8.1.4) (Alert 8.2.2).

Instead of the auxiliary building, a bomb explodes in the Administative Building(UE 8.3.2).

2-16

OSSI 92-402A-7A-Ginna EAL Validation Procedure, Rev. 0 Attachment 2 Validation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: Q Table-Top: ~

Scenario ¹ 17 Scenario Description(s):

The main turbine throws a blade which penetrates the turbine caseing (UE7.2.1) (UE 8.3.1).

The thrown blade richocets and breaks a seal oil line spraying oil and hydrogen into turbine building (Alert 8.3.4).

The spilled oil catches fire and burns out of control for 30 minutes destroying a vital power supply(UE 8.2.1) (UE 8.3.3) (Alert 7.2.2).

2-17

OSSI 92-402A-7A-Ginna EAL VaBdation Procedure, Rev. 0 Attachment 2 VaHdation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: Q Table-Top: ~

Scenario ¹ 18 Scenario Description(s):

The control room operators notice ground motion and recieve conformation of earthquake from Unit 3. Operators confirm the earthquake (UE 8.4.1).

It is determined that the earthquake was of magnitude 0.17g horizontal (Alert 8.4.5).

As a result of the earthquake the screenhouse building is destroyed (Alert 8.4.7).

2-18

OSSI 92-402A-7A-Gonna EAL Validation Procedure, Rev. 0 Attachment 2 Validation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: 0 Table-Top: ~

Scenario ¹ 19 Scenario Description(s):

A report to the control room states that a tornado has been sighted inside the security fence (UE 8.4.2).

An operator reports that he cannot get to the screenhouse because of wind and debris (8.4.3).

2-19

OSSI 92-402A-7A-Ginna EAL Validation Procedure, Rev. 0 Attachment 2 VaHdation Exercise Scenario Checklist No.:

Plant: IP2 Simulator: Cl Table-Top: ~

Scenario ¹ 20 Scenario Description(s):

River flooding has resulted in measured lake levels of (later] ft. (UE 8.4.4).

Frizzle ice formation has caused the intake structure level to drop to [later]

ft. (8.4.8).

2-20

OSSI 93-402A-10-IP2, IP-2 EAL Verification & Validation Report. Rev. 0 Attachment 4 EAL Validation S Sheets 4-1

OSSI 92-402A-7 3

EAL Validation Procedure, Rev. 0>

Attachment 1 VaHdation Suaxmaxy Sheet

/s /m/'PZ Plant:

QRGlC, It Validation Team Members: Qii ( ~

f ILL 5r.b 5 ~ ~6 I It'i 0 -AC C

5,c Ci- PC I c. 0 NG>> PCc I CH AC c.] C CzgOGg~

I >>

>>I Checklist No.: 'l it('I EAL Rev. No.: Checklist No.: ~3r EAL Rev. No.: I I I j

~EALN . Qlm nri N >> >> >>I I

z..l - 1 Q ii' z.> 'L Q Q I ) I I

>>>> Q Q-K 5 .'5

~>>

t Q Q 1 l Q o Q. ]Y Valid. performed and comments recorded: Validy. performed and comments recorded: I >>

.I.

Validation Team Leader Date Validation am Leader Date III Chccldist No.: Ivt "~>>I- EAL Rev. No.: Checklist No.: +s~t EAL Rev. No.: ~ >>

~I~g ~i s Q EL Q S Q S.Z--~ Q B- g /8 \

~ I Q Q 12 Q g l~ g 15 ~ >>

l Valid. performed and comments recorded: Valid@. performed and comments recorded: .

I t'l.>Ltd ~

4 4~7 ~ I I

Validation earn Leader Date VaBdation Team Leader Date j '

1 Cont::nuation Sheets Attached: I

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0; Attachment 1 VaHdation Suamaary Sheet lo!L Plant:

Validation Team Members: F - crit I

I I~

Checklist No.:

~EAL N ~lm EAL Rev. No.: C Checklist No.:

IL: i'> t~ EAL Rev. No.:

r I Q a /7 I

'r Q Q

Q Q 8 o Q /

Valid. performed and comments recorded: Valida. performed and comments recorded:

t)L g~(se/9g g. (~ Iqy I Validation Team Leader Date Validation Team Leader Date II r

Checklist No.: ~~li EAL Rev. No.: Checkhst No.: ~I9 vo EAL Rev. ",i No.:

j j r M e' IsLr s er ('

63 I Q ~ S I t' Q

Q EL 2 ~ 'j)(.

W.'4 l Q Q Q Valid. performed and comments recorded: Valida. performed and comments recorded: "

L(ti 9>

1 i

Validation Team Leader Date Validation Team Leader s'ate I'!

Continuation Sheets Attached: t) 1-2

(

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 1 VaHdation Sumxx ax@ Sheet Date Plant + 2-Validation Team Members: 5~ /me-1 IE

(,I r'i 4(

Checklist No.:

IL: I EAL Rev. No.: Checklist No:

IL: I

. I3 EAL Rev. No.: ~ st j

Q zl- Q g 2 c R9 Z.

t .~.l Q Q Z tE jl'I

~

.( Q Si lQ B E.

gj I

Q

~

Q l3 1 I

Valid. performed and comments recorded: Valida. performed and comments recorded: I

.(~t~) L~C~

Validation Team Leader Date Validation T Leader Date Checklist No.: ' 1 EAL Rev. No. Checklist No.: 3 II EAL Rev. No.:

SILE EI Q g9 Q Q ~ -L Q Q Q Q g ~ ~

Q Q Kl Valid. perfo d and comments recorded: Valida. performed and comments recorded:

1 I( .(EE Lcisr Ig) I l Validation earn Leader Date Validation Team Leader Date E'ontinuation Sheets Attached: jl I;I 1-3

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 1 VaHdation Smnxmuy Sheet Plant: > P2-Validation Team Members: Gi<<5e ~~

YS I l t- D U /2 oH'5 nL 5~ cM c eve~

2. tC-M 48%rN C(+4gLtC L,(m Qglg gg'Q, CheCkllet NO.: ~t EAL Rey. NO.: ~ 3ac.Y @Ange Cheokliaf NO.: ~S ts EAL ReV. NO.:

~EAL N, Qlm T-T enari N S = ~

Q gl 4 .) ~ s Q Q E9

~ . Q Q 6 l,hQ d,.l Q

Valid. performed and comments recorded:

Validation Team Leader Date Iles Q 8 Valida, performed and comments recorded:

VaBdation Team Leader Date Checklist No.:

Nl 5 EAL Rev. No.: Checklist No.: +~ EAL Rev. No.: ~

Q 5 Q liQ Q Q Q g-Z. Q Q 5 Q Z 2-~Q Q Q

~ 'z-3 Q (.z. t Valid. performed and comments recorded: Valfda. performed and comments recorded:

N Validation Team Leader Date Validation earn Leader Date Continuation Sheets Attached:

1-4

OSSI 93-402A-10-IP2 IP-2 EAI Verification & Validation Report, Rev. 0 Attachment 5 EAL Validation Exercise Checklists 5-1

QSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise Checklist Date: 10 20 93 Checklist No.: 1 Yes ~N ~NA

1. When the need for classification was initially recognized, were the EALs easily accessible to the user' ~ Q Q Comments: Len th of wallchart could make EALs at bottom of chart hard to read. side-b -side la out and com are with vertical la out.

2. Where plant conditions required emergency classification, did the format and layout of the EALs support easy and rapid classification recognition'? Q ~ Q Comments: On the matrix GE to be ut on left NUE on ri ht so eo le will tend to read GEs first. Consider makin borders or otherwi e rovidin better association of tables with their res ective EALs.

3. Was classification of any conditions ~no requiring emergency classification avoided' 5 Q Q Comments: None.

3-1

OSSI 92-402A-7 EAL VaBdatfon Procedure, Rev. 0 Attachment 3 VaHdation Exercise ChechHst Date: 10 20 9 Checldist No.: 1 Yes No ~NA

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classification efforts' 0 8 0 Comments: Consider eneratin a matrix and or f h ti d .~lych the CSFST subcate pries in the order in which the a ar rocedurall sub criticali bein first .

5. Where plant conditions required emergency classification, was the operating mode applicability of the EALs clearly recognized' ~ 0 Q Comments: None.

6, Did the EALs and required Emergency'lan procedures interface properly' a o ~

Comments: None.

7. After initial classification, did subsequent classification escalation follow a logical progression in the EALs when appropriate' ~ CI 0 Comments: None.

3-2

VI OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise ChechHst Date: 10 20 93 Checklist No.: 1 Yes No ~NA

8. Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate' 0 0 Comments: None.

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs'? a u r Comments: None.

10. Are the EALs devoid of any misleading or incorrect information' o ~ o Comments: 6.1.1 should be loss or ower to Station Service Transformers instead of Station Transform r .

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs'? ~ C3 C3 Comments: None 3-3

Wl tg

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise CheckHst Date: 10 20 93 Checklist No.: 1 Yes No ~NA

12. Did the EALs have adequate detail to be effectively evaluated' ~ Q Q Comments: ~Non .

13. Are the EALs devoid of excessive detail' 5 Q Q Comments: None.

14. Did the EAL identification scheme adequately support location of the EAL condition within the classification procedure' ~ Q Q Comments: None.

15. Additional Comments: For the a ext-base format consider makin one in which one cate o would be on a a e.

3-4

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Validation Exercise ChecMist Date: 10 20 93 Checklist No.: 2 Yes No ~NA

l. When the need for classiQcation was initially recognized, were the EALs easily accessible to the user' ~ Q Q Comments: None.

2. Where plant conditions required emergency classification, did the format and layout of the EALs support easy and rapid classification recognition' Comments: None.

3. Was classification of any conditions not requiring emergency classiQcation avoided' ~" Q Q Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classiQcation efforts' ~ Q Q Comments: None.

5. Where plant conditions required emergency classiQcation, was the operating mode applicability of the $ MLs clearly recognized'? ~ Q Q 3-1

1 OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise CheckHst Date: 10 20 93 Checklist No.: 2 Y~e No ~NA Comments: None.

6, Did the EALs and required Emergency Plan procedures interface properly'? 8 Q Q Comments: None.

7. After initial classification, did subsequent classification escalation follow a logical progression in the EALs when appropriate'? ~ Q Q Comments: None.

8, Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate? ~ Q Q Comments: ~Non .

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs'?

Comments: None.

3-2

OSSI 92-402A-7 EAL VaBdation Procedure, Rev. 0 Attachment 3 Validation Exercise Checklist Date: 10 20 93 Checklist No.: 2 Y~s No ~NA

10. Are the EALs devoid of any misleading or incorrect information' r a Comments: Remove VC from Table 5..

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs'? ~ a a Comments: None.

12. Did the EALs have adequate detail to be effectively evaluated' a a Comments: None.

13. Are the EALs devoid of excessive detail' r a a Comments: ~Non .

14. Did the EAL identification scheme adequately support location of the EAL condition within the classiQcation procedure' a a r Comments: None.

15. Additional Comments:

3-3

th I

II y<,

A

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise ChecRHst Date: 10 20 93. Checklist No.: 3 Y~s No ~NA

1. When the need for classiQcation was initially recognized, were the EALs easily accessible to the user' Q Q ~

Comments: None.

2. Where plant conditions required emergency classiQcation, did the format and layout of the EALs support easy and rapid classification recognition' r Q Q Comments:

3. Was classiAcation of any conditions not requiring emergency classiQcation avoided' W Q Q Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classification efforts' Q S Q Comments: Need to look at 4.1.4 from a human factors stand oin t v ri that the condition can be readil tied to its subcat o 3-1

l u

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise CheckHst Date: 10 20 93 Checklist No.: 3 Yes ~N ~NA

5. Where plant conditions required emergency classification, was the operating mode applicability of the EALs clearly recognized' Q W Q Comments: Consider combinin mode 1 and mode 2 in the tables into one mode. And modes 3 and 4. Confer with IP-3.

6. Did the EALs and required Emergency Plan procedures interface properly' Q Q ~

Comments: None.

7. After initial classiQcation, did subsequent classification escalation follow a logical progression in the EALs when appropriate' ~ Q Q Comments: ~Non .

8. Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate'? ~ Q Q Comments: ~Nni.

3-2

lg 1

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise Checklist Date: 10 20 93 Checklist No.: 3 Yes No ~NA 9 Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs? Q Q ~

Comments: None.

10. Are the EALs devoid of any misleading or incorrect information'? Q ~ Q Comments: For 4.1.2 4.1.5: The term "unex e t d" should be re laced with "uncontrolled."

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs? ~ Q Q Comments: None

12. Did the EALs have adequate detail to be effectively evaluated? 8 Q Q Comments: None

13. Are the EALs devoid of excessive detail' ~ Q Q Comments: None.

3-3

V C ~

OSSI 92-402A-7 EAL VaBdation Procedure, Rev. 0 Attachment 3 VaHdation Exercise CheckHst Date: 10 20 93 Checklist No.: 3 Yes ~N ~NA

14. Did the EAL identification scheme adequately support location of the EAL condition within the classification procedure'P a a o Comments: None.

15. Additional Comments: ~Non 3-4

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Va1Mation Exercise ChechHst Date: 10 20 93 Checklist No.; 4 Yes No ~NA

1. When the need for classiQcation was initially recognized, were the EALs easily accessible to the user' ~ Cl 0 Comments: None.

2. Where plant conditions required emergency classification, did the format and layout of the EALs support easy and rapid classiQcation recognitionV Comments: None.

3. Was classiQcation of any conditions not requiring emergency classification avoided' 5 CI CI Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classification efforts' 0 5 Cl Comments: Subcate o 7.2: Consider retitlin

~ft as "S stem Failures" ecaus the turbine is not 3-1

OSSI 92-402A-7 EAL Va11dation Procedure, Rev. 0 Attachment 3 VaHdation Exercise ChecRHst Date: 10 20 93. Checklist No.: 4 Y~s ~N ~NA 5, Where plant conditions required emergency classification, was the operating mode applicability of the EALs clearly recognized' ~ Q Q Comments: None.

6. Did the EALs and required Emergency Plan procedures interface properly' 5 Q Q Comments: None.

7. After initial classification, did subsequent classification escalation follow a logical progression in the EMs when appropriate' ~ Q Q Comments: None.

8. Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate' 5 Q Q Comments: None.

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs'? Q Q Comments: None.

3-2

OSSI 92-402A-7 EAL ValldatIon Procedure, Rev. 0 Attachment 3 VaHdation Exercise CheckHst Date: 10 20 93 Checklist No.: 4 Yes No ~NA

10. Are the EALs devoid of any misleading or incorrect information' ~ Q Q Comments: None.

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs'? ~ Q Q Comments: None.

12. Did the EALs have adequate detail to be effectively evaluated' 5 Q Q Comments: None.

13. Are the EALs devoid of excessive detail' 0 Q Q Comments: ~Nne.

14. Did the EAL identification scheme adequately support location of the EAL condition within the classiQcation procedure' ~ Q Q Comments: None.

15. Additional Comments: None.

3-3

iJ Ki

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise CheckHst Date: 10 20 93 Checklist No.: 5 Yes No ~NA

1. When the need for classification was initially r a'a recognized, were the EALs easily accessible to the user' Comments: None.

2. Where plant conditions required emergency classification, did the format and layout of the EALs support easy and rapid classification recognition' ~ a a Comments: None.

3. Was classification of any conditions not requiring emergency classification avoided? r a a Comments; None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classiQcation efforts? a ~ a Comments: None 3-1

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Validation Exercise CheckHst Date: 10 20 93 Checklist No.: 5 Yes No ~NA

5. Where plant conditions required emergency classiQcation, was the operating mode applicability of the EALs clearly recognized' ~ Q Q Comments: None.

6. Did the EALs and required Emergency Plan procedures interface properly' Q 8 Comments: None.

7. After initial classification, did subsequent classification escalation follow a logical progression in the EALs when appropriate' ~ Q Q Comments: None.

8. Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate' ~ Q Q Comments: None.

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALL Q Q ~

Comments: None.

3-2

4

~$

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Validation Exercise ChecMist Date: 10 20 93 Checklist No.: 5 Yes ~N ~NA

10. Are the EALs devoid of any misleading or incorrect information' ~ Q Q Comments: ~Non .

11. Did the'EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the &K@'? ~ Q Q Comments: None.

12. Did the EALs have adequate detail to be effectively evaluated' S Q Q Comments: None.

13. Are the EALs devoid of excessive detail' ~ Q Q Comments: None.

14. Did the EAL identification scheme adequately support location of the EAL condition within the classiQcation procedure' ~ Q Q Comments:

15. Additional Comments: None.

3-3

V

'll

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Validation Exercise Checklist Date: 10 20 93. Checklist No.: 6 Yes No ~NA

1. When the need for classiQcation was initially recognized, were the EALs easily accessible to the user' ~ Q Q Comments: None.

2. Where plant conditions required emergency classiQcation, did the format and layout of the EALs support easy and rapid classiQcation recognition' ~ Q Q Comments: ~Non .

3. Was classiQcation of any conditions ~no requiring emergency classiQcation avoided' ~ Q Q Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classification efforts' 5 Q Q Comments: None.

3-1

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise CheckHst Date: 10 20 93 Checklist No.: 6 Yes No ~NA

5. Where plant conditions required emergency classiQcation, was the operating mode applicability of the les clearly recognizedV ~ Q Q Comments: None.

6. Did the EALs and required Emergency Plan procedures interface properly' Q ~

Comments: None.

7. After initial classification, did subsequent classification escalation follow a logical progression in the EAL's when appropriate' ~ Q Q Comments: None.

8. Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate? ~ Q Q Comments: None.

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs'? Q Q ~

Comments None.

3-2

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Validation Exercise Checklist Date: 10 20 93 Checldist No.: 6 Y~s No ~NA 10, Are the EALs devoid of any misleading or incorrect information' Q Q Comments; None.

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs'? ~ Q Q Comments: None.

12. Did the EALs have adequate detail to be effectively evaluated' W Q Q Comments: None.

13. Are the EALs devoid of excessive detail' r Q Q Comments: ~Non .

14. Did the EAL identification scheme adequately support location of the EAL condition within the classification procedure? ~ Q Q Comments: None.

15. Additional Comments: ~Nn~

3-3

~1 OSSI 92-402A-7 EAL VaIIdation Procedure, Rev. 0 Attachment 3 Validation Exercise Checklist Date: 10 20 93 Checklist No.: 7 Yes No ~NA

1. When the need for classification was initially recognized, were the EALs easily accessible to the user' ~ Q Q Comments: None.

2. Where plant conditions required emergency classification, did the format and layout of the EALs support easy and rapid classification recognition' Q ~ Q Comments: On the text-ba ed EALs th re shoul be some wa of distin uishin etween ate pries.

Hard to find one number amidst the eneral clutter. This is actuall more of a eneral comment. Consider the com uter-based table con e t f r cess to information.

3. Was classification of any conditions ~no requiring emergency classification avoided' ~ Q Q Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classification efforts' Comments: None.

3-1

OSSI 92-402A-7 EAL VaIIdation Procedure, Rev. 0 Attachment 3 VaiMation Exercise Checklist 10 20 93 Checklist No.: 7 Yes No ~NA

5. Where plant conditions required emergency classiQcation, was the operating mode applicability of the EMa clearly recognized'? ~ 0 0 Comments: None.

6. Did the EALs and required Emergency Plan procedures interface properly' Comments: None.

7. After initial classification, did subsequent classification escalation follow a logical progression in the EALs when appropriate' r o o Comments: None.

8. Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate' 5 0 0 Comments: None.

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs'P o a ~

Comments: None.

3-2

'WJ OSSI 92-402A-7 EAL ValldatIon Procedure, Rev. 0 Attachment 3 Validation Exercise ChechHst Date: 10 20 93 Checklist No.: 7 Yes No ~NA

10. Are the EALs devoid of any misleading or incorrect information' ~ Q Q Comments: None.

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs'? ~ Q Q Comments: None.

12. Did the EALs have adequate detail to be effectively evaluated' ~ Q Q Comments: None.

13. Are the EALs devoid of excessive detail' ~ Q Q Comments: ~Nn~

14. Did the EAL identification scheme adequately support location of the EAL condition within the classification procedure' ~ Q Q Comments: None.

15. Additional Comments: None.

3-3

4

/T lg

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise CheckHst Date: 10 20 93 Checklist No.: 8 Yes No ~NA

1. When the need for classification was initially recognized, were the EALs easily accessible to the user' Comments: None.

2. Where plant conditions required emergency classification, did the format and layout of the EALs support easy and rapid classification recognition' o r o Comments: On the matrix Item 3.2 alert: Nee to make a note: "3.1.2 a lies."

3. Was classification of any conditions not requiring emergency classification avoided' r o o Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classification efforts' ~ o o Comments: None.

3-1

k>

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Va1Mation Exercise CheckHst Date: 10 20 93 Checklist No.: 8 Y~s ~N ~NA

5. Where plant conditions required emergency classification, was the operating mode applicability of the EALs clearly recognized' Q ~ Q Comments: It m 3.1.3 on the site ar emer en I RVLIS >39%: should be s li into two EALs a ed on mode.

6. Did the EALs and required Emergency Plan procedures interface properly' Q Q ~

Comments: None.

7. After initial classiQcation, did subsequent classification escalation follow a logical progression in the EALs when appropriate' ~ Q Q Comments: None.

8. Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate' Q S Q Comments: Add events other than both airlock d rs o en th loss of containmen inte ri NUE 4.1.1 i.e. loss of bili to isola e ontainm nt r ssure relief valves or ur e valves and there is a radiolo ical release ath.

3-2

\

[

ld

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise CheckHst Date: 10 20 93 Checklist No.: ~

Yes No ~NA

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs'? 0 0 ~

Comments: None.

10. Are the EALs devoid of any misleading or incorrect information' r a o Comments: None.

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs'? 5 Cl 0 Comments: ~Non .

12. Did the EALs have adequate detail to be effectively evaluated' ~ a a Comments: None.

13. Are the EALs devoid of excessive detail' 0 CI Comments: None.

3-3

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Validation Exercise ChecRHst Date: 10 20 93 Checklist No.: 8 Y~e ~N ~NA

14. Did the EAL identification scheme adequately support location of the EAL condition within the classification procedures 0 0 ~

Comments:

15. Addtttonsl Comments: ~Nne.

3-4

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Validation Exercise ChecMist Date: 10 20 93. Checklist No.: 9 Y~s No ~NA

1. When the need for classiQcation was initially recognized, were the EALs easily accessible to the user' 5 Q Q Comments: None.

2. Where plant conditions required emergency classification, did the format and layout of the EALs support easy and rapid classiQcation recognition' ~ Q Q Comments: None.

3. Was classification of any conditions not requiring emergency classification avoided' Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classiQcation efforts' ~ Q Q Comments: None.

3-1

Ip h

Qjl 4'

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise CheckHst Date: 10 20 93 Checklist No,: 9 Yes No ~NA 5, Where plant conditions required emergency classification, was the operating mode applicability of the EALs clearly recognizedV 5 Q Q Comments: None.

6. Did the EALs and required Emergency Plan procedures interface properly' Q Q ~

Comments: None.

7. After initial classification, did subsequent classiQcation escalation follow a logical progression in the EMa when appropriate' 8 Q Q Comments: None.

8. Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate' Comments: None.

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs'? Q Q a Comments: None.

3-2

4 p La

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise CheckHst Date 10 20 93 Checklist No.: 9 Yes No ~NA

10. Are the EALs devoid of any misleading or incorrect information' a o o Comments: None.

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs'? ~ 0 Cl Comments: None.

12. Did the EALs have adequate detail to be effectively evaluated' ~ 0 0 Comments: None.

13. Are the EALs devoid of excessive detail' ~ 0 0 Comments: None.

14. Did the EAL identification scheme adequately support location of the EAL condition within the classiAcation procedure' 0 Q ~

Comments: None.

15. Additional Comments: ~Non .

3-3

ib 4e 4

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Validation Exercise ChechHst Date: 10 20 93 Checklist No.: 10 Yes No ~NA

1. When the need for classification was initially recognized, were the EALs easily accessible to the user'? ~ Q Q Comments: None.

2. Where plant conditions required emergency classification, did the format and layout of the EALs support easy and rapid classiQcation recognition' ~ Q Q Comments: None.

3. Was classification of any conditions ~no requiring emergency classification avoided' 5 Q Q Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classification eQ'orts'?

Comments: None.

3-1

41

\Of

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Validation Exercise Checklist Date: 10 20 93 Checklist No.: 10 Yes No ~NA

5. Where plant conditions required emergency classification, was the operating mode applicability of the EALs clearly recognized' Comments: None.

6. Did the EALs and required Emergency Plan procedures interface properly' Q Q ~

Comments: None.

7. After initial classification, did subsequent classification escalation follow a logical progression in the EALs when appropriate' ~ Q Q Comments: None.

8. Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate'? 8 Q Q Comments: None.

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs'? Q Q ~

Comments: ~Non .

3-2

J~

iY

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Validation Exercise Checklist Date: 10 20 93 Checklist No.: 10 Yes No ~NA 10, Are the EALs devoid of any misleading or incorrect information?- ~ Q Q Comments: None.

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs'? Q ~ Q Comments: SAE 3.1.3 should define the core lane as the level involved.

12. Did the EALs have adequate detail to be effectively evaluated' Q Q Comments: ~Non

13. Are the EALs devoid of excessive detail' ~ Q Q Comments: None.

14. Did the EAL identification scheme adequately support location of the EAL condition within the classification procedure? Q Q ~

Comments: None.

15. Additional Comments: None.

3-3

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise Checklist Date: 10 20 93 Checklist No.: 11 Yes No ~NA

1. When the need for classiQcation was initially recognized, were the EALs easily accessible to the user' ~ Q Q Comments: None.

2. Where plant conditions required emergency classiQcation, did the format and layout of the EALs support easy and rapid classification recognition' ~ Q Q Comments: None.

3. Was classification of any conditions not requiring emergency classification avoided' ~ Q Q Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classification efforts' Comments: For subcate o 5.2: Add some reference to release rates.

3-1

ta ldt

OSSI 92-402A-7 EAL VaBdation Procedure, Rev. 0 Attachment 3 VaHdation Exercise Checklist Date: 10 20 93 Checklist No.: 11 Yes No ~NA

5. Where plant conditions required emergency classification, was the operating mode applicability of the EALs clearly recognized' r Q Q Comments; None.

6. Did the EALs and required Emergency Plan procedures interface properly'? Q Q ~

Comments: None.

7, After initial classification, did subsequent classification escalation follow a logical progression in the EALs when appropriate' ~ Q Q Comments; None.

8. Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate' S Q Q Comments: None.

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs'? Q Q Comments: None.

3-2

jt to

'%C

OSSI 92-402A-7 EAL Validation Procedure. Rev. 0 Attachment 3 Validation Exercise CheckHst Date: 10 20 93 Checklist No.: 11 Yes No ~NA

10. Are the EALs devoid of any misleading or incorrect information' ~ Q Q Comments: None.

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs'? ~ Q Q Comments: None.

12. Did the EALs have adequate detail to be effectively evaluated'?

Comments: None.

13. Are the EALs devoid of excessive detail' ~ Q Q Comments: None.

14. Did the EAL identification scheme adequately support location of the EAL condition within the classiQcation procedures Q Q ~

Comments: None.

15. Additional Comments: .3.1: Add: "r sultin from an uncontrolled rocess."

3-3

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Validation Exercise Checklist Date: 10 20 93 Checklist No.: 12 Yes No ~NA

1. When the need for classification was initially recognized, were the EALs easily accessible to the users ~ Q Q Comments: None.

2. Where plant conditions required emergency classification, did the format and layout of the EALs support easy and rapid classification recognitionV 8 Q Q Comments: ~Non .

3. Was classification of any conditions not requiring emergency classification avoided' ~ Q Q Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classification efforts' Comments: None.

3-1

,l

\ jE

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise Checklist Date: 10 20 93 Checklist No.: 12 Yes No ~NA

5. Where plant conditions required emergency classification, was the operating mode applicability of the EALs clearly recognizedY ~ Q Q Comments: None.

6. Did the EALs and required Emergency Plan procedures interface properly' Q Q ~

Comments: None.

7. After initial classification, did subsequent classification escalation follow a logical progression in the F~ when appropriate' ~ Q Q Comments: None.

8. Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate' 5 Q Q Comments: None.

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs'? Q Q ~

Comments: None.

3-2

t J

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise ChecMst Date: 10 20 93 Checldiet No.: 12 Yes No ~NA

10. Are the EALs devoid of any misleading or incorrect information' ~ Q Q Comments: None.

11, Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs'? ~ Cl Cl Comments: None.

12. Did the EALs have adequate detail to be effectively evaluated' E Q Cl Comments: None.

13. Are the EALs devoid of excessive detail' ~ Q Q Comments: None.

14. Did the EAL identification scheme adequately support location of the EAL condition within the classification procedure' Q Q ~

Comments: None.

15. Additional Comments: None.

3-3

i 4 OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise ChecMst Date: 10 20 93 Checklist No.: 13 Yes No ~NA

1. When the need for classification was initially recognized, were the EALs easily accessible to the user' S Q Q Comments: None.

2. Where plant conditions required emergency classification, did the format and layout of the EALs support easy and rapid classification recognition' ~ Q Q Comments: None.

3. Was classiQcation of any conditions not requiring emergency classification avoided' 5 Q Q Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classiQcation efforts Comments; None.

3-1

I I g

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise CheckHst Date: 10 20 93 Checklist No.: 13 Yes No ~NA

5. Where plant conditions required emergency classification, was the operating mode applicability of the EALs clearly recognized' ~ Q Q Comments: None 6, Did the EALs and required Emergency Plan procedures interface properly' Q Q 5 Comments: None.

7. After initial classification, did subsequent classification escalation follow a logical progression in the EALs when appropriate' 8 Q Q Comments: None.

8. Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate' ~ Q Q Comments: None.

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs'? Q Q ~

Comments: None.

3-2

'1 1+f 1I"

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise Checklist Date: 10 20 93 Checklist No.: 13 Y~s No ~NA

10. Are the EALs devoid of any misleading or incorrect information' ~ Q Q Comments: None.

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs'? 0 Q Q Comments: None.

12. Did the EALs have adequate detail to be effectively evaluated' ~ Q Q Comments: None.

13. Are the EALs devoid of excessive detail' ~ Q Q Comments: None.

14. Did the EAL identification scheme adequately support location of the EAL condition within the classification procedure' Q Q ~

.Comments: None.

15. Additional Comments: None 3-3

fl l f4,

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise Checklist Date: 10 20 93. Checklist No.: 14 Yes ~N ~NA

1. When the need for classiQcation was initially recognized, were the EALs easily accessible to the user' 5 Q Q Comments: None.

2. Where plant conditions required emergency classiQcation, did the format and layout of the EALs support easy and rapid classiQcation recognition' ~ Q Q Comments: None.

3. Was classiQcation of any conditions not requiring emergency classification avoided? r Q Q Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classiQcation efforts' Comments: None 3-1

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise ChecRHst Date: 10 20 93 Checklist No.: 14 Yes No ~NA 5, Where plant conditions required emergency classification, was the operating mode applicability of the EALs clearly recognized' ~ Q Q Comments: None.

6. Did the EALs and required Emergency Plan procedures interface properly' Q ~

Comments: None.

7. After initial classification, did subsequent classification escalation follow a logical progression in the EALs when appropriate' 5 Q Q Comments: None.

8, Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate'? ~ Q Q Comments: None.

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs'? Q Q ~

Comments: None.

3-2

z OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Validation Exercise Checklist Date: 10 20 93 Checldist No.: 14 Yes No ~NA

10. Are the EALs devoid of any misleading or incorrect information' Q Q Comments: None.

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALsV ~ Q Q Comments: None.

12. Did the EALs have adequate detail to be effectively evaluated? ~ Q Q Comments: None.

13, Are the EALs devoid of excessive detail' Comments: None.

14. Did the EAL identification scheme adequately support location of the EAL condition within the classiAcation procedure' Q Q ~

Comments: ~Non .

15. Additional Comments: None.

3-3

~

y.

t"

OSSI 92-402A-7 EAI- Validation Procedure, Rev. 0 Attachment 3 VaJMation Exercise CheckHst Date: 10 20 93 CheckBst No.: 15 Y~s No ~NA

1. When the need for classiQcation was initially recognized, were the EALs easily accessible to the user' ~ Q Q Comments: None.

2. Where plant conditions required emergency classification, did the format and layout of the EALs support easy and rapid classification recognition'? Q ~ Q Comments: 8.4.7: Need some kind of mechanism to tie the tabl s to the EALs that reference them

3. Was classification of any conditions not requiring emergency classification avoided' ~ Q Q Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classiQcation efforts' Q ~ Q Comments: Chan e subcate o 8.2 to include ex losion as well as fire.

3-1

OSSI 92-402A-7 EAL Va11dation Procedure, Rev. 0 Attachment 3 Validation Exercise CheckHst Date: 10 20 93 Checldist No.: 15 Yes No ~NA 5, Where plant conditions required emergency classification, was the operating mode applicability of the EALs clearly recognized'? ~ Q Q Comments: None.

6. Did the EALs and required Emergency Plan procedures interface properl+ Q Q ~

Comments: None.

7. After initial classification, did subsequent classification escalation follow a logical progression in the EALs when appropriate' a Q Q Comments: None.

8. Did the EPLs support escalation of emergency classification when plant conditions indicated that escalation was appropriate' 0 Q Q Comments: None.

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs'? Q Q ~

Comments: None.

3-2

OSSI 92-402A-7 EAL Validation Frocedure, Rev. 0 Attachment 3 Validation Exercise CheckHst Date: 10 20 93 Checklist No.: 15 Y~ No ~NA

10. Are the EALs devoid of any misleading or incorrect information' ~ o o Comments: None.

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs'? ~ o o Comments: None.

12. Did the EALs have adequate detail to be effectively evaluated' ~ o o Comments: None.

13. Are the EALs devoid of excessive detail' ~ o o Comments; None.

14. Did the EAL identification scheme adequately support location of the EAL condition within the classification procedure' o o r Comments: None.

15. Additional Comments: None.

3-3

'lc OSSI 92-402A-7 EAI- Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise CheckHst Date: 10 20 93 Checklist No.: 16 Yes No ~NA

1. When the need for classification was initially recognized, were the EALs easily accessible to the user' ~ Q Q Comments: None.

2. Where plant conditions required emergency classiQcation, did the format and layout of the EALs support easy and rapid classification recognition' ~ Q Q Comments: None.

3. Was classification of any conditions ~no requiring emergency classification avoided' ~ Q Q Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classiQcation efforts' ttt Comments: 8.3.2 would better be located under 8.2.

3-1

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Validation Exercise Checklist Date: 10 20 93 Checklist No.: 16 Yes No ~NA

5. Where plant conditions required emergency classification, was the operating mode applicability of the EALs clearly recognized' ~ Q 0 Comments: None

6. Did the EALs and required Emergency Plan procedures interface properly' Comments: None.

7. After initial classification, did subsequent classification escalation follow a logical progression in the EALs when appropriate' ~ 0 Q Comments: None.

8. Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate' Comments: None.

3-2

OSSI 92-402A-7 EAL ValidatIon Procedure. Rev. 0 Attachment 3 Validation Exercise Checklist Date: 10 20 93 Checklist No.: 16 Yes No ~NA 9, Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs'? Q Q ~

Comments: None.

10. Are the EALs devoid of any misleading or incorrect information' Q ~ Q Comments: 8.2.2: Eliminate the word "an " and make it" lant areas t bl 8.2..."

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs'? ~ Q Q Comments: ~Non .

12. Did the EALs have adequate detail to be effectively evaluated' ~ Q Q Comments:

13. Are the EALs devoid of excessive detail' ~ Q Q Comments: ~Non .

3-3

fg OSSI 92-402A-7 EAI Validatfon Procedure, Rev. 0 Attachment 3 VaHdation Exercise Checklist Date: 10 20 93 Checklist No.: 16 Yes No ~NA

14. Did the EAL identification scheme adequately support location of the EAL condition within the classification procedure' 0 0 ~

Comments: None.

15. Additional Comments: None.

3-4

OSSI 92-402A-7 EAI- Va11dation Procedure. Rev. 0 Attachment 3 Validation Exercise CheckHst Date: 10 20 93. Checklist No.: 17 Yes No ~NA

1. When the need for classification was initially recognized, were the EALs easily accessible to the user' ~ Q Q Comments: None.

2. Where plant conditions required emergency classiQcation, did the format and layout of the EALs support easy and rapid classification recognition' ~ Q Q Comments: None

3. Was classification of any conditions not requiring emergency classification avoided' S Q Q Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classification efforts' ~ Q Q Comments: None.

3-1

fJ F54 P

OSSI 92-402A-7 EAL Validation Procedure. Rev. 0 Attachment 3 Validation Exercise CheckHst Date: 10 20 93 Checklist No.: 17 Yes No ~NA

5. Where plant conditions required emergency classification, was the operating mode applicability of the EALs clearly recognized' ~ Cl Cl Comments; None

6. Did the EALs and required Emergency Plan procedures interface properly' Q 0 ~

Comments: None.

7. After initial classification, did subsequent classification escalation follow a logical progression in the EALs when appropriate' ~ a a Comments: None.

8. Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate' ~ 0 0 Comments: None.

3-2

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise CheckHst Date: 10 20 93 Checklist No.: 17 Yes ~N ~NA

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs'? Q Q ~

Comments: None.

10. Are the EALs devoid of any misleading or incorrect information' ~ Q Q Comments: None.

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs'? ~ Q Q Comments: None.

12. Did the EALs have adequate detail to be effectively evaluated' ~ Q Q Comments: N~~n.

13. Are the EALs devoid of excessive detail' ~ Q Q Comments: None.

3-3

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise CheckHst Date: 10 20 93 Checklist No.: 17 Yes No ~NA 14, Did the EAL identification scheme adequately support location of the EAL condition within the classiQcation procedure' Comments: None.

15. Addttional Comments: ~Non .

3-4

~

'Q, J

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 ValMation Exercise CheckHst Date: 10 20 93 Checklist No.: 18 Yes No ~NA 1, When the need for classiQcation was initially recognized, were the EALs easily accessible to the user'? R Q Q Comments: None.

2. Where plant conditions required emergency classification, did the format and layout of the EALs support easy and rapid classification recognition' Comments: None.

3. Was classification of any conditions not requiring emergency classification avoided' 5 Q Q Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classification efforts' ~ Q Q Comments: None.

3-1

0, OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise CheckHst Date: 10 20 93. Checklist No.: 18 Yes No ~NA

5. Where plant conditions required emergency classification, was the operating mode applicability of the EALs clearly recognized' ~ Q Q Comments: None.

6. Did the EALs and required Emergency Plan procedures interface properly' Q Q ~

Comments: None.

7. After initial classification, did subsequent classification escalation follow a logical progression in the EALs when appropriate' ~ Q Q Comments: None.

8. Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate' r Q Q Comments: None.

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs'? Q Q ~

Comments: None.

3-2

~ i L~

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Validation Exercise ChecRHst Date: 10 20 93 Checklist No.: 18 Y~s No ~NA

10. Are the EALs devoid of any misleading or incorrect information? ~ Q Q Comments: None.

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs'? Q ~ Q Comments: EAL 8.4.5 Notification from U-3 should indicate a s ecific number of li hts instead of "desi n basis" earth uake.

12. Did the EALs have adequate detail to be effectively evaluated' 8 Q Q Comments: None.

13, Are the EALs devoid of excessive detail' ~ Q Q Comments: None.

14. Did the EAL identification scheme adequately support location of the EAL condition within the classification procedure' Q Q ~

Comments: None.

15. Additional Comments: None.

3-3

i OSSI 92-402A-7 EAL Validation Procedure. Rev. 0 Attachment 3 VaHdation Exercise Checklist Date: 10 20 93 Checklist No.: 19 Yes No ~NA

1. When the need for classiQcation was initially recognized, were the EALs easily accessible to the user' r a o Comments: None.

2. Where plant conditions required emergency classification, did the format and layout of the EALs support easy and rapid classiQcation recognition' Comments: None.

3. Was classification of any conditions not requiring emergency classification avoided' ~ Q 0 Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classification efforts' 0 C3 Comments: None.

5. Where plant conditions required emergency classification, was the operating mode applicability of the EALs clearly recognized'? ~ a o 3-1

<<l4 J

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Validation Exercise CheckHst Date: 10 20 93 Checklist No,: 19 Yes No ~NA Comments: None.

6, Did the EALs and required Emergency Plan procedures interface properly' Q r Comments: None.

7. After initial classification, did subsequent classiQcation escalation follow a logical progression in the EALs when appropriate' ~ Q Q Comments: None.

8. Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate' ~ Q Q Comments: ~Non .

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the FJLs'? Q Q ~

Comments: None.

10. Are the EALs devoid of any misleading or incorrect information' ~ Q Q 3-2

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Validation Exercise CheckHst Date: 10 20 93 Checklist No.: 19 Yes No ~NA Comments: None.

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs'? 8 Q Q Comments: None.

12. Did the EALs have adequate detail to be eQ'ectively evaluated' 5 Q Q Comments: None.

13. Are the EALs devoid of excessive detail' r Q Q Comments: None.

14. Did the EAL identification scheme adequately support location of the EAL condition within the classification procedure' Q Q ~

Comments: None.

15. Additional Comments: None.

3-3

l($

4 =

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise CheckHst Date: 10 20 93 Checklist No.: 20 Yes No ~NA

1. When the need for classification was initially recognized, were the EALs easily accessible to the user' Comments: None.

2. Where plant conditions required emergency classiQcation, did the format and layout of the EALs support easy and rapid classification recognition' ~ Q Q Comments: None.

3. Was classification of any conditions ~no requiring emergency classification avoided' ~ Q Q Comments: None.

4. Did type and arrangement of EAL categories and subcategories adequately support emergency classiQcation efforts' ~ Q Q Comments: None.

3-1

4)

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 VaHdation Exercise ChecMst Date: 10 20 93 Checklist No.: 20 Yes No ~NA

5. Where plant conditions required emergency classification, was the operating mode applicability of the EALs clearly recognized' Comments: ~Non .

6. Did the EALs and required Emergency Plan procedures interface properly'? Q Q ~

Comments: None.

7. After initial classification, did subsequent classiQcation escalation follow a logical progression in the EALs when appropriate' ~ Q Q Comments: None.

8. Did the EALs support escalation of emergency classification when plant conditions indicated that escalation was appropriate' r Q Q Comments: None.

9. Where plant conditions permitted reduction in the level of emergency response, was down grading of classifications easily recognized using the EALs'? Q Q ~

Comments: None.

3-2

OSSI 92-402A-7 EAL Validation Procedure, Rev. 0 Attachment 3 Validation Exercise Checklist Date: 10 20 93 Checklist No.: 20 Yes No ~NA

10. Are the EALs devoid of any misleading or incorrect information' 0 ~ 0 Comments: Tabl 8.2: "S rvi W r Intake Structure" terminolo should be revised.

"Service water Pum Structure" mi ht be better.

11. Did the EALs adequately specify controls, instrumentation, operator aides, procedures, etc.

necessary to effectively evaluate the EALs'? 5 0 0 Comments: None.

12. Did the EALs have adequate detail to be effectively evaluated' ~ 0 0 Comments: None.

13. Are the EALs devoid of excessive detail' ~ 0 0 Comments: None.

14. Did the EAL identification scheme adequately support location of the EAL condition within the classiQcation procedure' 0 0 ~

Comments; None.

15. Additional Comments: None.

3-3

E OSSI 93-402A-10-IP2 IP-2 EAL Verification & Validation Report, Rev. 0 Attachment 6 EAL VaHdation Comment Database 6-1

~ ~ ~ ~ re ~

r ~ e r ~ ~

Record No. 52 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 CI JAF 0 IP-3 CI NMP-2 CI Generic BWR 8 General CI IP-2 CI NMP-1 CI Ginna CI Generic PWR Impact CI NUMARC-007 IHI Procedure CI Verification Cl Training CI Hardware CI EAL CI Technical Bases CI Validation CI Deviation CI None cat ~ IC¹ No. Emer. Class.

Comment Frank Inzirillo (Training Administrator):

Consider generating a matrix and/or table for each operating mode.

Resolution This can be done based on each site determination as to which format they desire status 0 Open 0 Resolved/Awaiting Disposition OI Closed Record No. 53 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 CI JAF CI IP-3 CI NMP-2 CI Generic BWR CI General IRI IP-2 CI NMP-1 CI Ginna CI Generic PWR Impact CI NUMARC-007 IHI Procedure CI Verification CI Training CI Hardware CI EAL IHI Technical Bases CI Validation CI Deviation CI None Cat ~ Ic¹ No. Emer. Class.

Comment Frank Inzirillo (Training Administrator):

Item 3.1.3 on the site area emergency table (RVLIS >39 lo): should be split into two EALs based on mode.

Resolution The concern of this EAL is water level < TAF under any mode. While this EAL could be split into two EALs with RVLIS applicable under all conditions and visual only under refuel, the usability enhancment does not warrant the increased verbage.

status 0 Open 0 Resolved/Awaiting Disposition Oi Closed

)

Record No. 54 Date 1Q/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 QJAF CIIP-3 CINMP-2 CIGenericBWR QGeneral Impact Q IP-2 0 NMP-1 P Ginna H Generic PWR CI NUMARC-007 IH Procedure 0 Verification 0 Training CI Hardware 0 EAL Q Technical Bases Q Validation 0 Deviation 0 None cat ~ Ic¹ No. Emer. Class.

Comment Frank Inzirillo (Training Administrator):

On the matrix, Item 3.2 alert: Need to make a note: "3.1.2 applies."

Resolution Make recommended change.

status 0 Open 0 Resolved/Awaiting Disposition Oi Closed Record No. 55 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 OJAF OIP-3 ONMP-2 OGeneric BWR CIGeneral IHLIP-2 QNMP-1 QGinna QGenericPWR Impact 0 NUMARC-007 HProcedure 0 Verification OTraining 0 Hardware 0 EAL OTechnical Bases CJValidation ODeviation ONone Cat. Ic¹ No. Emer. Class.

Comment Frank Inzirillo (Training Administrator):

On the matrix, GE to be put on left, NUE on right so people will tend to read GEs first.

Resolution Revise matices to start at General on left.

senatus OOpen 0 Resolved/Awaiting Disposition Oe Closed

Wg Record No. 56 Date 1Q/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 0 JAF Q IP-3 0 NMP-2 Q Generic BWR g General Impact C3 IP-2 0 NMP-1 CI Ginna CI Generic PWR 0 NUMARC-007 El Procedure 0 Verification 0 Training 0 Hardware 0 EAL Q Technical Bases 0 Validation 0 Deviation C3 None cat. IC¹ No. Emer. Class.

Comment Frank Inzirillo (Training Administrator):

Consider making borders or otherwise providing better association of tables with their respective EALs.

Resolution Move EALs to within associated category where possible.

status 0 Open 0 Resolved/Awaiting Disposition OI Closed Record No. 57 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 C3 JAF Q IP-3 [3 NMP-2 0 Generic BWR IIIGeneral Impact D IP-2 0 NMP-1 CJ Ginna I7 Generic PWR Cl NUMARC-007 H Procedure Cl Verification C3 Training C3 Hardware 0 EAL 0 Technical Bases Q Validation 0 Deviation 0 None cat. IC¹ No. Emer. Class.

Comment Frank Inzirillo (Training Administrator):

Consider the computer-based table concept for access to information.

Resolution This will be persued.

status Oo Open 0 Resolved/Awaiting Disposition 0 Closed

Record No. 58 oats 10/20/93 Name C. Kelly Walker Orlglnatlng Site Site Appllcablllty IP-2 Q JAF Q IP-3 QNMP-2 QGeneric BWR QGeneral Impact g IP-2 Q NMP-1 Q Ginna Q Generic PWR Q NUMARC-007 IH Procedure Q Verification Q Training Q Hardware Q EAL Q Technical Bases Q Validation Q Deviation Q None cat. IC¹ No. Emer. Class.

Comment Frank Inzirillo (Training Administrator):

For the a text-based format, consider making one in which one category would be on a page.

Resolution This can be done based upon the decision on format and presentation method status 0 Open 0 Resolved/Awaiting Disposition Oe Closed Record No. 59 Date 10/20/93 Name C. Kelly Walker Orlglnatlng Site Site Appllcablllty IP-2 QJAF QIP-3 QNMP-2 QGeneric BWR QGeneral Impact g IP-2 Q NMP-1 Q Ginna Q Generic PWR Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware Q EAL H Technical Bases Q Validation Q Deviation Q None cat. Ic¹ No. Emer. Class.

Comment Richie Burns:

Have the Tech Bases for 1.1.1 reflect the information about RCPs running and differing RVLIS levels (44% with 4 RCPs running, etc.).

Resolution Add to technical basis status 0 Open 0 Resolved/Awaiting Disposition Oe Closed

~4 Record No. 60 Date 1Q/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 0 JAF 0 IP-3 0 NMP-2 0 Generic BWR mj General Impact 0 IP-2 Q NMP-1 0 Ginna Q Generic PWR 0 NUMARC-007 IHI Procedure 0 Verification 0 Training 0 Hardware 0 EAL Q Technical Bases Q Validation 0 Deviation 0 None Cat. Ic¹ No. Emer. Class.

Comment Bill-Durr (Assistant to OPS Manager):

Flags should be put into the EOPs (including CSFSTs) calling attention to the EALs.

Resolution Agree status Oo Open 0 Resolved/Awaiting Disposition 0 Closed Record No. 61 Date 10/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 0 JAF 0 IP-3 0 NMP-2 0 Generic BWR 0 General Impact III IP-2 0 NMP-1 0 Ginna 0 Generic PWR 0 NUMARC-007 E Procedure Q Verification 0 Training 0 Hardware 0 EAL 0 Technical Bases 0 Validation 0 Deviation 0 None cat. IC¹ No. Emer. Class.

Comment Bill Durr (Assistant to OPS Manager):

Barrier analysis is not as easy as it was with the old EALs. SWS will be very busy going through an analysis. Needs to be human factored. Put CSFSTs EALs into red, orange blocks?

Resolution Familiarity with EAL structure and layout will make EAL evaluation easier. This has been shown through validation with other personnel.

status 0 Open 0 Resolved/Awaiting Disposition Oo Closed

Record No. 62 Date 1Q/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 0 JAF 0 IP-3 CI NMP-2 CI Generic BWR C3 General Impact Cj IP-2 0 NMP-1 0 Ginna 8 Generic PWR QNUMARC-007 E Procedure CI Verification CITraining 0 Hardware g EAL IHI Technical Bases C3 Validation Q Deviation 0 None cat. Ic¹ No. Emer. Class.

Comment Bill Durr (Assistant to OPS Manager):

Revisit whether 2.1.1 should be applicable only under power operations and hot standby.

Resolution NUMARC requires applicability under all modes status 0 Open 0 Resolved/Awaiting Disposition 0< Closed Record No. 63 Date 1Q/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 0 JAF 0 IP-3 0 NMP-2 Q Generic BWR CI General Impact 8 IP-2 0 NMP-1 0 Ginna 0 Generic PWR 0 NUMARC-007 H Procedure C3 Verification 0 Training C3 Hardware Q EAL C3 Technical Bases CI Validation 0 Deviation C3 None cat. IC¹ No. Emer. Class.

Comment John McAvoy (OPS Manager):

Instead of one long sheet for the matrix, a wide one would be better. Side-by-side format similar to the IP-3 model would be acceptable.

Resolution This can be done at the option of the utility.

status 0 Open 0 Resolved/Awaiting Disposition 0 Closed

Record No. 64 Date 'I Q/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 Q JAF Q IP-3 Q NMP-2 Q Generic BWR Q General Impact Q IP-2 Q NMP-1 Q Ginna g Generic PWR Q NUMARC-007 8 Procedure Q Verification Q Training Q Hardware g EAL 8 Technical Bases Q Validation Q Deviation Q None cat. IC¹ No. Emer. Class.

Comment John McAvoy (OPS Manager):

EAL '1.5.2 change "inoperative" to "inoperable."

Resolution Make change status 0 Open 0 Resolved/Awaiting Disposition Oo Closed Record No. 65 Date 1Q/2Q/93 Name C. Kelly Site Site Applicability Walkei'riginating IP-2 Q JAF Q IP-3 Q NMP-2 Q Generic BWR Q General Impact IHT IP-2 Q NMP-1 Q Ginna Q Generic PWR Q NUMARC-007 g Procedure Q Verification Q Training Q Hardware g EAL H Technical Bases Q Validation Q Deviation Q None cat No. Emer. Class.

Comment John McAvoy (OPS Manager):

2.3.2 Change R-11/R-12 to R-41/R-42.

Resolution Delete R-11 and change R-12 to R-42 status P Open 0 Resolved/Awaiting Disposition Oe Closed

(

Record No. 66 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 QJAF QIP-3 QNMP-2 QGenericBWR QGeneral Q IP-2 Q NMP-1 QGinna HGeneric PWR Impact Q NUMARC-007 IHI Procedure Q Verification Q Training Q Hardware g EAL g Technical Bases Q Validation Q Deviation Q None Cat. Ic¹ No. Emer. Class.

Comment John McAvoy (OPS Manager):

2.3.2 Add: "...caused by irradiated fuel damage or uncovery."

Resolution Make change status 0 Open 0 Resolved/Awaiting Disposition Oe Closed Record No. 67 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 QJAF QIP-3 QNMP-2 QGenericBWR QGeneral Impact Q IP-2 Q NMP-1 Q Ginna E Generic PWR Q NUMARC-007 HProcedure Q Verification QTraining Q Hardware g EAL g Technical Bases Q Validation Q Deviation Q None cat. Ic¹ No. Emer. Class.

Comment John McAvoy (OPS Manager):

4.1.3 Add the words "when required."

Resolution Make change status OOpen 0 Resolved/Awaiting Disposition Oe Closed

H Record No. 68 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 Q JAF Q IP-3 Q NMP-2 Q Generic BWR Q General Q IP-2 Q NMP-1 Q Ginna IHI Generic PWR Impact Q NUMARC-007 8 Procedure Q Verification Q Training Q Hardware H EAL gl Technical Bases Q Validation Q Deviation Q None cat IC¹ No. Emer. Class.

Comment John McAvoy (OPS Manager):

For the containment (4.x) EALs, need to define "LOCA."

Resolution Add definition to word list.

status 0 Open 0 Resolved/Awaiting Disposition Oo Closed Record No. 69 Date 10/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 Q JAF Q IP-3 Q NMP-2 Q Generic BWR Q General impact 8 IP-2 Q NMP-1 Q Ginna Q Generic PWR Q NUMARC-007 H Procedure Q Verification Q Training Q Hardware g EAL EI Technical Bases Q Validation Q Deviation Q None cat. Ic¹ No. Emer. Class.

Comment John McAvoy (OPS Manager):

For all the "Other" category, add Plant Operations Manager (P.O.M.) to the list of responsible personnel in the EALs. Make the change to the Tech Bases too.

Resolution Make change as noted status 0 Open 0 Resolved/Awaiting Disposition Oa Closed

Record No. 70 Date 1Q/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 0 JAF 0 IP-3 0 NMP-2 0 Generic BWR 0 General Impact 8 IP-2 0 NMP-1 0 Ginna 0 Generic PWR 0 NUMARC-007 H Procedure 0 Verification 0 Training C3 Hardware g EAL El Technical Bases CI Validation 0 Deviation 0 None Cat. Ic¹ No. Emer. Class.

Comment John McAvoy (OPS Manager):

For the category of loss of annunciators, clarification is needed. (Too vague.)

Resolution Discuss with IP2 personnel status 0+ Open 0 Resolved/Awaiting Disposition 0 Closed Record No. 71 Date 1Q/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 0 JAF 0 IP-3 0 NMP-2 C3 Generic BWR 8 General Impact 0 NUMARC-007 0 EAL cat.

'L Q IP-2 Cl NMP-1 H Procedure Technical Bases Ic¹ P Ginna 0 Generic 0 Verification 0 Validation No. Emer.

PWR Q Training Cl Deviation Class.

CI Hardware C3 None Comment Kelly Walker: Add definitions of Operable and Inoperable to glossary.

Resolution Add defintions to word list. Operable - capable of performing its intended function Inoperable - Not capable of performing its intended function status 0 Open 0 Resolved/Awaiting Disposition 0 Closed

Record No. 72 Date 10/2Q/93 Name C. Kelly Walker originating Site Site Applicability IP-2 Q JAF Q IP-3 ONMP-2 OGeneric BWR OGeneral QIP-2 ONMP-1 OGinna HGenericPWR Impact O NUMARC-007 H Procedure O Verification O Training O Hardware HEAL H Technical Bases O Validation O Deviation Q None Cat. IC¹ No. Emer. Class.

Comment Tom Schmeiser (General Manager of NPG):

1.5.1 and 1.5.2: Should be applicable in both power operation and hot shutdown. Also need to change the definition of power operation in the Tech Bases.

Resolution Agree. Will revise operating modes into 3 modes:

Hot - >200 'F Cold - <200'F Defuel status 0 Open 0 Resolved/Awaiting Disposition Oe Closed Record No. 73 Date 1Q/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 O JAF O IP-3 Q NMP-2 O Generic BWR O General O IP-2 O NMP-1 O Ginna H Generic PWR Impact O NUMARC-007 HProcedure O Verification Q Training O Hardware H EAL H Technical Bases O Validation O Deviation O None cat. Ic¹ No. Emer. Class.

Comment Tom Schmeiser (General'Manager of NPG):

6.1.1: Delete the word "offsite."

Resolution Delete word offsite status 0 Open 0 Resolved/Awaiting Disposition 0+ Closed

4s Record No. 74 Date 1Q/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 OJAF HIP-3 ONMP-2 OGeneric BWR OGeneral Impact SIP-2 QNMP-1 DGinna CIGenericPWR CI NUMARC-007 HProcedure 0 Verification 0 Training CI Hardware g EAL IHI Technical Bases 0 Validation 0 Deviation Cl None cat. Ic¹ No. Emer. Class.

Comment Charlie Limoges (Reactor Engineer):

Consider combining mode 1 and mode 2 in the tables into one mode. And modes 3 and 4. Confer with IP-3.

Resolution Agree. Will revise operating modes into 3 modes:

Hot - )200 'F Cold - <200 'F Defuel status OOpen 0 Resolved/Awaiting Disposition Oi Closed Record No. 75 Date 1Q/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 C3 JAF CI IP-3 P NMP-2 QGeneric BWR QGeneral Impact g IP-2 I7NMP-1 PGinna C]Generic PWR 0 NUMARC-007 HProcedure C3 Verification 0 Training CI Hardware g EAL gTechnical Bases CI Validation CIDeviation 0 None cat. Ic¹ No.

r Emer. Class.

Comment Bill Kessler: Tech Bases for sections 6.2.1 8 6.2.2: Add as a reference FSAR section 8.2.3.5 (Electrical System Design).

Resolution Add references s~a~us 0 Open 0 Resolved/Awaiting Disposition 0>> Closed

Record No. 76 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 OJAF C3IP-3 ONMP-2 QGeneric BWR CIGeneral HIP-2 C3NMP-1 CIGinna OGeneric PWR Impact C3 NUMARC-007 g Procedure 0 Verification 0 Training 0 Hardware g EAL gTechnical Bases CIValidation DDeviation QNone cat. Ic¹ No. Emer. Class.

Comment Kelly Walker: Use river level of 14.5'UE, 15'lert, reference FSAR section 2.5. For the low level Alert, use loss of suction to SW pumps (loss of Service Water).

Resolution Revise 8.4.4 and 8.4.8 as stated status OOpen OResolved/Awaiting Disposition OeClosed Record No. 77 Date 1Q/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 CI JAF 0 IP-3 0 NMP-2 C3 Generic BWR 8 General Impact P IP-2 P NMP-1 Q Ginna Q Generic PWR 0 NUMARC-007 IE Procedure 0 Verification OTraining 0 Hardware III EAL EITechnical Bases CIValidation DDeviation ClNone Cat. Ic¹ No. Emer. Class.

Comment Jack Parry (Health Physics): 5.3.1: Add: "resulting from an uncontrolled process."

Resolution Add wording to 5.3.1 s~a~us 0 Open 0 Resolved/Awaiting Disposition OI Closed.

'1l Record No. 78 Date 1p/2p/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 P JAF P IP-3 QNMP-2 CIGeneric BWR C3General HIP-2 ONMP-1 QGinna P Generic PWR Impact Q NUMARC-007 IHI Procedure CI Verification C7 Training 0 Hardware g EAL 8 Technical Bases C3 Validation CJ Deviation Q None cat. IC¹ No. Emer. Class.

Comment Jack Parry (Health Physics): 5.3.3: Should 8 R/hr apply to outside areas such as Condensate Storage Tank and Service Water Structure, where such a high dose rate is very unlikely?

Resolution Yes, the likelyhood is irrelevant. The concern is the loss of accessability to that area status 0 Open 0 Resolved/Awaiting Disposition Oo Closed Record No. 79 Date 1p/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 OJAF OIP-3 ONMP-2 OGeneric BWR CIGeneral IHL IP-2'INMP-1 QGinna CI Generic PWR Impact C3 NUMARC-007 H Procedure 0 Verification CI Training 0 Hardware g EAL H Technical Bases 0 Validation Q Deviation Q None cat. Ic¹ No. Emer. Class.

Comment Jack Parry (Health Physics): 2.2.3 number of 68 R/hr is not consistent with the PAG boundary dose for GE of Table 5.2.

Resolution The bases for these values are different and are not intended to be consistant. The containment radiation level is indicative of barrier loss while the Table 5.2 values are based on EPA PAGs.

status 0 Open 0 Resolved/Awaiting Disposition Oi Closed

Record No. 80 Date 1Q/2Q/93 Name C. Kelly Walker Orlginatlng Site Site Appllcablllty IP-2 Q JAF Q IP-3 QNMP-2 QGeneric BWR QGeneral HIP-2 QNMP-1 QGinna QGenericPWR Impact Q NUMARC-007 H Procedure Q Verification Q Training Q Hardware g EAL g Technical Bases Q Validation Q Deviation Q None cat. IC¹ No. Emer. Class.

Comment Jack Parry (Health Physics): The numbers of 2.2 could be plotted as a function of time.

Resolution This is true but little or no ehnhancement would result by doing so. The EAL attempts to provide a threshold for emergency classification based on barrier loss, not the radiological consequences of the values. Adding the variable of time after shutdown would complicate EAL evaluation. Also, because of the range in which these values fall, 17 R/hr to 68 R/hr, the variation in the values with timo in rnmnaricnn tn tho arnI Iranv nf tho riots ntnr wn>>irl cnnio littlo nIirnnco status OOpen 0 Resolved/Awaiting Disposition 0 Closed Record No. 81 Date 1Q/2Q/93 Name C. Kelly Walker Orlglnatlng Site Site Applicability IP-2 QJAF QIP-3 QNMP-2 QGenericBWR QGeneral IHL IP-2 Q NMP-1 Q Ginna Q Generic PWR Impact Q NUMARC-007 Q Procedure Q Verification Q Training Q Hardware laL EAL Q Technical Bases Q Validation Q Deviation Q None Cat. Ic¹ Emer. Class.

Comment Jack Parry (Health Physics): Correct typo in text EALs: In 1.2.1, add "Hot Shutdown."

Resolution Make revision s~a~us 0 Open 0 Resolved/Awaiting Disposition 0+ Closed

Record No. 82 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 C] JAF 0 IP-3 0 NMP-2 0 Generic BWR Q General Impact g IP-2 0 NMP-1 0 Ginna CI Generic PWR Q NUMARC-007 CJ Procedure 0 Verification Q Training CI Hardware iHL EAL E Technical Bases 0 Validation 0 Deviation 0 None cat. IC¹ No. Emer. Class.

Comment Kelly Walker: 8.3.3: There is potential to remove this EAL if it can be proved that no toxic gas can enter the site.

Resolution Will consider deletion upon being provided analysis to support status Qo Open 0 Resolved/Awaiting Disposition 0 Closed Record No. 83 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 QJAF OIP-3 CINMP-2 OGenericBWR C]General Impact 8 IP-2 0 NMP-1 0 Ginna 0 Generic PWR 0 NUMARC-007 H Procedure 0 Verification CITraining D Hardware 5g EAL IHL Technical Bases Cl Validation 0 Deviation CI None cat. IC¹ No. Emer. Class.

Comment John Ferrick: "Piggybacking" does not typically meet the definition of "unauthorized personnel" for purposes of 8.1.2 and 8.1.3. Replace "unauthorized person" with "adversary." Add "adversary" to the glossary of the Tech Bases.

Resolution Revise 8.1.2, 8.1.3 and 8.1.4 to refer to "an adversary" vs. unauthorized personnel sta~us 0 Open 0 Resolved/Awaiting Disposition Oo Closed

IW Record No. 84 Date 1Q/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 QJAF QIP-3 QNMP-2 QGenericBWR EGeneral Q IP-2 Q NMP-1 Q Ginna Q Generic PWR Impact Q NUMARC-007 IHProcedure Q Verification Q Training Q Hardware g EAL 8 Technical Bases Q Validation Q Deviation Q None cat. IC¹ No. Emer. Class.

Comment John Ferrick: 5.3.3: The number of 8 R/hr is not supported by the new 10CFR20 because the quarterly limits have changed.

Resolution The limits have not change, only the method by which it is calculated.

status 0 Open 0 Resolved/Awaiting Disposition 0>> Closed Record No. 85 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 QJAF QIP-3 QNMP-2 QGenericBWR gGeneral QIP-2 QNMP-1 QGinna QGenericPWR Impact Q NUMARC-007 g Procedure Q Verification Q Training Q Hardware g EAL EITechnical Bases QValidation Q Deviation Q None cat. Ic¹ Emer. Class.

Comment John Ferrick: 4.1.3 and 4.1.6: Change "downstream pathway" to "radiological release pathway."

Resolution Make change as noted status OOpen 0 Resolved/Awaiting Disposition 0>> Closed

1

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Record No. 86 Date 1Q/2Q/93 Name C. Kelly Walker Originating Site Site Appllcablllty IP-2 Q JAF 8 IP-3 Q NMP-2 Q Generic BWR Q General Impact g IP-2 Q NMP-1 Q Ginna O Generic PWR O NUMARC-007 IH Procedure O Verification O Training O Hardware III EAL IIITechnical Bases Q Validation Q Deviation Q None cat. Ic¹ No. Emer. Class.

Comment John Ferrick: 2.3.2: Add: "resulting from an uncontrolled fuel handling process." Delete the particulate monitor (R-41) because the concern is noble gas. Add to list of monitors R-7 (i.e. change to "R-2/R-7, VC radiation monitors." Need to revise P.E.G. to support this.

Resolution Revise as noted status 0 Open 0 Resolved/Awaiting Disposition Oe Closed Record No. 87 Date 1Q/2Q/93 Name C. Kelly Walker Orlglnatlng Site Site Appllcabillty IP-2 Q JAF Q IP-3 Q NMP-2 Q Generic BWR Q General Impact H IP-2 Q NMP-1 Q Ginna Q Generic PWR Q NUMARC-007 H Procedure Q Verification O Training Q Hardware III EAL H Technical Bases Q Validation Q Deviation Q None Cat ~ Ic¹ No. Emer. Class.

Comment Greg Dean: 8.4.4 and 8.4.8: change "intake" to "Service Water Bay."

Resolution Revise as noted.

status 0 Open 0 Resolved/Awaiting Disposition Oi Closed

k Record No. 88 Date 1Q/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 0 JAF 8 IP-3 CI NMP-2 C3 Generic BWR Q General Impact g IP-2 P NMP-1 CIGinna P Generic PWR 0 NUMARC-007 H Procedure Cl Verification Cl Training Q Hardware g EAL IHL Technical Bases P Validation Q Deviation 0 None cat. Ic¹ No. Emer. Class.

Comment Greg Dean: Add to 2.2.1: "Rapid rise...with confirmed coolant analysis sample in excess of 60 over E bar.

Resolution Revised to read "Rapid rise on R-41 or R-42 with coolant sample activity > 60/(E bar) pCI/CC" status 0 Open 0 Resolved/Awaiting Disposition Oo Closed Record No. 89 Date 1Q/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 0 JAF 8 IP-3 CI NMP-2 Q Generic BWR H General Impact 0 IP-2 Q NMP-1 P Ginna 0 Generic PWR 0 NUMARC-007 8 Procedure Q Verification 0 Training C3 Hardware g EAL H Technical Bases Cl Validation C3 Deviation 0 None cat ~

. Ic¹ No. Emer. Class.

Comment Kelly Walker: 6.2.1 and 6.2.2: Add the words, "all of the following."

Resolution Make change as noted status 0 Open 0 Resolved/Awaiting Disposition Oe Closed

Record No. 90 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 OJAF glP-3 QNMP-2 QGenericBWR OGeneral Impact g IP-2 0NMP-1 IHTGinna CIGeneric PWR C3 NUMARC-007 HProcedure CI Verification OTraining 0 Hardware g EAL 8 Technical Bases 0 Validation 0 Deviation 0 None cat. IC¹ No. Emer. Class.

'\

Comment Scenario ¹1:

Bill Smith: 6.1.1 should be loss or power to Station Service Transformers instead of Station Transformers.

Rill smith In tha msti'iv ni it the C!CCQT ciihnstannriac in tha ni'Bar in iaihir h thaw annaai'esolution Add "Service" to 6.1 ~ 1 Place Subcriticality first and renumber. Check Binning document for change.

status Oopen OResolved/Awaiting Disposition OeClosed Record No. 91 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 C]JAF HIP-3 ONMP-2 CIGenericBWR C]General Impact 8 IP-2 0 NMP-1 QGinna CIGeneric PWR 0 NUMARC-007 g Procedure Q Verification 0 Training Q Hardware g EAL H Technical Bases 0 Validation C3 Deviation Q None cat. Ic¹ No. Emer. Class.

Comment Scenario ¹2:

Bill Smith: Remove VC from Table 5.3.

Resolution Remove VC in Table. Check Tech. Basis and PEG status 0 open O Resolved/Awaiting Disposition O+ Closed

Record No. 92 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 Q JAF Q IP-3 Q NMP-2 Q Generic BWR Q General Impact Q IP-2 Q NMP-1 Q Ginna 8 Generic PWR Q NUMARC-007 H Procedure Q Verification Q Training Q Hardware g EAL H Technical Bases Q Validation Q Deviation Q None cat. Ic¹ No. Emer. Class.

Comment Scenario 03:

Charlie: Need to look at 4.1.4 from a human factors standpoint to verify that the condition can be readily tied to its subcategory.

C'.harlio Cnr A 1 9 A 1 6 The tarm "<<navnlainarl" chn<<ld ha ronlarorl iaiith "<<nnnntrnllorl" Resolution 4.1.4 appears to be in the propoer location Relace term "unexplained" with "uncontrolled" status 0 Open 0 Resolved/Awaiting Disposition OI Closed Record No. 93 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 Q JAF Q IP-3 Q NMP-2 Q Generic BWR g General Q IP-2 Q NMP-1 Q Ginna Q Generic PWR Impact Q NUMARC-007 g Procedure Q Verification Q Training Q Hardware g EAL g Technical Bases Q Validation Q Deviation Q None cat ~ IC¹ No. Emer. Class.

Comment Scenario t7 Frank: On the text-based EALs, there should be some way of distinguishing between categories.

(Hard to find one number amidst the general clutter.) This is actually more of a general comment.

Resolution This will be done based on decision on format and presentation method.

status 0 Open 0 Resolved/Awaiting Disposition 0 Closed

Record No. 94 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 0 JAF 0 IP-3 0 NMP-2 Q Generic BWR CI General Impact 0 IP-2 0 NMP-1 0 Ginna H Generic PWR CI NUMARC-007 H Procedure 0 Verification 0 Training 0 Hardware HEAL H Technical Bases Cl Validation CI Deviation Cl None Cat. IC¹ No. Emer. Class.

Comment Scenario ¹8:

Frank: Add events other than both airlock doors open to the loss of containment integrity NUE (4.1.1), i.e. loss of ability to isolate containment pressure relief valves or purge valves, and there is a radiological release path.

Re so lut ion Reword 4.1.1 to read as follows:

Both doors open on a VC airlock for > 4 hrs.

OR Inability to isolate containment pressure relief or purge valves which results in a radiological rolooco nothwov tn tho onvirnnrnont status 0 Open 0 Resolved/Awaiting Disposition OI Closed Record No. 95 Date 1Q/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 Q JAF H IP-3 Q NMP-2 P Generic BWR Cl General

~

Impact H IP-2 Cj NMP-1 Q Ginna 0 Generic PWR 0 NUMARC-007 H Procedure Q Verification 0 Training Cl Hardware HEAL H Technical Bases 0 Validation C3 Deviation C] None cat ~ Ic¹ No. Emer. Class.

Comment Scenario ¹10:

Frank: SAE 3.1.3 should define the core plane as the level involved.

Resolution Current wording is adequate for the intended condition.

status 0 Open 0 Resolved/Awaiting Disposition 0e Closed

4 h

Record No. 96 Date 10/20/93 Name C. Kelly Walker Originating Site Site Appllcabillty IP-2 OJAF OIP-3 ONMP-2 QGeneric BWR HGeneral Impact 8 IP-2 0 NMP-1 0 Ginna CI Generic PWR Cj NUMARC-007 El Procedure CI Verification CJ Training 0 Hardware ist EAL 8 Technical Bases Q Validation C3 Deviation 0 None cat. Ic¹ No. Emer. Class.

Comment Scenario ¹11:

Jack Parry: For subcategory 5.2: Add some reference to release rates.

Resolution Add "/Release Rates" to subcategory title status 0 Open 0 Resolved/Awaiting Disposition OI Closed Record No. 97 Date 10/20/93 Name C. Kelly Walker Orlglnatlng Site Site Appllcablllty IP-2 CIJAF OIP-3 ONMP-2 CIGeneric BWR CIGeneral Impact 0IP-2 ONMP-1 QGinna HGeneric PWR CI NUMARC-007 mj Procedure 0 Verification C] Training 0 Hardware g EAL EI Technical Bases 0 Validation 0 Deviation C] None cat. IC¹ No. Emer. Class.

Comment Scenario ¹15:

Jack Parry: 8.4.7: Need some kind of mechanism to tie the tables to the EALs that reference them.

Resolution Move tables into category referenced.

s~a~us 0 Open 0 Resolved/Awaiting Disposition 0 Closed

Record No. 98 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 Q JAF QIP-3 QNMP-2 QGeneric BWR HGeneral QIP-2 QNMP-1 QGinna QGeneric PWR Impact Q NUMARC-007 EI Procedure Q Verification QTraining 0 Hardware g EAL E Technical Bases Q Validation Q Deviation Q None cat. IC¹ No. Emer. Class.

Comment Scenario ¹16:

Bill Durr: 8.2.2: Eliminate the word "any" and make it "plant areas, table 8.2..."

Bill Durr: 8.3.2 would better be located under category 8.2.

Resolution Revise 8.2.2 to state "in plant areas, Table 8.2,..."

Renumber 8.3.2 to 8.2.2 and renumber susequent EALs as appropriate.

status 0 Open 0 Resolved/Awaiting Disposition 0 Closed Record No. 99 Date 1Q/2Q/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 Q JAF Q IP-3 Q NMP-2 Q Generic BWR Q General Impact 8 IP-2 QNMP-1 QGinna QGeneric PWR Q NUMARC-007 8 Procedure Q Verification Q Training Q Hardware g EAL H Technical Bases Q Validation Q Deviation Q None cat. Ic¹ No. Emer. Class.

Comment Scenario ¹18:

Bill Durr: 8.4.5 Notification from U-3 should indicate a specific number of lights, instead of "design basis" earthquake.

Re so lut ion Need to determine number of peak shock indicators to use status 0>> Open 0 Resolved/Awaiting Disposition 0 Closed

Record No. 100 Date 10/20/93 Name C. Kelly Walker Originating Site Site Applicability IP-2 OJAF OIP-3 C3NMP-2 QGenericBWR QGeneral HIP-2 C]NMP-1 OGinna QGeneric PWR Impact C3 NUMARC-007 H Procedure CI Verification 0 Training 0 Hardware g EAL gTechnical Bases OValidation CIDeviation P None Cat. Ic¹ No. Emer. Class.

Comment Scenario ¹20:

Bill Smith: Table 8.2: "Service Water Intake Structure" terminology should be revised. "Service water Pump Structure" might be better.

Resolution Revised to read "Service Water Pump Structure" status QOpen OResolved/Awaiting Disposition 0+Closed