ML17332A436
| ML17332A436 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 11/22/1994 |
| From: | John Hickman Office of Nuclear Reactor Regulation |
| To: | Fitzpatrick E AMERICAN ELECTRIC POWER SERVICE CORP., INDIANA MICHIGAN POWER CO. |
| References | |
| TAC-M89878, TAC-M89879, NUDOCS 9412010056 | |
| Download: ML17332A436 (29) | |
Text
Hr.
E.
E. Fitzpatrick, Vice President Indiana Hichigan Power Company c/o American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, OH 43215 November 22,
'4
SUBJECT:
REQUEST FOR ADDITIONAL INFORHATION REGARDING THE PROPOSED EHERGENCY ACTION LEVELS FOR DONALD C.
COOK NUCLEAR POWER
- PLANT, UNIT NOS.
1 AND 2 (TAC NOS.
H89878 AND H89879)
Dear Hr. Fitzpatrick:
By letter dated June 13,
- 1994, you submitted a proposed revision to the Emergency Classification System in the D.
C.
Cook Emergency Plan.
The revision was to incorporate emergency action levels based on the NUHARC methodology.
We have completed our initial review and request that you provide additional information, as discussed in the enclosed Request for Additional Information, so that we may complete our review.
Please advise me if you anticipate it will take more than 120 days to respond to these questions.
Please call me at (301) 504-3017, if you have any comments or questions.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OHB clearance is not required under P.L.96-511.
Sincerely, ORIGINAL SIGNED BY John B. Hickman, Project Hanager Project Directorate III-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos.
50-315 and 50-316
Enclosure:
As stated cc w/encl:
See next page DISTRIBUTION:
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Plant Service List DOCUHENT NAHE:
G:iWPDOCSiDCCOOKiC089878.RAI To receive a copy of thle document, indicate In the born C" ~ Copy without attachment/enclosure "E
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= No copy OFFICE LA:PDI II-1 C
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PD: PD I I I-1 NAHE DATE CJamerson II/lS/94 JHickman ll/iS/9 JHannon n/i 11/ZL/94 OFFICIAL RECORD COPY 800 94i201005b 94ii22 pDR
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E. Fitzpatrick Indiana Michigan Power Company CC:
Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, Illinois 60532-4351 Attorney General Department of Attorney General 525 West Ottawa Street
- Lansing, Michigan 48913 Township Supervisor Lake Township Hall Post Office Box 818
- Bridgman, Michigan 49106 Al Blind, Plant Manager Donald C.
Cook Nuclear Plant Post Office Box 458 Bridgman, Michigan 49106 U.S. Nuclear Regulatory Commission Resident Inspector Office 7700 Red Arrow Highway Stevensville, Michigan 49127 Gerald Charnoff, Esquire
- Shaw, Pittman, Potts and Trowbridge 2300 N Street, N.
W.
Washington, DC 20037 Mayor, City of Bridgman Post Office Box 366
- Bridgman, Michigan 49106 Special Assistant to the Governor Room 1
State Capitol
- Lansing, Michigan 48909 Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health Department of Public Health 3423 N.
Logan Street P. 0.
Box 30195
- Lansing, Michigan 48909 Donald C.
Cook Nuclear Plant Nr. S.
Brewer American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, Ohio 43215 Decanbcr 1993
RE E T F R ADDITI NAL INF ATI N RE ARDIN D.
K 1 2 N LEAR PLANT EAL REVISI N TO NUMAR NESP-007 METHODOLOGY The NRC has completed its initial review of the proposed emergency action levels (EALs) in the June 1994 D.C. Cook Nuclear Plant NUMARC EAL Submittal.
The Submittal included Emergency Plan Section 12,3.5, "Em r n
I ifica ion m" (Revision XX), the Letters of Concurrence from the State of Michigan and Berrien County, and the "D..
k N I
r Plan E-Pl n I s ifi i n v N
MAR NE P-7 0 vi i n B i
D men ". The licensee,didnotsubmit the actual Emergency Plan Implementing Procedure,
" 2-PMP 2
.EPP.1 1
Em r n
The proposed EALs were reviewed against the guidance in NUMARC/NESP-007, "Methodology for Development of Emergency Action Levels", Revision 2.
NUMARC/NESP-007 has been endorsed by the NRC in Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors", Revision 3, as an alternative means by which licensees can meet the requirements in 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50.
Since the staff has previously endorsed the guidance in NUMARC/NESP-007, the review focused on those EALs that deviated from the guidance and those EALs that required the development of site-specific thresholds.
As a result of the initial review, a number of EALs were identified which required additional information in order to determine whether the EALs conform with NUMARC/NESP-007.
Please provide this additional information as discussed below.
GENERAL The DC Cook EAL scheme deviates from the NESP methodology by not grouping EALs under ICs.
The Cook EAL scheme includes two separate tables; one table contains all the ICs and a second table contains all the EALs. In most cases the EALs are exact duplicates of the ICs. The separation of ICs and EALs under separate tables and the redundancy of many of the ICs and EALs is confusing, willmake classifying events more difficult, and is not justified from a human factors consideration.
Re-arrange the Cook EAL scheme to group EALs under IC or provide additional justification for the current proposed arrangement.
NUMARCRe niion e
A-Abn rm I R dL v I
adi I
i I Effl n
1.
The NUMARC Initiating Condition (IC) AU1 and EALs AU1-1 and AU1-2 are:
AU1 Any Unplanned Release of Gaseous or LiquidRadioactivity to the Environment that Exceeds Two Times the Radiological Technical Specifications for 60 Minutes or Longer.
AU1-2 Confirmed sample analysis for gaseous or liquidreleases indicates concentrations or release rates with a release duration of 60 minutes or longerin excess of two times (site-specific technical specifications/.
The D.C. Cook equivalent EALis:
ENCLOSURE D.C. COOK NUCLEAR PLANT
ECC: R-1 Effluents (UEJ Unplanned radioactive release lasting more than 60 minutes at 2 times the high alarm setpoint on VRS-1505 or VR-2505.
A. The D.C. Cook EAL did not include the "Note" specified in the NUMARC EAL. The assessment specified in this EAL to ensure that the release exceeds two times the technical specification value based on actual amount of radioactive effluents being released.
In addition this note is intended to prompt dose assessment using actual'meteorology to determine whether the Site Area or General Emergency radioactive effluent EALs are being exceeded.
Revise this EAL or provide additional justification for this deviation.
B. The D.C. Cook "Deviation Basis Document" (DBD) stated, "Generic EAL¹2involves analysis of samples.
The control room personnel are not required to review these sample results for technical specification compliance, so inclusion of this comparison as an FALis not beneficial based on our procedures for controlling radioactive effluents".
The NUMARC Basis defines the term "Unplanned" as "any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.J on the applicable permit". The D.C. Cook DBD and other documents submitted to the NRC did not define the meaning of the term "Unplanned"
~ The DBD did not explain why the control room operators are not responsible for monitoring effluent technical specifications (e.g., reference to NRC Generic Letter 89-01).
Even if effluent technical specifications have been eliminated at D.C. Cook, this does not justify elimination of an EAL equivalent to NUMARC AU1-2.
Provide justification for these deviations from the NUMARC/NESP-007 Guidance.
C. Additional information is need to determine the relationship between the setpoint for the radiation monitor,"2 times the high alarm setpoint," and the IC, "2 x technical specification limits."
ln addition, additional information is need to determine whether the radiation monitor specified in this EAL detects gaseous or liquid effluents. This information is needed to determine whether the D. C. Cook EAL deviates from the NUMARC guidance.
Provide additional information regarding the relationship of the EAL setpoint, i.e., "2 times the high alarm setpoint" and the IC of 2 times technical specification limits and whether this monitor is for liquid or gaseous releases.
Justify any deviations from the NUMARC guidance.
2.
The NUMARC EALs AU2-1, 2 5. 4 are:
Unexpected Increase in Plant Radiation or Airborne Concentration.
1.
(Site-specific/ indication of uncontrolled water level decreasein the reactor refueling cavity with a//irradiated fuel assemblies remaining covered by water.
2.
Uncontrolled water level decrease in the spent fuel pool and fuel transfer canal with all irradiated fuel assemblies remaining covered by water.
4.
Valid Direct Area Radiation Monitor readingsincreases by a factor of 1000 over normal" levels.
Normal levels can be considered as the highest readingin the past twenty-four hours excluding the current peak value.
The D.C. Cook equivalent EALs are:
ECC: R-2 In-Plant Rad Levels (UEJ D.C. COOK NUCLEAR PLANT
~ Unexpected radiation levels of:
~ > 2.5 mrlhrin either Control Room or the Central Alarm Station
~ > 15 mrlhrin Spent Fuel area
~ An uncontrolled water level decrease in an area holding irradiated fuel assemblies outside the reactor vessel.
A. The D.C. Cook EAl.s combine NUMARC EALs AU2-1 and AU1-2, but do not provide any site epecific indication (e.g., level instrumentation or visual indication of level). The D.C. Cook EALs also exclude fuel assemblies in the reactor vessel
~ The NUMARC Basis specifically discusses the purpose and background for these EALs as being related to actual Reactor Cavity Seal failures at PWRs during refueling operations.
The NUMARC Basis does not exclude fuel in the reactor vessel
~
As written, the D.C. Cook EAL would appear to apply only to fuel in the reactor cavity which was suspended on refueling equipment (i.e., extracted from the core area in the vessel), fuel in the transfer canal, and fuel in the spent fuel pool. The.DBD did not provide justification for eliminating fuel in the vessel from this EAL.
B. NUMARC EAL AU2-4 is intended to apply to areas throughout the plant.
The D.C. Cook EAL limits this EALto the Control Room, Central Alarm Station, and Spent Fuel Area. The DBD did not provide justification for restricting this EAL to the three stated areas, and for eliminating applicability to other in-plant areas.
Provide justification for these deviations from NUMARC/NESP-007 guidance.
Any Unplanned Release of Gaseous or LiquidRadioactivity to the Environment that Exceeds 200 Times Radiological Technical Specifications for 15 Minutes or l.onger.
1.
A valid reading on one or more of the following monitors that exceeds oris expected to exceed the value shownindicates 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(sl 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.
2.
Confirmed sample analysis for gaseous or liquidreleases indicates concentrations or release ratesin excess of (200 x site-specific technical specificationsJ for 15 minutes or longer.
D.C. COOK NUCLEAR PLANT
The D.C. Cook equivalent EALs are:
ECC: R-1 Effluents (Alert Unplanned radioactive release lasting more than 15 minutes at ) 4.0 x 1<7 uci/cc on VRS-1505 or VRS-2505.
A. The D.C. Cook EAL did not include the "Note" specified in the NUMARC EAL. The assessment specified in this EAL to ensure that the release exceeds 200 times the technical specification value based on actual amount of radioactive effluents being released.
In addition this note is intended to prompt dose assessment using actual meteorology to determine whether the Site Area or General Emergency radioactive effluent EALs are being exceeded.
Revise this EAL or provide additional justification for this deviation.
B. DC EAL appears to deviate from the NUMARC EAL by not including an EAL for liquid releases.
Provide justification for this apparent deviation.
C. As previously discussed under NUMARC EAL AU1-2, D.C. Cook eliminated the use of sample analysis (AA1-2) as an EAL without proper justification.
Provide a more detailed explanation of how the release concentration trigger point was calculated and justification for other deviations from the NUMARCINESP-007 guidance.
AA2 Major Damage to Irradiated Fuel or Loss of Water Level that Has or WillResult in the Uncovering ofIrradiated Fuel Outside the Reactor Vessel.
1.
A (site-specific set pointJ alarm on one or more of the following radiation monitors: (site-specific monitorsJ Refuel Floor Area Radiation Monitor Fuel Handling Building Ventilation Monitor Fuel Bridge Area Radiation Monitor 2.
Report of visual observation ofirradiated fuel uncovered.
3.
Water Level less than (site-specificJ feet for the Reactor Refueling Cavity that willresultin irradiated fuel uncovering.
4.
Water level less than (site-specificJ feet for the Spent Fuel Pool and Fuel Transfer Canal that willresult inirradiated fuel uncovering.
The D.C. Cook equivalent EALs are:
ECC: R-2 ln-plant Rad Levels
~ Unplanned decrease in water level that results in uncovery ofirradiated fuel assembly outside the reactor vessel.
ECC: R-3 Fuel Damage (AlertJ
~ Visualindication ofdamage to anirradiated fuel assembly AND valid high alarm on ANYof the following:
~ ERS-1301/1401/2301/2401
<<D.C. COOK NUCLEAR PLANT
~ ERS-1305/1405/2305/2405
~ VRS-1501/2501 A. The D.C. Cook DBD stated, "Generic EAL¹1is not used since there are not area monitorsin a/I regions where fuel uncovery can occur".
Provide details of the arrangement of area radiation monitors in the vicinity of fuel handling and storage areas and provide additional justification for not using these radiation monitors in an EAL under this IC.
B. The use of the word "Unplanned" in ECC R-2 is not in keeping with the intent of the NUMARC generic EAL.
Revise this EAL to be consistent with the NUMARC EAL or provide additional justification for this deviation.
C. As in prior D.C. Cook EALs associated with reactor cavity and spent fuel pool water level, R-2 deviates from the NUMARC guidance by not including instrumentation or visual level limits.
Provide additional justification for this deviation from the NUMARC/NESP-007 guidance.
D. D.C. Cook EAL R-3 combines a requirement (not suggested in the NUMARC generic EAL) that there be "visualindication of damage toirradiated fuel" combined, using an AND statement, with high alarms on any of several radiation monitors (which were claimed to be lacking as a justification for eliminating NUMARC generic EAL AA2-1). While the "visual indication" aspect of this EAL is satisfactory, and implied in the NUMARC generic IC, if not in the Generic EALs, combining the "visual indications" with the alarms is non-conservative.
Ifthis D.C. Cook EAL were split in two pieces, it would meet the basic intent of NUMARC generic EALs AA2-1 and AA2-2.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
'elease ofradioactive materia/ orincreases in radiation levels within the facility that impedes operation ofsystems required to maintain safe operations or to establish or maintain cold shutdown.
2.
Valid (site-specificJ radiation monitor readings GREA TER THAN <site-specific>
values in areas requiringinfrequent access to maintain plant safety functions:
(Site-specificJ list NOTE:
The Emergency Director should determine the cause of the increase in radiation levels and review other ICs for applicability.
The D.C. Cook equivalent EAL is:
ECC: R-2 In-plant Rad Levels (AlertJ
~ Unexpected radiation levels of:
~ > 15 mr/brin either control room or the Central Alarm Station
~ > 100 mr/hr genera/ areain Auxiliarybuilding hallways The intent of the NUMARC generic EAL was to "addressincreased radiation levels thatimpede D.C. COOK NUCLEAR PLANT
necessary access to operating stations, or other areas containing equipment that must be operated manually, in order to maintain safe operation or perform a safe shutdown".
The D.C. Cook DBD provides a list, on page 4 of 46, of such areas that "contain equipment necessary for the security or safe shutdown of the units" {e.g., auxiliary cable vaults, diesel generator rooms, auxiliary feedwater pump rooms, UPS battery and inverter rooms, etc.).
The DBD provides no explanation why the second bullet in this EAL was limited to radiation levels in Auxiliary building hallways.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
- 6. The NUMARC criteria for AS1-1, 3 5. 4 are:
Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds 100 mR I//ho/e Body or 500 mR Child Thyroid for the Actual or Projected Duration of the Release.
AS1-1 A valid reading on one or more of the following monitors that exceeds oris expected to exceed the value shownindicates that the release may have exceeded the above criterion andindicates the need to assess the release with (site-specific procedure J:
(site-specific listJ Note:
Ifthe monitor reading(slis 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.
AS1-3 Valid dose assessment capability indicates dose consequences greater than 100 mR whole body or 500 mR child thyroid.
AS1-4 Field survey resultsindicate site boundary dose rates exceeding 100 mFVhr expected to continue for more than one hour; or analysis of field survey samples indicate child thyroid dose commitment of 500 mR for one hour ofinhalation.
The D.C. Cook equivalent EAL is:
ECC: R-1 Effluents (SAEJ Projected site boundary dose greater than 100 mrem TEDE or 500 mrem CDE - OR - Field survey resultsindicate site boundary dose greater than 100 mremlhr Beta-Gamma during the release.
A. The D.C. Cook EAL scheme did not include an EAL corresponding to EAL AS1-1. The justification given was that dose assessment could not be performed within the first 15 minutes of the release.
Licensees are expected to have the capability to quickly perform dose assessments.
The effluent radiation monitor is a good indication of the severity of an event and should be used in an EAL. The setpoint of this EAL should be determined based upon annual average meteorology and a realistic source term.
Worst case meteorology was not specified to be used in calculating the setpoint for this EAL so that the events would not be classified at a higher classification level than is warranted.
In any case, it is anticipated that events would be classified based upon plant condition, e.g. fission product barriers, or upon dose assessments.
The radioactive effluent EAL should not be used for event classification unless for some unanticipated reason the plant conditions EAL does not result in the proper classification and dose assessment cannot be performed in a reasonable time.
B. The D.C. Cook EAL fails to add the NUMARC generic EAL¹3 words "thyroid dose" when referring to the 500 mrem CDE. The D.C. Cook EAL also fails to include the generic EAL¹4 criteria D.C. COOK NUCLEAR PLANT
of "fieldsurvey samples indicate thyroid dose commitment of 500 millimeter (CDEJ for one hour inhalation ".
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity Exceeds'000 mR Whole Body or 5000 mR Child Thyroid for the Actual or Projected Duration of the Release Using Actual Meteorology.
1.
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.
3.
Valid dose assessment capability indicates dose consequences greater than 1000 mR whole body or 5000 mR child thyroid.
4.
Field survey resultsindicate site boundary dose rates exceeding 1000 mlVhr expected to continue for more than one hour; or analysis of field survey samples indicate child thyroid dose commitment of 5000 mR for one hour ofinhalation.
The D.C. Cook equivalent EAL is:
ECC: R-1 Effluents (GEJ Projected site boundary dose greater than 1000 mrem TEDEor 5000 mrem CDE-OR - Field survey results indicate site boundary dose rate greater than 1000 mremlhr Beta-Gamma during the release.
The D.C. Cook DBD EAI Deviation statement for this EAL set read essentially identical to that for NUMARC generic EAL AS1.
AIIof the deviations discussed above under AS1 are applicable to AG1.
D.C. COOK NUCLEAR PLANT
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
SU1 Loss ofAllOffsreeIRower to Essential Busses for Greater Than 15 Minutes.
SU1-1.
The following conditions exist:
- a. Loss ofpower to (site-specificJ transformers for greater than 15 minutes.
AND
- b. At least (site-specificJ emergency generators are supplying power to emergency busses.
The D.C. Cook equivafent:EAL is:
ECC: S-2 Loss ofAC Power (UEJ NEITHER Switchyard NOR 69 KVpower supplies available for ) 15 minutes.
Modes: 1,2,3,4,5
.The D.C. Cook DBD stated, "Thereis no need to extend this to defueled (Mode 6J since our spent fuel coolingis redundant between units. Added ICIEAL to ECC: S-4 to address the loss of spent fuel cooling.
There was no need to state that DGs are supplying the emergency buses since coincident failure of DGs is clearly recognizable as a loss of allAC power which is Separately classified".
The basis for this EAL as stated in NUMARCINESP-007 is: "Prolonged loss of AC power reduces required redundancy and potentially degrades the level of safety of the plant by rendering the plant more mflnerable to a complete loss of AC power..."
The justification in the D.C. Cook DBD for not including mode 6 as an applicable mode for this EAL did not address the basis for the EAL.
Provide additional justiTication for not including mode 6 as an applicable mode for this EAL. In addition provide a more detailed description of the AC power distribution.
- 9. The NUMARC criteria for SU3-1 is:
Unplanned Loss ofAfost or AllSafety System Annunciation or Indication in the Control Room for Greater Than 15 Minutes.
1.
The following conditions exist:
Loss ofmost or all (site-specificJ annunciators associated with safety systems for greater than 15 minutes.
AND Compensatory non-alarmin gindications are available.
AND C.
In the opinion of the Shift Supervisor,",the loss of the annunciators orindicators requiresincreased surveillance to safely operate the unit(sJ.
AND D.C. COOK NUCLEAR PLANT
d.
Annunciator or Indicator loss does not result from planned action.
The equivalent D.C. Cook EAL is:
ECC: S-5 Loss ofAnnunciators or Indicators (UEJ Unplanned loss of all control room annunciators for ) 15 minutes BUT SPDS or PPCis OPERABLE.
The D.C. Cook IC Deviation statement stated, "Deleted reference to loss of "most" annunciators and loss ofall or mostindicators.
The loss of "most" annunciatorsis not plausible with our design.
The only single failure that affects a majority of the annunciators willcause the loss of "ALL" annunciators.
Loss ofindications was deleted from this IC because a major loss ofindications ICRIDsJ willalso render the compensatory non-alarmingindicationsinoperable (SPDSIPPCJ because Ioss of the CRIDs willdisable input to these systems also".
The D.C. Cook DBD did not provide a full discussion of the power supplies and inter-relationships of control indicators (CRIDs), SPDS, PPC, and Annunciators.
However, based upon DBD discussion, it would appear that the units could suffer a loss of most or all indication (CRIDs) and therefore SPDS and PPC, without a loss of annunciators.
While the NUMARC example EAL starts with a statement on loss of annunciators, the BASIS discussion clearly states that loss of either annunciators or indications are to be considered.
A more thorough discussion of the possible causes of loss of various sections of the safety system sections of the annunciator tiles is required in order to evaluate the licensee's claim that a loss of "most" annunciators is not plausible.
Provide additional information on annunciator and indicator design, and justification for the apparent deviation from NUMARC/NESP-007 guidance.
- 10. The NVMARCcriteria for SU7 is:
Unplanned Loss of Required DC Power During Cold Shutdown or Refueling Mode for Greater Than 15 Minutes.
1.
Either of the following conditions exist:
ao Unplanned loss of vital DC power to required DC busses based on (site-specificJ bus voltage indications.
OR b.
Failure to restore power to at least one required DC bus within 15 minutes from the time ofloss.
D.C. COOK NUCLEAR PLANT
The equivalent D.C. Cook EAL is:
ECC: S-3 Loss of DC Power Unplanned loss of 250V DC buses ABAND CD for ) 15 minutes Note: Lossis defined as < 210V DC A. The NUMARC BASIS discussion for "site specific" loss states, "Bus voltage should be based on the minimum bus voltage necessary for the operation ofsafety related equipment.
This voltage value shouldincorporate a margin ofat least 15 minutes of operation before the onset ofinability to operate those loads".
D.C. Cook added a 15 minute time requirement to their definition of loss of 250V DC buses.
No explanation was provided as to how the 210 volt figure was computed.
The intent of the NUMARC EAL is to initiate an emergency declaration at the voltage for which 15 minutes of load capacity remains, not to arrive at that voltage and then wait 15 minutes before making a declaration.
B. The D.C. Cook DBD provided no discussion of any lower voltage DC systems (e.g., 125V DC) which may serve safety related loads.
Additional information on D.C. Cook DC systems is necessary to evaluate the adequacy of the plant specific EAL.
Provide additional information on DC systems and justification for deviation from the NUMARC/NESP-007 guidance.
C. D.C. Cook added the following EAL:
Unplanned loss of SFP cooling for greater than 60 minutes in ALLmodes The SFP cooling EAL was added, according to licensee discussion provided under NUMARC generic EAL SU1 (Loss of All Offsite Power to Essential Busses for Greater Than 15 Minutes), in order to eliminate Mode 6 from the SU1 site specific EAL. The review (herein) of the D.C. Cook response to NUMARC SU1 stated that elimination of Mode 6 did not appear appropriate, given the potential for offsite power failures to affect both units.
Furthermore, the addition of this EAL using a 60 minute criteria is less conservative than the 15 minute criteria under NUMARC SU1.
The D.C.
Cook DBD statement under NUMARC SU1 implied that Mode 6 refers only to "DEFUELED";
Clarification of operating modes is required to complete evaluation of both the D.C. Cook response to NUMARC SU1 and this NUMARC EAL SU7 (e.g., is Mode 6 "DEFUELED" and/or "REFUELING",
and is Mode 5 "REFUELING" or "COLD SHUTDOWN").
Provide a detailed description of all D.C. Cook Operating Modes, and justification for these deviations from the NUMARC/NESP guidance.
- 11. The NUMARC example SA4-1 is:
Unplanned Loss of Most or AllSafety System Annunciation or Indication in the Control Room With Either (1J a Significant Transientin Progress, or (2J Compensatory Non-Alarming Indicators are Unavailable.
D.C. COOK NUCLEAR PLANT 10
1.
The following conditions exist:
ao Loss ofmost or all (site-specificJ annunciators associated with safety systems for greater than 15 minutes.
AND b.
In the opinion of the Shift Supervisor, the loss of the annunciators orindicators requiresincreased surveillance to safely operate the unit(sJ.
AND C.
Annunciator or Indicator loss does not result from planned action.
AND Either of the following:
1.
A significant plant transientisin progress.
OR 2.
Compensatory non-alarming indications are unavailable.
The equivalent D.C. Cook EAL is:
ECC: S-5 Loss ofAnnunciators or Indicators (AlertJ
~ Unplanned loss of three CRIDs
~ Unplanned loss of all control room annunciators for ) 15 minutes with either:
~ A transient in progress
~ SPDS and PPC are INOPERABLE Previously in the D.C. Cook DBD (under NUMARC SU3), the licensee claimed that, "Loss of indications was deleted from this IC because a major loss ofindication (CRIDsJ willalso render the compensatory non-alarmingindications inoperable (SPDSIPPCJ because loss of the CRIDs will disableinput to these systems also".
The NUMARC EAL, stated simply, would be met by one of two basic conditions: (1) Loss of annunciators AND Loss of Control Indications, SPDS, PPC, etc.,
or (2) Loss of annunciators AND a transient in progress.
The D.C. Cook EAL would require a loss of annunciators, and control room indication, and a transient in progress.
This D.C. Cook EAL, contrary to the licensee statement under NUMARC SU3, seems to imply that SPDS and PPC can continue to operate with a failure of CRIDs. As written, the D.C. Cook EAL is either non-conservative (if SPDS and PPC can continue to operate with a loss of CRIDs), or contains a logic error (if SPDS and PPC are rendered inoperable by CRIDs failure).
Provide additional information on the relationship of CRIDS, SPDS, and PPC, and justification of the apparent deviation from the NUMARC/NESP guidance.
D.C. COOK NUCLEAR PLANT
- 12. The NUMARC criteria for SS3-1 is:
Loss ofAllVitalDC Power.
1.
Loss ofAllVitalDC Power based on (site-specificJ bus voltage indications for greater than 15 minutes.
The equivalent D.C. Cook EAL is:
ECC: S-3 Loss of DC Power (Alertl Unplanned loss of 250V DC buses ABAND CD for ) 15 minutes Modes: 1.2,3,4 D.C. Cook has reduced the classification level of this NUMARC example IC/EALto an Alert. The Alert level EAL, S-3, has been discussed previously, as it relates to operation in Modes 5 and 6, under NUMARC generic EAL SU7.
In the D.C. Cook IC Deviation statement, the only apparent difference between Cook and other PWRs, might be the fact that D.C. Cook has inverters for the normal power supply to control room instrumentation.
As in the evaluation of the D.C. Cook response to NUMARC SU7, additional information on DC power supplies (e.g., 125V DC) is required to complete this evaluation.
The deviation statement should be written in terms of what sets D.C. Cook apart from other Westinghouse PWRs of the same vintage with respect to this NUMARC IC/EAL.
Provide additional information on DC power supplies, unique design features which set D.C. Cook apart from other Westinghouse PWRs, and justification for this deviation from the NUMARC/NESP guidance.
- 13. The NUMARC criteria for SS5-1 is:
Loss of Water Levelin the Reactor Vessel That Has or WillUncover Fuelin the Reactor Vessel.
1.
Loss of Reactor Vessel Water Level asindicated by:
a.
Loss of all decay heat removal cooling as determined by (site-specificJ procedure.
AND b.
(site-specificJ indicators that the coreis or willbe uncovered.
The equivalent D.C. Cook EAL is:
ECC: S-4 Loss of Shutdown Functions (SAEJ Loss of shutdown cooling with reactor vessel level decreasing and expected to drop below 613 ft 6inches.
Modes: 5,6 The D.C. Cook DBD did not relate the 613 ft 6 inches to Top of Active Fuel.
A measurement in feet referenced to sea level is typical of levels monitored during refueling.
Are there other level instruments which read out in reactor vessel reference while in Modes 5 and 6l Provide additional details on level instruments and how their levels relate to Top of Active Fuel ITAF).
D.C. COOK NUCLEAR PLANT 12
1.
The following conditions exist:
a.
Loss of (site-specificJ annunciators associated with safety systems.
AND b.
Compensatory non-alarmingindications are unavailable.
AND C.
Indications needed to monitor (site-specificJ safety functions are unavailable.
AND d.
Transient in progress.
The equivalent D.C. Cook EAL is:
EAL ECC: S-5 Loss ofAnnunciators or Indicators (SAEJ Loss ofALL CRIDS -OR-Loss ofall control room annunciators with concurrent loss of three CRIDs For the reasons previously discussed for the Unusual Event and Alert EALs for loss of annunciators, this EAL does not appear to be an appropriate criteria for indication of the inability to monitor a significant transient.
Revise this EAL to be consistent with the NUMARC guidance or provide information justifying this deviation.
HU1-1 (Site-specificJ method indicates felt earthquake.
The corresponding D. C. Cook EAL is:
ECC:N-1 EARTHQUAKE(UEJ Earthquake is readily felt but does not cause visible damage to plant structures The DC DBD did provide information regarding the plant seismic instruments and why indications from these instruments was not included in the EAL.
Provide information on the plant seismic instruments and justify not including indication from these instruments in this EAL.
- 16. The NUMARC criteria for HU5-1 is:
Other Conditions Existing Which in the Judgement of the Emergency Director Warrant, Declaration of an Unusual Event.
1.
Other conditions exist which in thejudgement of the Emergency Directorindicate a potential degradation of the level ofsafety of the plant.
D.C. COOK NUCLEAR PLANT 13
The D.C. Cook equivalent EAL is:
Cook IC: None
'"iCDeviation: This criterion applies all the time, so ithas been incorporatedinto the body of Iheimplementing procedure 12-PMP 2080.EPP.101, "Emergency Classification".
Instructions in the procedure direct the SEC to determine classification from the Recognition Category tables AND fromjudgement for every event with the highest classification prevailing."
The D.C. Cook Emergency Plan, Section 12.3.5, paragraph 12.3.5.3, contains an excellent discussion of SEC (Site Emergency Coordinator) judgement examples.
D.C. Cook did not submit the actual EPIP (12-PMP 2080.EPP.101) with this proposed EAL revision.
Provide verification that SEC judgement will be addressed and highlighted in the actual EPIP, or that it willbe incorporated in the actual EAL scheme.
Address similar deviations with NUMARC EALs HA6, HS3, and HG2.
HA 1-1 (Site-specificJ methodindicates felt earthquake.
The corresponding D. C. Cook EAL is:
ECC:N-1 EARTHQUAKE(AlertJ Earthquake causes visible damage to plant structures The DC DBD did provide information regarding the plant seismic instruments and why indications from these instruments was not included in the EAL.
Provide information on the plant seismic instruments and justify not including indication from these instruments in this EAL.
HA1-2 Tornado or high winds striking plant vital areas:
tornado or high winds greater than (site-specificJ mph strike within protected area boundary.
The corresponding D. C. Cook EAL is:
ECC:N-2 HIGH WINDS (ALERTJ Visible damage to plant structures The OC deviates by not including criteria on wind speed and by not specifying the location of the tornado strike, i.e. within the protected area boundary.
Revise this EALto conform with the corresponding NUMARC EAL or provide justification for this deviation.
HA1-6 Turbine failure generated missiles resultin any visible structural damage to or penetration ofany of the followingplant areas:
(site-specificJ list D.C. 'COOK NUCLEAR PLANT 14
The corresponding D. C. Cook EAL is:
ECC:N-7 EQUIPMENT OR STRUCTURAL FAILURE Visible damage to plant structures The DC deviates from the NUMARCguidance by not specifying turbine missiles and by not including the condition of missile penetration.
Provide justification for this deviation.
- 20. The NUMARC criteria for HA2-1 is:
Fire or Explosion Affecting the Operability of Plant Safety Systems Required to Establish or Maintain Safe Shutdown.
1.
The following conditions exist:
a.
Fire or explosion in any of the following (site-specificJ areas:
(site-specificJ list AND b.
Affected system paremeter indications show degraded performance or plant personnel report visible damage to permanent structures or equipment within the specified area.
The D.C. Cook equivalent EAL is:
ECC: H-1 Fire (Alert)
Fire affecting the operability ofsafety systems required for the current operating mode.
A. The licensee moved the reference to explosion to the Natural/Destructive Phenomena category.
This is addressed in the accompanying SER.
B. The D. C. Cook EAL deviates from the NUMARC guidance by not including the "site-specific areas" and by not including the "report visible damage to permanent structures or equipment within the specified area."
Provide justification for this deviation.
- 21. The Numarc criteria for HA4-1 5. 2 is:
Security Event in a Plant Protected Area.
1.
Intrusion into plant Protected Area by a hostile force.
2.
Other security events as determined from (site-specificJ Safeguerds Contingency Plan.
The D.C. Cook equivalent EALs are:
ECC: H-3 Security Events (Alertl
~ Intrusioninto the Protected Area by a hostile force.
~ Other security events whichindicate that plant safety systems may be degraded.
D.C. COOK NUCLEAR PLANT 15
The NUMARC BASIS for these EALs states, "Intrusion into a vital area by a hostile force will escalate this event to a Site Area Emergency".
The second bullet in the D.C. Cook EAL related to plant safety system degradation would include, in many cases, intrusion into a vital area (as defined by D.C. Cook on page 4 of 46 of the DBD) because many "safety systems" are located in vital areas.
Intrusion into a vital area is classifiable as a Site Area Emergency.
The DBD provided no discussion of how the Safeguards Contingency Plan, or notification by the site security force would be considered in this EAL, Provide justification for this deviation from the NUMARC/NESP-007 guidance.
The comment above concerning Safeguards Contingency Plan and advice from the security force also applies to NUMARC IC/EAL HS1.
- 22. The NUMARC criteria for HA6-1 is:
Other Conditions Existing Which in the Judgement of the Emergency Director Warrant Declaration ofan Alert.
1.
Other conditions exist whichin thejudgement of the Emergency Directorindicate that plant safety systems may be degraded and thatincreased monitoring ofplant functionsis warranted.
The D.C. Cook equivalent EAL is:
Cook IC: None IC Deviation: This criterion applies all the time, so it has been incorporatedinto the body of the implementing procedure "12-PMP 2080.EPP. 101, Emergency Classification ".
See discussion on this topic under NUMARC IC/EAL HU5 Provide justification similar to that requested for NUMARC IC/EAL HU5.
D.C. COOK NUCLEAR PLANT 16
- 23. The NUMARC criteria for HS2-1 is:
Control Room Evacuation Has Been Initiated and Plant Control Cannot Be Established.
1.
The following conditions exist:
a.
Control room evacuation has been initiated.
AND b.
Control of the plant cannot be established per (site-specific) procedure within (site-specific) minutes.
The D.C. Cook equivalent EAL is:
ECC: H-4 Control Room Evacuation (SAEJ Control Room evacuation has beeninitiated AND the Shift Supervisor determines that RCS inventory control has ~NTbeen established after 15 minutes.
Modes: All The NUMARC BASIS for this EAL states, "In cold shutdown and refueling modes, operator concern is directed toward maintaining core cooling such asis discussedin Generic Letter 88-17, "Loss of Decay Heat Removal".
/n power operation, hot standby, and hot shutdown modes, operator concernis primarily directed toward maintaining critical safety functions and thereby assuring fission product barrierintegrity". The D.C. Cook EAL limits control outside the control room to "RCS Inventory Control", thus ignoring the other critical safety functions.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
- 24. The NUMARC criteria for HS3-1 is:
Other Conditions Existing Which in the Judgement of the Emergency Director Warrant Declaration ofSite Area Emergency.
1.
Other conditions exist whichin thejudgement of the Emergency Directorindicate actual or likelymajor failures ofplant functions needed forprotection of the public.
The D.C. Cook equivalent EAL is:
Cook IC: None Provide discussion of this deviation when addressing NUMARC EALs HU5 and HA6.
- 25. The NUMARC criteria for HG2-1 is:
Other Conditions Existing Whichin the Judgement of the Emergency Director Warrant Declaration of General Emergency.
1.
Other conditions exist whichin thejudgement of the Emergency Directorindicate: (1J actual orimminent substantial core degradation with potential for loss of containment, or (2) potential for uncontrolled radionuclide releases.
These releases can reasonably be expected to exceed EPA PAG plume exposure levels outside the site boundary.
D.C. COOK NUCLEAR PLANT 17
The D.C. Cook equivalent EAL is:
Cook IC: None Provide discussion of this deviation when addressing NUMARC EALs HU5, HA6, and HS3.
NUMAR R co nition F - Fi ion Product Barrier FPB De rada ion
- 26. The NUMARCcriteria for Fuel Clad Barrier Example EAL¹ 1 is:
POTENTIAL: Core Cooling - ORANGE gR Heat Sink - RED The D.C. Cook equivalent EAL stated:
POTENTIAL: Core Cooling - ORANGE Heat Sink - RED - AND - Wide range level in at least 3 SGs is (29% (43% for adverse containmentJ The D.C. Cook DBD provided discussion on how the SGs will continue to act as a heat sink until wide range level is lost. Although absent from the DBD, the D.C. Cook FPB matrix does contain an OR statement for the two CSFs.
The generic Westinghouse EPGs for the HEAT SINK CSF require no SGs in the narrow range, and feedwater flow less than the safeguards AFW flow requirement for heat removal to equate to a RED path.
The D.C. Cook DBD did not make a statement as to whether they had deviated from the Westinghouse EPGs in formulating their plant-specific EOPs (I.e., do the EOPs contain this same caveat on SG wide range level in order to achieve a RED path on the HEAT SINK CSF?).
Provide justification for this deviation from the NUMARC/NESP-007 guidance in the form of discussion on criteria for the plant specific HEAT SINK RED path on the CSF Status Trees (CSFSTs), and by providing details on the relationship of wide to narrow range SG level instrumentation.
- 27. The D.C. Cook EAL scheme did not include EALs corresponding the following NUMARC EALs for the potential loss of fuel clad:
Core Exit Thermocouple Readings:
GREA TER THAN (site-specificJ degree F Reactor Vessel Water Level:
Level LESS THAN(site-specificJ value Ifeither of these NUMARC EALs are met the fuel clad is to be considered potentially lost. The D.C.
Cook DBD states that the core cooling CSFTST - ORANGE is equivalent to these EAL. However the generic core cooling CSFST requires both core exit thermocouples above a given setpoint and vessel water level below a given setpoint to get a ORANGE path.
Provide additional information regarding the relationship of the D.C Cook EAL and to the NUMARC EALs. Justify any deviations or revise the D.C. Cook EAL scheme to be consistent with the NUIVIARCEALs.
- 28. The NUMARC criteria for Fuel Clad Barrier Example EAL¹ 5 is:
FUEL CLAD EAL ¹5t Containment Radiation Monitoring D.C. COOK NUCLEAR PLANT 18
LOSS: Containment Rad monitor reading GREA TER THAN(site-specificJ R/hr POTENTIAL LOSS: Not applicable
'he D.C. Cook equivalent EAL is:
LOSS: Containment area radiation > 200 R/hr within first 90 minutes after accident:
~ VRS-1310/1410 (U1J
~ VRS-2310/2410 (U2J POTENTIAL LOSS: (none>
A. The D.C. Cook DBD provided the following EAL Deviation statement:
"We have applied a time limit on the use of containment radiation monitors because the radiation levels for a given amount of fuel damage willbe constantly decreasing with time.
In order to prevent the SS/SEC from having to refer to a time-plot ofradiation vs fuel damage, we have limited the viabi%'ty of this symptom and used the lowest radiation reading within that time frame associated with the level of core damage assumedin the generic guidance.
Therefore this symptomis not used on the Fission Product Barrier table associated with ICs".
The D.C. Cook EAL Deviation statement appears to contain questionable reasoning as follows: The only types of accidents for which their claim of "constantly decreasing radiation levels" is true are those for which most or all of the fuel or cladding damage occurs at the outset of the accident, combined with most or ail of the RCS inventory loss to containment also occurring early in the accident sequence.
One only need to review the containment radiation plots for the TMI accident to understand that the licensee's claim is questionable.
The only family of accidents for which the licensee's claim would apply are those involving discrete early fuel/clad damage and a large break LOCA. Thus the 90 minute time limit applying to the containment radiation levels should be eliminated.
B. The licensee's DBD statement, "Therefore this symptomis not used on the Fission Product Barrier table associated with ICs", requires further explanation.
In the copy of the D.C. Cook Nuclear Plant Emergency Plan, Section 12.3.5, "Emergency Classification System", submitted for review, there are two FPB matrices provided.
The first is titled, "INITIATINGCONDITIONS, RECOGNITION CATEGORY: Fission Product Barriers", and the second titled, "EMERGENCYACTION LEVELS, RECOGNITION CATEGORY: Fission Product Barriers".
It was not clear what the intended use will be for the "INITIATING CONDITIONS Matrix", but indeed this NUMARC EAL and several others are missing from that matrix.
Provide justification for these deviations from the NUMARCINESP-007 guidance, and an explanation as to the purpose of the "INITIATINGCONDITIONS" section versus the "EMERGENCY ACTION LEVEL" sections of the "Emergency Classification System" procedure (12.3.5).
These deviations also apply to the D.C. Cook treatment of NUMARC example RCS EAL ¹4, Containment Radiation Monitoring, and to NUMARC example CONTAINMENTEAL ¹5, Significant Radioactive Inventory in Containment.
FUEL CLAD EAL ¹6r Other (Site-Specific Indications LOSS: (Site-SpecificJ as applicable POTENTIAL LOSS: (Site-SpecificJ as applicable The D.C. Cook equivalent EAL is:
LOSS: Atleast 5% clad damage POTENTIAL LOSS: (none>
D.C. COOK NUCLEAR PLANT 19
The NUMARC discussion for this EAL states, "This EALis to cover other /site-specificJ indications that may indicate loss or potential loss of Fuel Clad Barrier, includingindications from containment air monitors or any other (site-specificJ instrumentation".
The D.C. Cook DBD contained no discussion on their basis for selecting a simple "Atleast 5% clad damage", with no indication as to how that assessment would be made.
D.C. Cook did not provide discussion as to why they have no other potential indicators, such as containment airborne monitors, portable instrument radiation readings on letdown lines, area radiation monitor readings in process piping areas containing circulating coolant, etc..
Provide information on how the 5% clad damage is to be determined, and justification for the lack of other possible indicators of fuel damage.
LOSS: Any condition in the opinion of the Emergency Director thatindicates LOSS of the fuel clad barrier POTENTIAL LOSS: Any condition in the opinion of the Emergency Director that indicate POTENTIAL LOSS of the fuel clad barrier The D.C. Cook equivalent EAL is:
LOSS: SEC Judgement POTENTIAL LOSS: SEC Judgement D.C. Cook specifically eliminated all other "Emergency Director Judgement" EALS suggested by NUMARC (e.g., HU5, HA6, HS3 5 HG2) from the body of the plant specific EALs.
Explain why "SEC Judgement" or in NUMARCterms "Emergency Director Judgement" were eliminated from other EALs, but included here.
This question also applies to NUMARC RCS EAL
¹6, and to NUMARC CONTAINMENTEAL ¹8.
- 31. The NUMARC criteria for the Reactor Coolant System (RCS) Barrier EAL ¹1 is:
LOSS: Not Applicable POTENTIAL LOSS: RCS Integrity - RED OR Heat Sink - RED D.C. COOK NUCLEAR PLANT 20
~
~
The D.C. Cook equivalent EAL is:
LOSS: <none>
POTENTIAL LOSS: Core Cooling - RED Heat Sink - RED - AND - Wide range levelin at least 3 SGs is <29
(<43'or adverse containmentJ A. The D.C. Cook DBD EAL Deviation statement, concerning HEAT SINK, for this EAL reads IDENTICALto that used in Fission Product Barrier EAL II1. The questions raised in that earlier discussion should also be addressed for this EAL.
B. D.C. Cook substituted "Core Cooling - RED" for "RCS Integrity - RED" with no explanation, This substitution of CSFSTs, combined with a continued discussion concerning the fuel clad barrier (versus the RCS barrier) in the Deviation statement, indicate that the licensee may have misread the NUMARC EAL guidance.
Provide justification for these significant deviations from the NUMARC/NESP-007 guidance.
LOSS: GREA TER THANavailable makeup capacity asindicated by a loss ofRCS subcooling.
POTENTIAL LOSS: Unisolable leak exceeding the capacity of one charging pumpin the normal charging mode.
The D.C. Cook equivalent EAL is:
LOSS: RCS subcooling <30 degrees PAND can NOT be restored.
POTENTIALLOSS: ECCS operating in Sl mode AND Slis not diagnosed as "inadvertent ".
A. The D.C. Cook DBD EAL Deviation statement stated, "On the loss EAL, we added the caveat that subcooling cannot be restored.
This allows some leeway in those circumstances where the EOPs direct minimizing subcooling for some mitigating action".
The licensee did not provide an example of where the EOPs purposefully have the operators reduce subcooling to < 30 degrees F
(it is presumed that this includes instrument error). The licensee placed no time constraint on the phrase "can NOT be restored"
~
B. The setpoint for the potential loss of RCS specified in the D.C. Cook scheme is higher than the setpoint specified in the NUMARC scheme, i.e. "Unisolable leak exceeding the capacity of one charging pump in the normal charging mode."
The D. C. Cook DBD did not provide adequate justification for this deviation.
Provide justification for these significant deviations from the NUMARC/NESP-007 guidance.
D.C. COOK NUCLEAR PLANT 21
RCS EAL ¹3: SG Tube Rupture LOSS: (Site-specificJ indication that a SGis ruptured and has a non-isolable secondary line break or (site-specificl indication that a SGis ruptured and a prolonged release of contaminated secondary coolantis occurring from the affected SG to the environment.
POTENTIAL LOSS: Site-specificindication that a SGis ruptured and the primary-to-secondary leak rate exceeds the capacity of one charging pump in the normal charging mode.
The D.C. Cook equivalent EAL is:
LOSS: ANYSG BOTH RUPTURED and FA ULTED POTENTIAL LOSS: <none>
EAL Deviation:
Our loss EAL relies on operator knowledge of the meaning of RUPTURED and FAULTED as usedin the EOPs.
Based on these meanings, our loss EALis equivalent to the generic EAL.
We do not have a potential loss EAL for SG tube rupture because the potential EAL associated with RCS leak rate completely covers the event proposed by the generic EAL.
A. The D.C. Cook EAL appears to deviate from the NUMARC guidance by using the term FAULTED instead of the NUMARC conditions of: "a non-isolable secondary line break or a prolonged release of contaminated secondary coolant is occurring from the affected SG to the environment."
In addition no site-specific indications of a ruptured SG was provided.
B. Contrary to the assertion made in the D. C. Cook DBD, including the SG tube rupture under the event based EAL is not equivalent to including the SG tube rupture under the fission product barrier EALs.
Provide discussion of the EOP definitions for RUPTURED and FAULTED, and provide justification for the deviations from NUMARC/NESP-007 guidance taken in both this EAL and in RCS EAL ¹2 for the definition of POTENTIAL LOSS.
- 34. The NUMARC criteria for RCS Barrier example EAL ¹4 (Containment Radiation Monitoring) was treated by D.C. Cook in an identical manner (except for radiation level) to how they previously treated the NUMARC EAL for Fuel Clad Barrier EAL ¹5.
Provide justification for the same deviations addressed under NUMARC Fuel Clad Barrier EAL ¹5 which are also applicable to this EAL (NUMARC RCS Barrier EAL ¹4).
RCS EAL ¹5: Other (Site-Specific Indications LOSS: (Site-SpecificJ as applicable POTENTIAL LOSS: (Site-SpecificJ as applicable D.C. COOK NUCLEAR PLANT 22
The D.C. Cook equivalent EAL is:
LOSS: ECCS operating in any SI RECIRCULATION MODE POTENTIAL LOSS: (none>
The NUMARC BASIS for this EAL suggests indications such as containment air monitors and other indications.
As with NUMARC Fuel Clad EAL¹ 6, provide justification as to why D.C. Cook has no other possible indicators (e.g., for LOSS, RCP Seal Failure, or PORV Failure, and for POTENTIAL LOSS, Rapid increase in SG Blowdown Radiation monitors or Containment Atmosphere monitors, etc.).
CONTAINMENTEAL ¹2: Containment Pressure LOSS: Rapid unexplained decrease followinginitialincrease.
OR Containment pressure or sump level response not consistent with LOCA conditions.
POTENTIAL LOSS: (Site-specificJ PSIG andincreasing OR Explosive Mixture Exists OR Containment pressure greater than containment depressurization setpoint and less than one fulltrain of depressurization equipment operating.
The D.C. Cook equivalent EAL is:
LOSS: (none>
POTENTIAL LOSS: Containment pressureisump level response NOT consistent with expected conditions.
OR CNTMTH> >4%
A. D.C. Cook has no LOSS EALs. Excerpts from the D.C. Cook EAL Deviation read as follows:
"We do not use a loss EAL because the symptoms describedin the generic guidance may occur due to activation ofourice condenser..~...
the containment sump level responseis also variable andis not used as a discrete symptom of containment loss.
However, both loss EALs were combined and retained as potential loss symptom".
The licensee's reason for not including any "LOSS" EALs is weak.
Even though D,C. Cook is an ice condenser site, other plants must deal with unique containment performance caused by sprays and Containment Atmosphere Recirculation (CAR) fans.
The Deviation statement implies that the licensee has no indication of when the ice condenser doors open; is this true?
With some applied analysis, D.C. Cook should be able to establish observable criteria that distinguish a "hole in containment" from "ice condenser activation". Elimination of the second NUMARC LOSS example EAL (pressure and sump level response) negates the primary indication of a containment bypass scenario.
B. D.C. Cook eliminated the first NUMARC bullet under POTENTIAL LOSS, based on the fact that it is covered under CSFST - RED condition in other FPB EALs. While the NUMARC BASIS for this EAL agrees with this position, it does not suggest eliminating the criteria from this Containment Pressure FPB EAL. The problem which this and other deviations present, is the manner in which the FPB matrix logic is used to arrive at an emergency declaration.
Shifting criteria within one of the three major FPB categories, and leaving it at the same level (i.e., LOSS or POTENTIAL LOSS) should not present a problem.
However, the overall impact of the numerous D.C. Cook deviations D.C. COOK NUCLEAR PLANT 23
will require further analysis depending on the resolution of deviations identified in this initial Request for Additional Information (RAI}.
C. D.C. Cook completely eliminated an EAL equivalent to the third NUMARC EAL under POTENTIAL LOSS /Containment pressure greater than containment depressurization setpoint and less than one fulltrain of depressurization equipment operating).
The DBD provided no explanation for this deviation.
Provide justification for these significant deviations from the NUMARC/NESP-007 guidance.
- 37. The D.C. Cook emulation of NUMARC Containment Barrier example EAL II3 IContainment Isolation Valve Status after Containment Isolation) appears satisfactory; However, a final determination cannot be made without a review of the plant specific procedure FR-Z.1 Attachment A (or B} referenced in the D.C. Cook EAL.
Provide a written discussion or a copy of the referenced procedure.
CONTAINMENTEAL 4'4: SG Secondary Side Release with Primary to Secondary Leakage LOSS: Release ofsecondary side to atmosphere with primary to secondary leakage greater than technical specification allowable.
POTENTIAL LOSS: Not Applicable The D.C. Cook equivalent EAL is:
LOSS: SGis RUPTURED AND the ruptured SG has known steam flow outside the containment for greater than 30 minutes.
POTENTIAL LOSS: <none>
There are several problems with this D.C. Cook EAL, as follows: D.C. Cook uses the term "RUPTURED", which in previous EALs was implied to refer to a tube rupture.
The NUMARC EAL refers to primary to secondary leakage, not a SG tube rupture.
D.C. Cook uses the words, "ruptured SG has known steam flow outside the containment for greater than 30 minutes".
D.C.
Cook has previously implied that the word "FAULTED"refers to a SG discharging steam to atmosphere.
The NUMARC example EAL contained no time criteria for the discharge of steam to atmosphere; whereas D.C. Cook has added a very non-conservative 30 minutes before meeting this EAL.
Provide justification for these significant deviations from the NUMARC/NESP-007 guidance.
D.C. COOK NUCLEAR PLANT 24
39.
One of the NUMARC example EALs for Containment Barrier is:
Core exit thermocouplesin excess of 1200'nd restoration procedures not effective within 15 minutes; or, core exit thermocouplesin excess of 700'ith reactor vessel level below top of active fuel and restoration procedures not effective within 15 minutes The corresponding D. C. Cook EAL is:
Core Coo(ing CSFST-RED AND core temperature does NOT decrease within 15 minutes The D. C. Cook DBD did not adequately justify the equivalence of the D. C. Cook EAL and the NUMARC EAL. In particular, no information was given regarding the relationship between the NUMARC criteria of "core exit thermocouples in excess of 700 'F and reactor vessel below top of active fuel" and the D. C. Cook EAL, " Core Cooling CSFST-RED"
~
Provide additional justification for this EAL.
CONTAINMENTEAL ¹5: Other (Site-Specific.Indications LOSS: (Site-SpecificJ as applicable POTENTIAL LOSS: (Site-SpecificJ as applicable The D.C. Cook equivalent EAL is:
LOSS: (none)
POTENTIAL LOSS: )20% clad damage The NUMARC BASIS for this EAL suggests indications such as area or ventilation monitors in the containment annulus or other contiguous buildings. The D.C. Cook DBD provides no insight as to w'hy ")20% clad damage" was selected as being indicative of POTENTIAL LOSS of Containment, or as to how that criteria would be measured.
As with NUMARC Fuel Clad EAL¹ 6 and NUMARC RCS EAL ¹ 5, provide justification as to why D.C. Cook has no other possible indicators for LOSS or POTENTIAL LOSS, and an explanation of the basis for selecting > 20/o clad damage as a POTENTIAL LOSS indicator.
D.C. COOK NUCLEAR PLANT 25
'f 4 '4 I
I.
C