ML17263A767
| ML17263A767 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 09/01/1994 |
| From: | Andrea Johnson Office of Nuclear Reactor Regulation |
| To: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| References | |
| TAC-M89506, NUDOCS 9409070248 | |
| Download: ML17263A767 (50) | |
Text
Septer, 1,
1994 Dr. Robert C. Hecredy Vice President, Nuclear Production Rochester Gas and Electric Corporation 89 East Avenue Rochester, NY 14649
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION ON R.E.
GINNA EMERGENCY ACTION LEVELS (TAC NO. M89506)
Dear Dr. Hecredy:
In your letter dated Hay 13,
- 1994, you submitted the Ginna Nuclear Power Plant Emergency Action Levels (EAL) revision to NUMARC NESP-007 methodology for review and approval by NRC staff.
In a teleconference held on August 17, 1994, the NRC staff presented their initial findings from the review of the revised EAL to Rochester Gas and Electric Corporation (RG&E).
The staff has completed their review of the revised EAL using NUMARC NESP-007 as the basis for their review.
The staff has identified a number of EALs that depart from the NUMARC NESP-007 cr'iteria.
These EALs should be modified to meet the NUMARC criteria or additional information provided to support the changes.
Please respond to the enclosed request for additional information within 30 days of receipt of this letter.
This requirement affects fewer than ten respondents and, therefore, is not subject to Office of Management and Budget review under P.L.96-511.
Sincerely, 940't/070248 94090i f DR ADOCX 0S000244 F
pDR I
Original signed by Allen R. Johnson, Project Manager Project Directorate I-3 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation Docket No. 50-244
Enclosure:
Request for Additional Information cc w/encl:
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Dr. Robert C. Hecredy Vice President, Nuclear Production Rochester Gas 'and Electri'c Corpoqation 89 East Avenue Rochester, NY
.14649 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON> D.C. 20555-M01 September i, 1994
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION ON R.E.
GINNA EMERGENCY ACTION LEVELS (TAC NO. H89506)
Dear Dr. Hecredy:
This requirement affects fewer than ten respondents and, therefore, is not subject to Office of Management and Budget review under P.L.96-511.
Sincerely, P
In your letter dated Hay 13,
- 1994, you submitted the Ginna Nuclear Power Plant Emergency Action Levels (EAL) revision to NUHARC NESP-007 methodology for review and approval by NRC staff.
In a teleconference held on August 17,
- 1994, the NRC staff presented'heir initial findings from the review of the revised EAL to Rochester Gas and Electric Corporation (RG&E).. The staff has completed their review of the revised EAL using NUHARC NESP-007 as the basis for their review.
The staff has identified a number of EALs that depart from the NUMARC NESP-007 criteria.
These EALs should be modified to meet the NUMARC criteria or additional information provided to support the changes.
Please respond to the enclosed request for additional information within 30 days of receipt of this letter.
A en R. Johns n, Project Manager oject Dire orate I-3 D)
Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket No. 50-244
Enclosure:
Request for Additional Information cc w/encl:
See next page
Dr. Robert C. Hecredy R.E.
Ginna Nuclear Power Plant CC:
ThomasA.
Mosl.ak,, Senior Resident Inspector R.E.
Ginna Plant U.S. Nuclear Regulatory Commission 1503 Lake Road
- Ontario, NY 14519 Regional Administrator, Region I
U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Hs.
Donna Ross Division of Policy Analysis 5 Planning New York State Energy Office Agency Building 2 Empire State Plaza
- Albany, NY 12223 Charlie Donaldson, Esq.
Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Nicholas S.
Reynolds Winston 8 Strawn 1400 L St.
N.W.
Washington, DC 20005-3502 Hs. Thelma Wideman
- Director, Wayne County Emergency Management Office Wayne County Emergency Operations Center 7370 Route 31
- Lyons, NY 14489 Ms. Mary Louise Meisenzahl Administrator, Monroe County Office of Emergency Preparedness 111 West Fall
- Road, Room 11 Rochester, NY 14620
REQUEST FOR ADDITIONALINFORMATION REGARDING R. E. GINNA NUCLEAR POWER PLANT EAL REVISION TO NlJMARC/NESP-007 METHODOLOGY (TAC NUMBER M89506)
I.
BACKGROUND The March 23, 1994 proposed revision to R. E. Ginna Nuclear Power Station emergency action levels (EALs) was reviewed against the requirements in 10 CFR 50.47 (b)(4) and Appendix E to 10 CFR Part 50.
10 CFR 50.47(b)(4) specifies that onsite emergency plans must meet the following standard: "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee...."
Appendix E (IV)(C) specifies that "emergency action levels (based not only on onsite and offsite radiation monitoring information but also on readings from.a number of sensors that indicate a potential emergency, such as pressure in containment and response of the Emergency Core Cooling System) for notification of offsite agencies shall be described...
The emergency classes defined shall include (1) notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency."
In Revision 3 to Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power'Reactors,"
the NRC endorsed NUMARC/NESP-007, Revision 2 (NESP-007), "Methodology for Development of Emergency Action Levels," as an acceptable method for licensees to meet the requirements of 10 CFR 50,47 (b)(4) and Appendix E to 10 CFR Part 50.
The staff utilized NUMARC/NESP-007 as the basis for this review of the R. E.
Ginna Nuclear Power Station proposed revision.
The staff has identified a number of EALs that depart from the NUMARC/NESP-007 criteria.
These EALs should be modified to meet the NUMARC criteria or additional information provided which support the changes.
II.
REVIEW RESULTS - R. E. Ginna EALs - REVISION 3 23 94 ORGANIZATION OF EALS Enclosure project.
The joint EAL upgrade project objective was to ensure conformity and consistency between the following nuclear plants:
Nine"Mile Point (Units 1 and 2)
James A. Fitzpatrick Indian Point Station 2 Indian Point 3 R. E. Ginna The R. E. Ginna revised EALs were derived from the Ginna Plant Specific EAL Guideline (PEG).
The PEG was a reproduction of the NUMARC methodology, modified by additions or deletions that customized the NUMARC EALs to plant specific EALs for the R. E. Ginna Station.
Bases information for each NUMARC example EAL modification, addition, or deletion was included.
The PEG was the R. E. Ginna interpretation of the NUMARC methodology for developing EALs.
0
. A Fission Product Barrier (FPB) Evaluation, Rev 0, was generated to ascertain the combinations of FPB loss or potential loss and derive the appropriate classification level. The PEG and the FPB Evaluation formed the bases for the R. E. Ginna EAL classification scheme.
The licensee has organized the EALs into nine categories.
Category 1.0 Category 2.0 Category 3.0 Category 4.0 Category 5.0 Category 6.0 Category 7.0 Category 8.0 Category 9.0 CSFST Status Reactor Fuel Reactor Coolant System Containment Radioactivity Release Electrical Failures, Equipment Failures Hazards Other Each category was divided into one or more subcategories, a brief statement of the NUMARC Initiating Condition.
For example: Category 1.0, CSFST, contained the following subcategories; 1.1 1.2 1.3 1.4 1.5 Subcriticality Core Cooling Heat Sink Integrity Containment
C C
Following the sub category, in ascending order of severity, the classification level was listed; unusual event, alert, site area emergency, and general emergency.
Below the emergency classification level the plant specific emergency action levels (thresholds) were exhibited.
The applicable plant operation mode was specified for each classification level. The operation modes are:
Power operations Hot Shutdown Cold Shutdown Refueling Defueled If an EAL was applicable for all operating modes, the "Mode Applicability" was stated as "All."
A separate
- document, "R. E. Ginna Emergency Action Levels Technical Bases," Revision 0, was keyed to the emergency classification scheme by category and sub category.
The technical bases defined the operating modes, fission product barriers, and event classification level, replicating most of the information in the PEG, but in paragraph rather than table form.
The technical bases provided the following information for each EAL:
Classification Specific conditions constituting the EAL Operating mode(s)
EAL Basis Plant Specific EAL Guideline (PEG) reference Basis reference(s)
GENERAL The R.E. Ginna EAL tables (both Categories and Sub-Categories) omitted the full text of the NUMARC Initiating Conditions.
For example, the NUMARC criteria for Initiating Condition AG1 states:
"Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity that Exceeds 1000 mR Whole Body or 5000mR Child Thyroid for the Actual or Projected Duration of the Release Using Actual Meteorology."
The equivalent R.E..-Ginna Initiating Condition (IC) stated in part:
"5.0 Radioactivity Release/Area Radiation"
and "5.2 Dose Projections/Environmental Measurements/Release Rates" In accordance with NUMARC/NESP-007, ICs are: "one of a predetermined subset of nuclear power plant conditions where either the potential exists for a radiological emergency, or such an emergency has occurred."
EALs are:
"a pre-determined, site-specific, observable threshold for a plant IC that places the plant in a given emergency class,"
The use of ICs is advantageous from a human factors perspective.
Grouping EALs under ICs will indicate to those who must use the EALs how an EAL (or several diverse EALs) is related to the plant condition of concern.
This will assist the emergency director in the use of judgement in making the correct event classification.
The lack of ICs for loss of fission product barriers is of particular concern to the staff.
It is important that personnel who perform event classification, and those who communicate the classification to offsite authorities, clearly understand the condition of each fission product barrier as reflected in the EAL. This association between barriers and EALs is not readily apparent in the Ginna methodology.
The lack of ICs in the licensee's classification scheme represents a
significant departure from the NUMARC guidance and is unacceptable.
The licensee should include ICs with their EALs to demonstrate the relationship between the EALs and their associated classification.
Absent from the R.E. Ginna IC and the supporting EAL were the NUMARC criteria of "Actual or Imminent" and "Using Actual Meteorology," The basis document included the criteria regarding meteorology, but would have to be referred to by a classifier in addition to a classification implementing procedure.
The licensee should assure that cross referencing requirements are minimized by including all necessary attributes of ICs and EALs in one location.
The licensee's failure to include a fission product barrier evaluation matrix constitutes a significant departure from the method'ology in NUMARC/NESP-007.
NESP-007 specifically included barrier evaluation in its classification methodology to compliment the symptomatic and event-based
- ICs, especially for the higher classifications.
The fission product barrier matrix provides multiple indicators to operators to assess the status of each of the barriers and classify the emergency based upon their integrity. The matrix
I also provides the ability to dynamically assess how far present conditions are from escalating to the next higher emergency class.
"For example, if Fuel Clad barrier and RCS barrier 'Loss'ALs existed, this would indicate to the Emergency Director thatin addition to offsite dose assessments, continual assessments of radioactive inventory and containment integrity must be focused on.
If, on the other hand, both Fuel Clad barrier and RCS barrier 'Potential Loss'ALs existed, the Emergency Director would have more assurance that there was no immediate need to escalate..."
The licensee has indicated that their proposed fission product barrier EALs reduce the burden on the operators in evaluating the fission product barriers, however, the use of nine separate categories of EALs by the licensee will still require someone to refer to several different categories to perform a dynamic assessment of the fission product barriers.
Further, the scheme is internally conflicting because of the multiple categories.
For example, if coolant activity was > 300 pCI/cc DEI-131 and primary system leakage was
) 46 gpm, either of these conditions would be an Alert per the licensee's EAL tables.
However, the collective failures would not necessarily result in a site area emergency (SAE) declaration, as is required by NUMARC criteria.
In the bounding analysis that was performed to evaluate the numerous combinations of conditions of the three fission product barriers, several assumptions were made that were not adequately justified or led to the elimination of some combinations that were bounded by the condition.
For example, under the remarks section of the Ginna Fission Product Barrier EAL Evaluation:
3.
The initiation signal for containment isolations are result of an RCS breach.
Containment isolation signals can also occur due to loss of containment cooling or a faulted steam generator.
4.
In order to reach containment-red on the CSI=ST, containment design pressure has been reached or exceeded... Itis not possible to reach this condition without beingin a Heat Sink-Red or Core Cooling-RED CSI=ST...
No technical supporting information was provided to support the assertion that a core cooling or heat sink RED path must exist.
The licensee also did not adequately demonstrate that this condition is indicative of a loss of the fuel clad barrier.
10.
A Core Exit Thermocouple reading greater >700'F with reactor vessel water level below the top of active fuel requires entry to the Core Cooling-RED CSFST and warrants declaration of a General Emergency...
Entry into a Core Cooling-RED path also requires the loss of all RCPs and is not indicative of a potential loss of containment.
Therefore, declaration of a General Emergency would be unwarranted, 11.... Thus, entryinto Core Cooling-Red requires declaration of a General Emergency...
The NUMARC guidance for a potential loss of the containment due to degradation in the Core Cooling CSF specifically requires that functional recovery procedures have been ineffective for 15 minutes.
Severe accident analyses have concluded that function restoration procedures can arrest core degradation within the reactor vessel in a significant fraction of the core damage scenarios, and that the likelihood of containment failure is very small in these events, Therefore, it is appropriate to provide a reasonable period of time to allow function restoration procedures to arrest the core melt sequence.
Whether or not the procedures will be effective should be apparent within 15 minutes.
12.
Core Cooling-Orange on the CSFST represents a potential loss of the fuel clad barrier and a loss of subcooling which is indicative of a loss of the RCS barrier...
The "Loss" EAL for the RCS barrier in NUMARC/NESP-007 that addresses RCS leakage is under the heading "RCS Leak Rate."
The wording is "RCS leak rate GREATER than makeup capacity as indicated by a loss of RCS subcooling,"
In NUMARC's technical basis it states that "loss of subcooling is a fundamental indication that the inventory control systems are inadequate in maintaining RCS pressure and inventory against the volume loss through the leak." Thus, loss of subcooling is a valid indicator for the loss of the RCS barrier ~wh n an R
I k
ndi i n xi NUMARC does not state that loss of subcooling can only occur due to a loss of the RCS pressure boundary as is implied by the statement above..The licensee must technically justify that a loss of subcooling can only occur when there is a breach'f the RCS barrier.
22.
This combination of conditions would produce a containment radiation level at least at the level of EAL¹ FC5. 1.
Therefore, this combination of conditionsis unnecessary and can be deleted.
The'NUMARC guidance has been developed to specifically provide for multiple redundant indications of loss or potential loss of the three fission product barriers.
It is unacceptable to'simply eliminate a combination of conditions because of its redundancy to other EALs.
23."
EAL¹ FC6. 1 is equivalent to... Therefore, this combination is unnecessary and can be deleted.
This comment applies to the combination of a loss of the RCS barrier as indicated by containment radiation monitor readings and a loss of the fuel clad as indicated by other site-specific indications.
The licensee has eliminated it based upon its redundancy to an containment radiation monitor EAL for loss of the RCS and Fuel Clad.
As stated in the previous comment, it is unacceptable to simply eliminate a combination of conditions because of its redundancy to other EALs,"
45.
Any combination of PC4.
1 and either of the following: FC2. 1, FC3. 1, FC5. 1, or FC6. 1 warrants declaration of a General Emergency...
PC4.1 states, "Release of secondary side to atmosphere with primary to secondary leakage greater than tech spec allowable." This condition is not reflective of a loss or potential loss of the RCS barrier.
- Thus, declaration of a General Emergency would not be warranted in conjunction with a loss of the fuel clad.
Both the NUIVIARCguidance and Appendix E to 10 CFR Part 50 require the use of multiple indicators for evaluating plant conditions.
The licensee should consider a different format (barrier analysis) for the fission product barrier EALs that maximizes the number of parameters or indicators available, minimizes the time to classify, and assures multiple conditions are readily evaluated and properly classified.
4.
In several instances that are specifically commented on, the licensee has departed from the NUMARC guidance of basing classifications upon observing the integrity of the three fission product barriers, and made classifications based upon one indicator, especially in the case of Critical Safety Function Status Tree (CSFST) status.
For example, if the CSF for containment is on a Red Path, a General Emergency is declared.
This approach is inconsistent with NUIVIARC guidance that requires evaluation of each barrier.
The licensee should assure that all barriers are evaluated when
gl I
I arriving at a classification rather than simply observing one status indicator.
This comment relates to the comment above.
5.
The technical bases for those site-specific EALs proposed by the licensee concerning secondary side releases consider the condenser air ejector as a potential release pathway.
The "Questions and Answers" on NUMARC/NESP-007, published in June 1993, specifically exclude the condenser air ejectors as a prolonged secondary side release pathway.
The licensee should provide justification for including this pathway as a discriminator for those EALs or revise their technical bases to eliminate the reference.
6.
In several EALs proposed by the licensee, entry into a Core-Cooling ORANGE or RED path was considered to be at least a potential loss of the RCS barrier.
However, the core-cooling critical safety function was not considered by NUMARC/NESP-007 as a discriminator for the RCS barrier integrity and its use by the licensee was not adequately justified. The licensee should provide additional information that clearly demonstrates that a Core-Cooling ORANGE or RED path is indicative of a failure of the RCS barrier or revise those EALs that incorporate this concept to be consistent with the NUMARC guidance.
EAL SPECIFIC COMMENTS These comments are organized by the recognition categories defined by NUMARC/NESP-007.
NUIVIARC Reco ni ion Ca e or R - Abnormal Rad Levels Radiolo ical Effluen 1,
The NUMARC example AU1-1 states in part:
"A valid reading on one or more of the following monitors that exceeds the 'value shown'site-specific monitorsJ indicates that the release may have exceeded the above criterion andindicates the need to assess the release with /site-specific procedure):"
(site-specific list)
Note:
Ifthe monitor reading/sf is sustained for longer than 60 minutes and the required assessments cannot be completed within this period, then the declaration must be made based on the valid reading. "
The licensee equivalent EAL for effluent monitors, Unusual Event, 5.1.1
. states in part:
"A valid reading on any,monitors table 5. 1 column 'NUE'or ) 60 min."
NUMARC specifies that a site specific procedure be used to assess the release.
The licensee's PEG provided procedures for release assessment, but these procedures were not incorporated into the EALs nor included in the technical bases.
The NUIVIARCnote regarding declaration if the assessment is not accomplished within 60 minutes was not included in the EAL, but was discussed in the technical bases.
It is important that a dose assessment is performed using actual meteorology and a best estimate of the actual radionuclide mix to determine if the effluent release will lead to escalation 'of the emergency due to adverse conditions.
The licensee should revise this EAL to achieve consistency with the NUMARC criteria, or provide technical justification for the deviation.
2.
The NUMARC example AA1-1 states in part:
"A valid reading on one or more of the followingmonitors that exceeds oris expected to exceed the value shown indicates that the release may have exceeded the above criterion andindicates the need to assess the release with [site-specific procedure/:
fsite-specific list)
Note:
Ifthe monitor readingfsJ is sustained for longer than 15 minutes and the required assessments cannot be completed within this period, then the declaration must be made based on the valid reading. "
The licensee equivalent EAL for effluent monitors, Alert, 5.1.2 states in part:
"A valid reading on any monitors table 5.1 column "Alert"for ) 15 min. "
NUMARC specifies that a site specific procedure be used to assess the release.
The licensee's PEG provided procedures for release assessment, but these procedures were not incorporated into the EALs nor included in the technical bases.
The NUMARC note regarding declaration if the assessment is not accomplished within,15 minutes was not included in the EAL, nor discussed in the technical bases.
It is important that a dose assessment is performed using actual meteorology and a best estimate of the actual radionuclide mix to determine if the effluent release will lead to escalation of the emergency due to adverse conditions.
The licensee should revise this EAL to achieve consistency with the NUMARC criteria, or provide technical justification for the deviation.
~ 3, The NUMARC criteria for Initiating Condition AA3 states in part:
"Release ofradioactive material orincreasesin radiation levels within the facility that impedes operation of systems required to maintain safe operations or to establish or maintain cold shutdown. "
The licensee equivalent EAL for Area Radiation Levels, Alert, 5.3.3 states in part:
"Sustained abnormal area radiation levels ) 8 Rlhr within any areas, Table 5.3 ANO Access is required for safe operation or shutdown. "
The licensee's EAL did not include the NUMARC criteria for establishing or maintaining cold shutdown conditions.
The referenced table 5.3 was not included in the EAL, but was in the technical bases, The licensee should revise this EAL to be consistent with the NUMARC criteria and provide the referenced table in the EAL or provide technical justification for the deviation.
4.
The NUMARC example AS1-1 states in part:
"A valid reading on one or more of the followingmonitors that exceeds oris expected to exceed the value shown indicates that the release may have exceeded the above criterion andindicates, the need to assess the release with (site-specific procedureJ:
(site-specific listJ Note:
Ifthe monitor reading(sJ is sustained for longer than 15 minutes
~
and the required assessments cannot be completed within this period, then the declaration must be made based on the valid reading. "
The licensee equivalent EAL for effluent monitors, Site Area Emergency, 5.1.3 states in part; "A valid reading on any monitors table 5. 1 column "SAE" for ) 15 min. "
NUMARC specifies that a site specific procedure be used to assess the release.
The licensee's PEG provided a procedure for release assessment, however, this was not incorporated into the EALs. The NUMARC note regarding declaration if the assessment is not accomplished within =15 minutes was not included in the EAL and not discussed in the technical bases.
The effluent setpoints for the site area emergency EAL are based upon FSAR source terms and average annual meteorology and, therefore, may significantly differ from the actual release conditions.
Thus, escalation to a site area emergency due to effluent releases should be based upon an assessment of potential offsite doses as determined by actual source term and meteorology.
The primary purpose of the effluent setpoint is to trigger this assessment, not to upgrade the emergency class.
Classification through use of the effluent monitor reading alone is only expected when dose
'assessments can not be completed within the required time.'he licensee should revise this EAL to achieve consistency with the NUMARC criteria, or provide adequate justification for the deviation.
The licensee should also provide information on the source term(s) utilized to determine the values in table 5.1.
The NUMARC criteria for Initiating Condition AG1 states in part:
"Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity that Exceeds 1000 mR Whole Body or 5000mR Child Thyroid for the Actual or Projected Duration of the Release Using Actual Meteorology. "
The licensee equivalent EAL for effluent monitors, General Emergency, 5.2.5 states in part:
"Dose projections or field surveys which indicate doses / dose rates )
Table 5.2 column 'GE't the site boundary or beyond."
NUMARC specifies the use of actual meteorology for the dose projections.
The licensee EAL did not reflect the use of actual meteorology for dose projections, however the licensee discussed the requirement for use of actual meteorology in the technical bases, The licensee should revise this EAL to achieve consistency with the NUMARC criteria, or provide adequate justification for the deviation.
6.
The NUMARC example AG1-1 states:
K "A valid reading on one or more of the followingmonitors that exceeds oris expected to exceed the value shown indicates that the release may have exceeded the above criterion andindicates the need to assess the release with (site-specific procedureJ:
w fsite-specific listJ Note:
Ifthe monitor reading fsJ is sustained for longer than 15 minutes and the required assessments cannot be completed within this period, then the declaration must be made based on the valid reading. "
The licensee equivalent EAL for effluent monitors, General Emergency, 5.1.4 states in part:
"A valid reading on any monitors table 5. 1 column "GE" for ) 15 min. "
NUMARC specifies that a site specific procedure be used to assess the release.
The licensee's PEG provided a procedure for release assessment which was not incorporated into the EALs. The NUMARC note regarding
'declaration if the assessment is not accomplished within 15 minutes was not included in the EAL nor discussed in the technical bases.
The effluent setpoints for the general emergency EAL are based upon FSAR source terms and average annual meteorology and, therefore, may significantly differ from the actual release conditions.
Thus, escalation to a general emergency due to effluent releases should be based upon an assessment of potential offsite doses as determined by actual source term and meteorology.
The primary purpose of the effluent setpoint is to trigger this assessment, not to upgrade the emergency class.
Classification through use of the effluent monitor reading alone is only expected when dose assessments can not be completed within the required time.
The licensee should revise this EAL to achieve consistency with the NUMARC criteria, or provide adequate justification for the deviation.
The licensee should also provide information on the source term(s) utilized in determining the values of table 5,1.
UIVIARC Re o ni i n C e
r F - Fission Produ t Barri r D ra ion 7.
The licensee's EAL 4.1.3, "Containment Integrity Status," states:
Either:
CI or CVI valvefsJ not closed when required following a confirmed LOCA OR Inability to'isolate any primary system discharging outside containment AND Radiological release pathway to'he environment exists The relationship between Cl and CVI valves was not explained in the technical bases to demonstrate how a failure of either one to close will provide a pathway outside containment.
The licensee should provide information on these two systems and their interfaces, if any.
The licensee should provide information on the entry conditions for a LOCA to demonstrate these entry conditions are commensurate with a potential loss or loss of the RCS barrier.
The second argument does not provide a threshold for the amount of primary system leakage outside containment.
The licensee should include a threshold that operators can utilize to evaluate this argument against the guidance in NUMARC/NESP-007 for a loss or potential loss of the RCS barrier.
The NUMARC criteria for "Fuel Clad Barrier Example EALs" (Table 4, Fission Product Barrier Reference Table), "1. Critical Safet Func ion Status" states in part:
LOSS POTENTIAL LOSS Core Cooling-Red Core Cooling-Orange OR Heat Sink-Red NUMARC Table 4 also states:
ALERT:
ANYLoss or ANYPotential Loss of EITHER Fuel Clad OR RCS SlTE AREA EMERGENCY:
Loss of BOTH Fuel Clad AND RCS OR Potential Loss of BOTH Fuel Clad AND RCS OR Potential Loss of EITHER Fuel Clad OR RCS, and Loss ofANYAdditional Barrier" The licensee equivalent EAL, CSFST status, 1.2 Core Cooling for SAE states in part:
"ORANGEor RED'path in F-0.2, CORE COOLING" The phrase "ORANGE or RED path in F-0.2, CORE COOLING," was inconsistent with the text of NUMARC Table 4 in that an Orange or Red path for core cooling was not considered in the guidance as a loss or potential loss of the RCS barrier.
The basis document provided the following justification for this departure:
"CSFST Core Cooling - ORANGE path is entered based on either:
OR Core exit thermocouples ) 700'F RVLIS level ( 43% wl no RCPs (TAF)
Either condition indicates subcooling has been lost and that some clad damage may occur.
It must also be assumed that the loss of RCS inventory is a result of a loss of RCS barrier, Therefore a Site Area Emergency is warranted based upon the potential loss of fuel clad with loss of RCS barriers."
The assumption that the RCS barrier is lost when a Core-Cooling Orange or Red path exists was not adequately justified, The licensee should provide additional justification to show that the additional conservatism afforded by relying on the singular CSF of this EAL clearly demonstrates a challenge to both the RCS and Fuel Clad barriers, or modify the EAL scheme to be consistent with the NUMARC criteria.
9.
The NUMARC criteria for "Fuel Clad Barrier Example EALs" (Table 4, Fission Product Barrier Reference Table), "4. R ac or Ve s I Wa er L vel," states in part:
LOSS Not applicable POTENTIAL LOS Level LESS than I'site-specific/
value NUMARC Table 4 also states:
ALERT:
ANYLoss or ANYPotential Loss of EITHER Fuel Clad OR RCS" The licensee equivalent EAL, Category 3.0, Reactor Coolant System, for SAE 3.1.3 states in part:
"RVL1S cannot be maintained ) 43% with no RCPs running OR With the reactor vessel head removed, itis reported that water levelin the reactor vesselis droppingin an uncontrolled manner and core uncoveryis likely. "
LQMMTt hb f
h KALI'ldbig*dd.h NUMARC criteria provides for declaration of an Alert on loss of one barrier, i.e., when water level drops to top of active fuel., The licensee's EALs required a declaration of a SAE. This inconsistency with the NUMARC criteria was not technically justified in the Bases Document.
Furthermore, the licensee treated reactor vessel level as an EAL reflecting Reactor Coolant System integrity, whereas the NUMARC criteria utilizes level as a fuel integrity EAL. The licensee should provide additional justification to show that the added conservatism afforded by relying on the singular EAL of reactor vessel water level for declaration of a Site Area Emergency is warranted, or modify the EAL scheme to be consistent with the NUMARC criteria.
10.
Table 4 in NUMARC/NESP-007. requires the declaration of a General Emergency when there is:
Loss ofANYTwo Barriers AND Potential Loss of Third Barrier The licensee's EAL 4.2.2, "SG Tube Rupture wl Secondary Release," states that a General Emergency will be declared when:
Release ofsecondary side to atmosphere with primary to secondary leakage ) 0.1 gpm per steam generator AND Anyindicators of fuel clad damage, Table 4.2 This EAL provides indications of loss of the fuel clad barrier and loss of the containment barrier.
The licensee's use of 0.1 gpm primary to secondary leakage as an indication of a potential loss of the RCS barrier was not adequately justified. The licensee should provide additional information that demonstrates the adequacy of this threshold for potential loss of the RCS or revise the EAL to be consistent with the NUMARC guidance.
11.
The NUMARCcriteria for "Containment Barrier Example EALs" (Table 4, Fission Product Barrier Reference Table), "1. Cri ic I S fe F nc i n
~S~," states in part:
LOSS Not applicable POTENTIAL LOSS Containment-Red NUMARC Table 4 also states:
I UNUSUAL EVENT:
ANYLoss or ANYPotential Loss of Containment" The licensee-equivalent EAL, CSFST status, 1.5 Containment for GE states in part:
"RED path F-0.5, CONTAINMENT" The bases document states in part:
"CSFST Containment - RED path is entered based upon exceeding containment design pressure of 60 psig.
This pressure is well in excess of that expected from the design basis loss of coolant accident.
This is indicative of a loss of both RCS and fuel clad boundaries in that it is not possible to reach this condition without also being in a Heat Sink-RED or
- Core Cooling-RED CSFST."
L1 Section 3.9 of the NUMARC discussion concerning Emergency Action Levels states in part:
"It reasonably follows that if any CSF enters a RED path, a site area emergency exists.
Thus it is acceptable to provide an EAL that is inconsistent with Table 4 (i.e., a SAE vs. UE), but conservatively anticipatory since the containment function on a Red Path is '... an extreme challenge to a plant function necessary for the protection of the public...'owever, as the licensee stated in the basis document, it is not possible to reach this condition without other indicators.
Classifications based upon the NUMARC guidance are not made based upon sole indicators such as "CSFST Containment - RED," but rather a combination of indicators.
Therefore, the licensee should provide additional justification to show that the added conservatism afforded by relying on the singular CSF of this EAL for declaration of a General Emergency is warranted, or modify the EAL scheme to consistency with the NUIQARC criteria.
This comment also applies to EAL 4.3.1, "Combustible Gas Concentrations."
12.
The licensee's PEG bases for RCS Leak Rate, RCS 2.2 states in part:
"... two charging pumps are required for normal liquid inventory control."
The PEG bases for SG Tube Rupture, RCS 3.2 states in part:
"... one charging pump is required for normal inventory control."
The licensee should correct the inconsistency and assure that any deviation from the NUMARC criteria of exceeding the capacity of one charging pump in the normal charging mode are technically justified.
13.
The licensee used Table 4.1, Fuel Clad Loss Indicators, and Table 4.2, Fuel Clad Damage Indicators, in the EALs as follows:
Table 4. 1 Fuel Clad Loss indicators 1.
Coolant activity > 300 uCi/cc of I-131 2.
Containment rad monitor R-29/R-30 reading > 100 R/hr 3.
Letdown Monitor R-9 reading > 10 R/hr Table 4.2 Fuel Clad Damage indicators
~
ORANGE or RED path in F-0.2, CORE COOLING
~
RED PATHin F-0.3, HEATSINK
~
Coolant activity > 300 uCi/cc of I-131
~
Containment rad monitor R-29/R-30 reading > 100 R/hr
~
Letdown Monitor R-9 reading > 10 R/hr COMMENT The licensee's technical bases, as well as EALs, for general emergency, 4,1.4 referred to Table 4.1 as fuel clad "loss" indicators; general emergency, 4.1.5 referred to Table 4.2 as fuel clad "damage" indicators.
No distinction between "loss" and "damage" used in the EAL table titles was made.
The licensee should clarify the difference between fuel clad loss and fuel clad damage.
14.
The NUMARC'criteria for Fuel Clad and RCS Barrier Example EALs utilizing Containment Radiation Monitoring as the EAL thresholds state in part:
"FUEL CLAD BARRIER EXAMPLE EALs..."
"5. Con ainmen Radia ion Moni orin Containment rad monitor reading GREATER THAN (site-specific) Rlhr" "RCS BARRIER EXAMPLE EALs" "4.
n inm n Radi i n IVloni rin Containment rad monitor reading GREA TER THAN (site-specific) Rlhr" The equivalent R.E. Ginna EALs (Category 2.0, Reactor Fuel) state in part:
"2.3 Containment Radiation 2.3.1 Alert Containment radiation monitor R-29/R-30 reading ) 10 Rlhr 2.3.2 Site Area'Emergency Containment radiation monitor R-29/R-30 reading > 100 Rlhr 2.3.2 General Emergency Containment radiation monitor R-29/R-30 reading ) 1000 Rlhr" There were no equivalent Category 3,0 Reactor Coolant System EALs.
However, the PEG for the RCS Barrier EALs (RCS4.1) utilizing Containment Radiation Monit'oring as the EAL threshold states in part:
"Containment radiation monitoring reading greater than R/hr" 10 The PEG Bases information accompanying this EAL states in part:
"The ~10 R hr reading is a value which indicates the release of reactor coolant to the containment."
t The Technical Basis information for Category 2.0 Reactor Fuel, EAL 2.3.1, states in part:
"The 10 R/hr reading is a value which indicates the release of reactor coolant to the containment....
This EAL is indicative of a RCS leak only."
s No additional justification inforrpation was included in either of the bases information as,to why a RCS leak EAL was included in the Reactor Fuel category, and omitted from the Reactor Coolant System category.
C(
The licensee should include the NUMARC criteria for discerning reactor coolant system leaks utilizing containment radiation monitoring or provide justification for omitting it from the RCS category.
The licensee should also provide the site specific analyses for calculating these containment radiation monitor setpoints.
e 15.
The NUMARC criteria for Containment Barrier Example EALs utilizing Containment Radiation Monitoring as the EAL thresholds state:
CONTAINMENTBARRIER EXAMPLE EALs
- 5. Si nifi an Radi aciv
!nv n r in Con ainm n Containment rad monitor reading GREA TER THAN fsite-specificJ R/hr The equivalent R.E, Ginna EALs (Category 2.0, Reactor Fuel) stated:
2.3 Containment Radiation 2.3.1 Alert" Containment radiation monitor R-29/R-30 reading > 10 R/hr 2.3.2 Site Area Emergency Containment radiation monitor R-29/R-30 reading ) 100 R/hr
. 2.3.2 General Emergency Containment radiation monitor R-29/R-30 reading ) 1000 R/hr There were no equivalent Category 4.0 Containment EALs. However, the PEG for the Containment Barrier EALs (PC5.1) utilizing Containment Radiation Monitoring as the EAL threshold stated:
"Containment radiation monitoring reading greater than
~1000 R hr" The PEG and Technical Bases information accompanying this EAL stated:
"The ~1000 R hr reading is a value which indicates significant fuel damage well in excess of the EALs associated with both loss of fuel
'lad and toss of RCS barriers."
)1 Section 3.8 of the NUMARC discussion concerning Emergency Class Thresholds addressed the subject of significant radioactive inventory within containment is not possible unless a major fuel cladding failure has occurred, Thus it is possible to.consider accepting an EAL that is inconsistent with Table 4 (i.e., a GE vs. UE) for the same rationale as in Comment ¹9. That is, such an EAL is conservatively anticipatory since the containment with large radioactive inventory is ".. ~ an extreme challenge to a plant function necessary for the protection of the public..." However, as the licensee stated in the basis document, itis not possible to reach this condition without other indicators.
Classifications based upon the NUMARC guidance are not made based upon sole indicators such as Containment radiation monitor R-29/R-30 reading ) 1000 R/hr, but rather a combination of indicators.
The licensee should provide additional justification to show that the added conservatism afforded by relying on the singular radiation monitor reading of this EAL for declaration of a General Emergency is warranted, or modify the EAL scheme to be consiste'nt with the NUMARC criteria. The licensee should also provide the site specific analyses used to determine the containment radiation monitor setpoints, Reco ni ion C or M - S m Malfun i n 16.
The NUMARC example for SU4-1 states:
(Site-specific) radiation monitor readingsindicating fuel clad degradation greater than Technical Specification allowable limits.
The licensee equivalent EALs under 2.1.1, "Coolant Activity,"and 2.2.1, "Failed Fuel Detectors," state:
Coolant sample activity: 100% of 84/E-Bar lJCI'/cc total specific activity OR ) 0.2 pCI'/cc I-131 equivalent and the conditions of Tech. Spec.
- 3. 1.4.3b are exceeded.
and Letdown line monitor R-9 > 2 R/hr.
The licensee should provide additional information to justify the AND logic in the second argument of EAL 2.1.1.
The licensee should also demonstrate how EAL 2.2.1 is equivalent to EAL 2.1.1.
17.
NUMARC IC SS5, "Loss of Water Level in the Reactor Vessel That Has or Will Uncover Fuel in the Reactor Vessel," provides the following example EAL for declaration of a Site Area Emergency:
Loss of Reactor Vessel INater Level asindicated by:
Loss of all decay heat removal cooling as determined by (site-specificJ procedure.
ANO b.,
(Site-specific) indicators that the coreis or willbe uncovered.
The licensee equivalent EAL under 2.4.3, "Refueling accidents or Other Radiation Monitors," states, for an Alert:
Report of visual observation ofirradiated fuel uncovered.
The licensee's technical basis for this EAL specifically includes declarations
'or fuel uncovery in the reactor vessel, This deviation from NUMARC was not justified. The licensee also did not include the anticipatory w'ording of NUMARC which requires declaration when indicators show that the fuel will be uncovered.
The licensee should provide justification for these deviations or revise the EAL to be consistent with the NUMARC guidance.
18.
The NUMARC examples AA2-3 and AA2-4 were not addressed in the licensee's classification scheme.
These example EALs state:
Water Level less than (site-specificJ feet for the Reactor Refueling Cavity that willresult in Irradiated Fuel Uncovery.
OR Water Level less than (site-specificJ feet for the Spent Fuel Pool and Fuel Transfer Canal that willresultin Irradiated Fuel Uncovery.
The licensee should include site-specific EALs for these examples or provide technical justification for their omission.
19.
The NUMARC example for SU1-1 states:
The following conditions exist:
- a. Loss ofpower to (site-specific J transformers for greater than 15 minutes.
AND
- b. At least (site-specificJ emergency generators are supplying power to emergency busses.
The licensee equivalent EAL for Loss of AC Power Sources, Unusual Event,
6.1.1 stated
I Loss of ability to supply power to the safeguard busses from offsite circuits 751 and 787 for ) 15 min.
The NUMARC criteria specifically requires a site specific minimum emergency generator supply to the emergency busses.
The licensee did not provide a site specific minimum emergency generator electrical supply to the emergency busses in the EAL. The PEG specified that both emergency diesel generators are capable of supplying power to the safeguard busses.
The NUMARC criteria requires that emergency generators are actually supplying power.
The licensee should provide additional justification for the deviation from the NUMARC criteria or revise this EAL to achieve consistency.
20.
The NUMARC example SU7-1 states:
Either of the following conditions exist:
a.
Unplanned los's of vital DC power to required DC busses based on (site-specific J bus voltage indications.
AND b.
Failure to restore power to at least one required DC bus within 15 minutes from the time of loss.
The licensee equivalent EAL for loss of DC power, Unusual Event, 6.2.1 stated:
< 105 vdc bus voltage on 125 vdc batteries 1A and 1B for > 15 min.
The NUMARC criteria specifies that the loss of DC voltage is unplanned.
This EAL applies to cold shutdown and refueling, and planned work that de-energizes the DC busses should not trigger a declaration.
The licensee should revise this EAL to achieve consistency with the NUMARC criteria or provide technical justification for the deviation.
21.
The NUMARC example SA1-1 states:
The following conditions exist:
a.
Loss ofpower to (site-specificJ transformers AND b.
Failure of (site-specificJ emergency generators to supply power to emergency busses.
AND c.
Failure to restore power to at least one emergency bus within 15 minutes from the time of loss offsite and onsite power.
The licensee equivalent EAL for Loss of AC Power Sources, Alert, 6.1,2 stated:
Loss of all safeguards bus ACpower for > 15 min.
The NUMARC criteria specifies a site specific list of transformers and generators.
The licensee did not provide a site specific list in this EAL, but did specify the site specific power requirements in the PEG.
The licensee should revise this EAL to achieve consistency with the NUMARC criteria or provide technical justification for the deviation.
22.
The NUMARC example SA2-1 states:
(Site-specificJ indication(sJ exist thatindicate that reactor protection system setpoint was exceeded and automatic scram did not occur, and a successful manual scram occurred.
The licensee equivalent Initiating Condition in the PEG stated:
SA2 Failure of Reactor Protection system instrumentation to
- complete orinitiate an automatic reactor ceram
~tri once a Reactor Protection system setpoint has been exceeded andlor manual acr ~ ~ri was not successful.
The licensee equivalent EAL, CSFST status, 1.1.1 Alert stated:
ORANGE or RED path F-0. 1 SUBCRITI/CAL/TYAND Emergency boration is required.
The licensee Initiating Condition and EAL deviated from the NUMARC criteria.
NUMARC bases the Alert on the failure of the automatic protection system to respond to the established setpoint.
The licensee added the additional, inappropriate condition that a manual scram was also ineffective, which should escalate the event to a SAE. The licensee's technical basis
- states, This EAL addresses any manual trip or automatic trip signal followed by a manual trip which fails to shut down the reactor to an extent requiring emergency boration.
The licensee identified this difference as a deviation in the PEG but did not provide justification for the deviation in the technical bases.
, ~
The licensee should revise this EAL to achieve consistency with the NUMARC criteria or provide technical justification for the deviation, For additional guidance on this IC the licensee should reference the "Questions and Answers" on NUMARC/NESP-007, published in June 1993.
23.
The NUMARC example SA3-1 states:
The following conditions exist:
a.,Loss of fsite-specificJ Technical Specification required functions to maintain cold shutdown AND b.
Temperature increase that either:
~
Exceeds Technical Specification cold shutdown temperature limit OR
,1 F,
~
Results in uncontrolled temperature rise approaching cold shutdown technical specification limit.
The licensee equivalent EAL for system failures, Alert, 7,2.4 stated:
Reactor coolant temperature cannot be maintained ( 200 'F The licensee EAL did not include the required technical specification functions to maintain cold shutdown and did not include the anticipatory philosophy related to an uncontrolled temperature
- rise, The licensee justified the omission of these attributes in the Technical Basis document with the statement: A reactor coolant temperatureincrease that approaches or exceeds the cold shutdown technical specification limit warrants declaration of an Alertirrespective of the availabi%'ty of technical specification required functions to maintain cold shutdown.
The concern of this EALis the loss of ability to maintain the plant in cold shutdown which is defined by reactor coolant temperature and not the operability of equipment which supports removal ofheat from the reactor.
Without the anticipatory declaration that would occur with the loss of shutdown functions or uncontrolled'rise in temperature, the EAL is inadequate.
Therefore, the licensee should modify the EAL to achieve consistency with the NUMARC criteria, or provide additional justification for the deviation.
24.
The NUMARC example SS1-1 states:
Loss of all offsite and onsite ACpower as indicated by:
a.
Loss ofpower to (site-specificJ transformers AND b.
Failure of (site-specific) emergency generators to supply power to emergency busses.
AND c.
Failure to restore power to at least one emergency bus within 15 minutes from the time ofloss offsite and onsite power.
The licensee equivalent EAL for Loss of AC Power Sources, SAE, 6.1.4 stated:
L Loss of'all safeguards bqs AC power for ) 15 min.
The NUMARC criteria specifies a site specific list of transformers and generators.
The licensee omitted a site specific list in the EAL, but did specify the site specific power requirements in the PEG.
The licensee should revise this EAL to achieve consistency with the NUMARC criteria or provide justification for the deviation.
25
~
The NUMARC example SS2-1 states:
fSite-specific J indication exist that automatic and manual scram were not successful.
The licensee equivalent EAL, CSFST status, 1.1.2 stated:
RED path F-0. 1 SUBCRITIICALITYAND either: Emergency boration is inoperable OR Power range not ( 5% within 15 min. ofinitiation of emergency boration.
I The Subcriticality Red Path is entered based upon failure of power range indication to decrease below 5% following a reactor trip. This condition by itself would be an adequate EAL except the licensee has added other conditions that were inconsistent with the NUMARC criteria. Therefore, the licensee should revise this EAL to achieve consistency with the NUMARC criteria, or provide adequate justification for the deviation.
sl 26.
The NUMARC example for SS4-1 states:
Complete loss of any (site-specificJ function required for hot shutdown.
The licensee equivalent EAL, RCS Leakage 1.3.1, for SAE stated:
RED path in F-0.3, HEATSINK
.The NUMARC criteria specifies complete loss of functions required for hot shutdown, including the ultimate heat sink and reactivity control.
The licensee EAL did not address the loss of functions required for hot shutdown.
Entry into the CSFST Red Path did not provide the anticipatory declaration that loss of functions would.
The licensee should revise this EAL to achieve consistency with the NUMARC criteria, or provide adequate justification for the deviation.
The licensee should also provide information on their disposition of the function of core cooling in relation to this IC.
27.
The NUMARC example SS5-1 states:
OPERA TING MODE APPLICABILITY: Cold Shutdown Refueling Loss of Reactor Vessel Water Level as indicated by:
a.
Loss of all decay heat removal cooling as determined by (site-specific) procedure.
AND b.
(site-specificJ indicators that the core is or willbe uncovered.
The licensee equivalent EAL, RCS Leakage 3.1,3 for SAE stated:
RVLIS cannot be maintained > 43% with no RCPs running.
OR With the reactor vessel head removed, itis reported that water levelin the reactor vesselis droppingin an uncontrolled manner and core unco veryis likely.
(Mode Applicability) All The NUMARC criteria specifies evaluation of decay heat removal for this event since the criteria applies, for the shutdown condition.
The licensee did not include this criteria in the EAL since the EAL was intended to apply to all operating modes.
However, the EAL was self-contradictory in that the mode applicability cannot be All... With the reactor vessel head removed.
Therefore, the licensee should revise this EAL to achieve consistency with the NUMARC criteria and clarity of meaning, or provide adequate justification for the deviation.
28.
The NUMARC example SS6-1 states:
The following conditions exist:
a.
Loss of (site-specificJ annunciators associated with safety systems.
AND b.
Compensatory non-alarming indications are unavailable.
AND c.
Indications needed to monitor (site-specificJ safety functions are unavailable.
~'l AND d.
Transient in progress.
The licensee equivalent EAL for Equipment Failures, SAE, 7.3.4 stated:
Loss of annunciators orindicators on any Control Room Panels, Table 7.3 AND Complete loss of ability to monitor all critical safety function status AND A plant transientin progress The NUMARC criteria specifies that Compensatory non-alarmingindications are unavailable.
Although the PEG reflected a "modified" EAL of LCsSd S
i/ dl, hi specificity was lost in the translation to the Technical Bases and the EAL Categories.
(Based upon limited information available, the reviewer had to assume the PPCS and SAS were not located on the panels of Table 7.3).
No justification was provided in the technical bases for the omission.
Therefore, the licensee should revise this EAL to achieve consistency with the NUMARC criteria and clarity of meaning, or provide adequate justification for the deviation.
29.
The NUMARC example SG1-1 states:
Prolonged loss of all offsite and onsite AC power asindicated by:
ae 0
Loss ofpower to (site-specificJ transformers.
AND b.
Failure of (site-specificJ emergency diesel generators to supply power to emergency busses.
AND C.
At least one of th'e following conditions exist:
~
Restoration of at least one emergency bus within (site-specific) hoursis NOT likely OR
~
(Site-specific J Indication of continuing degradation of core cooling based on Fission Product Barrier monitoring.
The licensee equivalent EAL for Loss of AC Power Sources, GE, 6.1.5 stated:
Loss of all safeguards bus AC power AND either:
Power cannot be restored to any safeguards bus in ~ 4 hrs OR ORANGE or RED path on F-0.2. "CORE COOLING" NUMARC employs the wording that Restoration......is NOT likely. The licensee used the wording Power cannot be restored....
The NUMARC "not likely" implies that as soon as it is known that power will not be restored the threshold has been exceeded, whereas the licensee "cannot" implies that power restoration must be a "known" quantity before a licensee declaration.
The NUMARC intent is that the condition is met as soon as it is known that power restoration is not likely within the specific time limit. Further, the licensee did not employ the concept of IMMINENTreferred to in NUMARC Table 4 and discussed in the NUMARC bases information for this Initiating Condition.
The NUMARC criteria specifies a site specific list of transformers and generators.
The licensee did not provide a site specific list in this EAL although site specific power requirements were specified in the PEG.
The licensee should revise this EAL to achieve consistency with the NUMARC criteria and clarity of meaning, or provide adequate justification for the deviation.
30.
The NUMARC examples SG2-1 and -2 state:
fSite-specificJ indications exist that automatic and manual scram were not successful.
ANO 2.
Either of the following:
a.
ISite-specificJ indications exist that the core cooling is extremely challenged.
OR b.
(Site-specific J indication exists that heat removalis extremely challenged.
The equivalent licensee EAL was found in Category 1,0, CSFST Status, 1.3.2 General Emergency, which stated:
REO pathin F-0.3, HEATSINK ANO REO path in F-0. 1, SU8CRITICALITY The NUMARC logic of core cooling OR heat removal was omitted from the licensees EALs (and the Technical Bases Document) notwithstanding that the logic was included in the PEG.
The licensee should revise this EAL to achieve consistency with the NUMARC criteria, or provide adequate justification for the deviation.
)
R o nii nC e
r H-Hazar sandOherC ndiions 31.
The NUMARC example HU1-3 states:
Assessment by the control room that an event has occurred.
The licensee equivalent EAL for Hazards, Unusual Event, 8,4,3 stated:
Assessment by Control Room personnel that a natural event has occurred precluding access to a plant vital area, Table 8.3.
The NUMARC criteria is unrestricted with the modifying verbiage precluding access to a plant vital area, Table 8.3.
The licensee restricts the declaration to natural events that preclude access to vital areas without justification in the technical bases.
The licensee should revise this EAL to achieve consistency with the NUMARC criteria, or provide adequate justification for the deviation.
32.
The NUMARC example HU4-1 and -2 states:
1.
Bomb device discovered within plant Protected Area and outside the plant VitalArea.
2.
Other security events as determined from (site-specificJ
The licensee equivalent EAL for Hazards, Unusual Event, 8.1.1 stated:
Bomb device or otherindication of attempted sabotage discovered within plant Protected Area.
The NUMARC criteria suggests that other security events which may potentially impact plant safety should be the subject of a declaration, however the additional EAL was omitted from the licensee's EAL category.
The Technical Bases Document stated, This EALis based on the REGNPS Security Contingency Plan.
Security events which do not represent at least a potential degradationin the level of safety of the plant are reported under 10 CFR 73. 71 orin some cases under 10 CFR 50. 72.
As written, the EAL did not permit an emergency declaration for other security events that ~ma represent a potential degradation of safety which is inconsistent with the NUMARC criteria.
This discussion is also applicable to the Alert and SAE EALs but will not be repeated.
The licensee should revise this EAL to achieve consistency with the NUMARC criteria, or provide adequate justification for the deviation.
33.
The NUMARC"example HA1-3 states:
3.
Report of any visible structural damage on any of the following plant structures:
~
Reactor Building
~
Intake Building etc.
The licensee equivalent EAL for Hazards, Alert, 8.4.7 stated:
Assessment by Control Room personnel that a natural event has resultedin damage to equipment needed for safe plant operation, Table 8.3.
The NUMARC criteria does not limit the threshold of declaration to resulted in damage to equipment needed for safe plant operation.
The intent of the NUMARC EAL is that if visible structural damage has occurred to the building, the event was significant and has a high potential for damage to
'quipment needed for safe plant operation.
The licensee's Technical Bases document recognized this potential with the following: This EAL addresses events that may have resultedin a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems.
However, this recognition did not carry through to the plant EAL. Anticipating the ~oen ial damage, the declaration should be made based upon visible structural damage, not Assessment.
~. damage to equipment needed... safe plant operation.
The licensee should revise this EAL to achieve consistency with the NUMARC criteria, or provide adequate justification for the deviation.
34.
The NUMARC example HA2-1 states:
The following conditions exist:
a.
Fire or explosion in any of the following (site-specificJ areas:
~
(site-specificJ list AND b.
Affected system parameterindications show degraded performance or plant personnel report visible damage to permanent structures or equipment within the specified area.
The licensee equivalent EAL for Hazards, Alert, 8,2.2 stated:
Fire or explosion in any plant area, Table 8.2 or Table 8.3 which results in damage to plant equipment or structures needed for safe plant operation.
The NUMARC criteria includes the condition that Affected system parameter indications show degraded performance.
The licensee EAL did not clearly convey this NUMARC criteria.
The licensee should revise this EAL to a'chieve consistency with the NUMARC criteria or technically justify the deviation, 35, The NUMARC examples HA3-1 and 2 state:
Report or detection of toxic gases within a Facility Structurein concentrations that willbe life threatening to plant personnel.
2.
Report or detection of flammable gases within a Facility Structure in concentrations that willaffect the safe operation of the plant.
The licensee equivalent EAL for Hazards, Alert, 8.3.5 stated:
Report or detection of toxic or flammable gases within a plant area, Table 8.3, in concentrations that willbe life threatening to plant personnel or preclude access to equipment needed for safe plant operation.
The licensee did not provide or reference measurable criteria to the emergency director for establishing concentrations that affect safe operation of the plant. Without such information readily available, classification would be difficult.
The licensee should provide measurable criteria to the classifier to determine when life threatening and flammable concentration thresholds have been exceeded.
36.
The NUMARC example HA5-1 states:
Entryinto (site-specific) procedure for control room evacuation.
The licensee equivalent EAL for Equipment Failures, Alert, 7.2.3 stated Control Room evacuation.
The NUMARC criteria specifically initiates the declaration at the time of entry into the control room evacuation procedure.
The licensee's EAL was not specific about the time of declaration and did not identify the procedure upon which declaration would be based, The licensee should revise this EAL to achieve consistency with the NUMARC criteria or provide technical justification for the deviation.
37.
The. NUMARC example HS2-1 states:
The following conditions exist:
a.
Control room evacuation has been initiated.
AND b.
Control of the plant cannot be established per (site-specificJ procedure within (site-specificJ minutes.
The NUMARC Basis information goes on to state: (Site-specificJ time for transfer based on analysis or assessments as to how quickly control must be reestablished without core uncovering andlor core damage.
This time should not exceed 15 minutes.
The equivalent licensee EAL, 7.2.5, SAE stated:
Control Room evacuation AND Core cooling cannot be established per AP-CR. 1 "Control Room Inaccessibility" in < 20 min.
The licensee Technical Bases Document stated:
The time interval for transfer is based, on analysis or assessments as to how quickly control must be reestablished without core uncovering and/or core damage.
REGNPS Appendix R submittalindicates that 20 minutesis the maximum time for which control ofplant safety systems should occur under worst case conditions.
If the revfewer understands tPe licensee's basis information correctly, the basis information states that under worst case conditions it could take up to 20 minutes to regain control of safety systems from remote shutdown facilities. This says nothing about whether core uncovering andlor core damage could occur during the transfer period.
The intent of the NUMARC guidance is that a declaration of SAE should be made after the time elapses where safety systems may be "unattended", and not incur uncovering and/or damage.
The licensee basis information did not indicate this unattended time, and the deviation of 20 minutes from the maximum criteria of 15 minutes was not adequately justified.
The licensee should revise this EAL to achieve consistency with the NUMARC criteria or provide technical justification for the deviation.
38.
The NUMARC examples HG1-1 and -2 state:
1.
Loss ofphysical control of the control room due to a security event (ORJ 2.
Loss ofphysical control of the remote shutdown capability due to a security event The licensee equivalent EAL for Hazards, GE, 8.1.4 stated:
Security event which resultin:
Loss ofplant control from the Control Room AND Loss ofremote shutdown capability The NUMARC criteria utilized OR logic for the EALs whereas the licensee utilized AND logic, This inconsistency with the NUMARC criteria was not justified in the Technical Bases Document.
The licensee should revise this EAL to achieve consistency with the NUMARC criteria or provide technical justification for the deviation.
Enclosure
OW p