ML18038B302
| ML18038B302 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/20/1995 |
| From: | Salas P TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18038B304 | List: |
| References | |
| NUDOCS 9506290206 | |
| Download: ML18038B302 (83) | |
Text
PRIORITY 1 tACCELERATED RZDS PROCESSING)
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9506290206 DOC.DATE: 95/06/20 NOTARIZED: NO DOCKET g
FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 P
50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION SALAS,P.
Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION I
Document Control Branch (Document Control Desk)
SUBJECT:
Forwards response to NRC 950301 RAI re TVA 941019 submittal 0
of Rev to App A of radiological emergency plan, replacing current EALs w/EALs developed from NUMARC methodology.
Revised App A of radiological emergency plan encl.
DISTRIBUTION CODE: A045D COPIES RECEIVED:LTR g ENCL
(
SIZE:
Q + g 1 P I TITLE: OR Submittal:
- Plans, Implement'g Procedures, C
NOTES:
RECIPIENT ID CODE/NAME PD2-3-PD INTERNAL:
CENTZ OC -ABSTRACT EXTERNAL: NOAC COPIES LTTR ENCL 1
1 1
1 1
1 1
1 RECIPIENT ID CODE/NAME WILLIAMS,Z.
NRR/DOTS/TERB NRC PDR COPIES LTTR ENCL 1
1 1
1 1
1 D
N NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE!
CONTACT THE DOCUMENT CONTROL DESKI ROOM OWFN 5DS (4!15-2083)
TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDl TOTAL NUMBER OF COPIES REQUIRED:
LTTR 7
ENCL 7
Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609 June 20, 1995 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentleman:
In the Matter of Tennessee Valley Authority Docket Nos.
50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - REQUEST FOR ADDITIONAL INFORMATION (RAI) - EMERGENCY ACTION PLAN CONVERSION TO NUMARC EMERGENCY ACTION LEVELS (EALs)
By letter dated October 19,
- 1994, TVA submitted a revision to Appendix A of TVA's Radiological Emergency Plan for BFN Units 1, 2, and 3.
The proposed revision, when approved, will replace the current EALs with EALs developed from the Nuclear Utilities Management and Resources Committee (NUMARC) methodology.
By letter dated March 1,
- 1995, NRC submitted a
request for additional information (RAI) to TVA regarding the BFN EAL conversion.
TVA met with NRC on March 23, 1995, at the NRC headquarters office to discuss the RAI.
As a result of TVA's review of NRC comments and the discussion held at the referenced
- meeting, TVA is providing the following information: ~
~
Enclosure 1 to this letter provides TVA's reply to the subject RAI;
~
Enclosure 2 is a revised copy of the subject
~
Enclosure 3 is a copy of the Emergency Plan Implementing Procedure-1; 9506290206 950620 PDR ADOt."K'5000259 F
U.S. Nuclear Regulatory Commission Page 2
June 20, 1995
~ Enclosure 4 provides a cross reference between the NUMARC EAL designator and the BFN EAL designator;
~ Enclosure 5 describes any deviations from the NUMARC guidelines.
NRC also requested that TVA describe the process used to develop the BFN EALs, including a discussion of the internal review by site and corporate representatives.
This information is provided as Enclosure 6 to this submittal.
If you have any questions regarding this reply, please contact me at (205) 729-2636.
S' Salas Manager of Site Licensing Enclosures cc (Enclosures):
Mr. Mark S. Lesser, Acting Branch Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637
- Athens, Alabama 35611 Mr. J.
F. Williams,'roject Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. David E. LaBarge, Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555,Rockville Pike Rockville, Maryland 20852
.'0-259 BROWNS FERRY 1
". EMERGENCY ACTION LEVERS REQUEST FOR ADDITIONAL INFORMATION REC'D W/LTR DTD 6/20/95...9506290206
-NOTICE-THE'ATTACHED FILES ARE OFFICIAL RECORDS OF THE INFORMATION &
REPORTS MANAGEMENT BRANCH.
THEY HAVE BEEN CHARGED TO YOU FOR A LIMITED TIME PERIOD AND MUST BE RETURNED TO THE RE-CORDS & ARCHIVES SERVICES SEC-TION P1-22 WHITE FUNT. PLEASE DO NOT.SEND DOCUMENTS CHARGED OUT THROUGH THE MAIL. REMOVAL OF ANY PAGE(S) FROM DOCUMENT FOR REPRODUCTION MUST BE RE-FERRED TO FILE PERSONNEL.
-NOTICE-
ENCLOSURE 1
TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
EMERGENCY ACTION LEVELS (EALs)
REQUEST FOR ADDITIONAL INFORMATION (RAI)
Z ~
GENERAL NRC Comment Z.1 NUMARC/NESP-007 provides the following guidance concerning emergency class downgrading:
A combination approach involving recovery from General Emergencies and some Site Area Emergencies and termination from Unusual Events, Alerts, and certain Site Area Emergencies causing no long-term damage appears to be the best choice.
Downgrading to lower emergency classes adds notifications but may have merit under certain circumstances.
Comment:
No downgrading approach was included in the submittal package.
TVA Res onse TVA's philosophy will be to terminate rather than downgrade due to the potential confusion that this has created for the state and local response agencies.
This will be implemented in BFN Emergency Plan Implementing Procedure (EPIP) 16 and CECC EPIP-13, along with the new EALs and is consistent with the approved philosophy implemented at WBN.
NRC Comment I.2 Some of the licensee EALs do not register the correct monitor identifications for EALs'that use such indications.
The licensee EALs apply to all three units but, it is not assured that monitor or indicator identification numbers are the. same for each unit.
For example:
EAL 3.2.S, Site Area Emergency for Secondary
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Containment Radiation lists radiation monitors numbers as,90-25A, 90-28A,90-13A, etc.
All begin with 90 and end with A.
Is this number system universal to all three units?
What identification is used for unit common (elevated release point) monitors?
TVA Res onse All monitors identified in the EALs were reviewed and confirmed to be the same instrument numbers for all units unless otherwise noted.
For example, radiation monitor number 90-25A is the same for all units with distinct unit identifier (1-90-25A, 2-90-25A and 90-25A)
~
NRC Comment I.3 BFN Unit 1 and 2 share a common control room and the Unit 3 Control Room is separated by building walls.
For a site wide emergency such as; earthquake, toxic gas, civil disturbance, who is in charge before command is transferred to the Technical Support Center (TSC)?
TVA Res onse Although BFN has separate control rooms, only one Shift Operations Supervisor (SOS) is designated to be the Site Emergency Director (SED), regardless of which unit the emergency is declared on.
This individual will be in charge of the facility following Radiological Emergency Plan (REP) activation, until c'ommand is transferred to the TSC.
NRC Comment I.4 Part of the licensee deviation document appeared to be inaccurate.
For example:
the licensee states in deviation 10 that, "NUMARC SU4 example 1 does not correlate to a Specific EAL. It is covered by Radioactive Release EALs.
BFN does not have other specific alarm setpoints to base this EAL on."
The licensee EAL 1.4-'U; Main Steam Line Radiation High High, reference section directly relates this EAL to NUMARC SU4-1.
,EAL 1.4-U has been revised to include the Off Gas Pretreatment Rad Monitor and the deviation document has been revised to explain the use of the Main Steamline Radiation High-High Alarm.
E1-2
NRC Comment I.S Part of the licensee EAL cross reference document appeared to be inaccurate.
For example:
The licensee cross reference related NUMARC EAL SA4 to licensee EAL 8.2-A.
There is no licensee EAL 8.2-A.
TVA Res onse TVA concurs, this was a typographical error.
The cross reference document has been revised to relate NUMARC EAL SA4 to Browns Ferry EAL 8.3-A instead of 8.2-A.
NRC Comment I.6 NUMARC prescribes in the fission product barrier, Table 3, the use of the IMMINENT concept as follows: "An event (or multiple events) could occur which result in the conclusion that the Loss or Potential Loss thresholds is IMMINENT (i.e. within 1 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />).
In this IMMINENT LOSS situation use judgement and classify as if the thresholds are exceeded."
The licensee refers to the concept of "IMMINENT" IN EAL 8.4-G which is general emergency based on the Emergency Director judgement.
No definition of the term "imminent" is provided in the bases.
TVA Res onse The imminent concept has been added to the basis of EALs 8.4-U, 8.4-A, 8.4-S and 8.4-G.
II SPECIFIC NRC Comment II.A:
NUMARC Reco nition Cate or A-Abnormal Rad Levels Radiolo ical Effluent 1.
The NUMARC criteria for EAL AUl-1 states:
A valid reading on one or more of the following monitors that exceeds the "value
.hown" (site-specific monitors) indicates that the release may have exceeded the above criterion and indicates the need to assess the release with (site-specific procedure):
(site-specific list)
The licensee equivalent EALs state:
Gaseous release rates exceed ANY limit in Table 4.1-U E1-3
kl
AND Duration listed in Table 4.1-U will be exceeded.
a.
There is no clear direction in the EAL to assess the release with a site specific procedure, as required by the NUMARC criteria.
TVA Res onse EAL 4.1U has been revised to add note 4.1-U which states:
Prior to making this emergency classification based upon the WRGERMS indication, assess the -release by either of the following:
1.
Actual field measurements exceed the limits in Table 4.1-U 2.
SI 4.8.B.l.a.l Release Fraction exceeds 2.0
~,
If neither assessment can be conducted within 60 minutes then the declaration must be made on the valid WRGE1gfS reading.
The NUMARC basis required that monitor indications should be based on annual average meteorology where allowed.
The licensee does not address meteorology in the EAL or in the technical basis.
TVA Res onse There is reference to the Browns Ferry Offsite Dose Calculation Manuals (ODCM) for this EAL.
The ODCM calculations are based on historical annual average meteorology.
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NUMARC criteria for radiological releases specify that site specific monitor setpoints, when exceeded, will trigger an assessment of the release by use of a site specific procedure.
No requirement to assess radiological
- releases, when monitor's setpoints are exceeded, with a site specific procedure is evident.
The NUMARC assessment criteria requirement is provided to ensure accurate classification.
The monitor setpoint alone should not trigger the classification unless an assessment cannot be completed within the allowed time.
The NUMARC criteria requiring an assessment of a radiological release when monitor setpoints are exceeded is not evident in the licensee EALs.
P 0
TVA Res onse EAL 4.1-U has been revised to add note 4.1-U which requires assessment prior to cl'assification.
- Also, note 4.1-U states if assessment cannot be completed within 60 minutes then the declaration must be made on the valid WRGERMS reading.
NRC Comment II.A.2 The NUMARC criteria for Initiating Condition (IC)
AU2 and EAL AU2-1 state:
AU2 Unexpected increase in plant radiation or airborne concentration.
1.
(Site-specific) indication of uncontrolled water level decrease in the reactor refueling cavity with all irradiated assembles remaining covered.
The licensee equivalent EALs states:
l.
1-U1 Unusual Event Uncontrolled water level decrease in Reactor Cavity AND Irradiated fuel assemblies remain covered by water.
a.
The licensee EAL omits the NUMARC criteria for site specific indication.
The licensee basis for this EAL states:
"This event classification should only be considered if, in the opinion of the Site Emergency Director, the water level decrease is substantial enough to ultimately result in increased dose rates in the area of the Reactor Cavity due to loss of shielding by water covering irradiated fuel."
The basis statement adds an extra dimension to the EAL that is not contained in the EAL specific criteria.
The statement establishes a subjectivity that relies on the opinion of the SED.
NUMARC requires that mode EALs be objective and have observable values.
The licensee EAL does not meet the criteria.
TVA Res onse TVA has revised EAL 1.1-U1 to add "expected" as part of the EAL.
The basis was also expanded to E1-5
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provide example indicators of uncontrolled water level decrease.
- However, TVA believes there remains some judgement based on what the SED determines to be a valid indicator.
Comment ZI.A.3 The 2.
NUMARC criteria for Initiating Condition AU2-2 states:
Uncontrolled water level decrease in the spent fuel pool and fuel transfer canal with all irradiated fuel assemblies covered by water.
The licensee equivalent EAL states:
1-U1 Unusual Event Uncontrolled water level decrease in Spent Fuel Storage Pool AND a ~
Irradiated fuel assemblies remain covered by water.
The licensee basis for this EAL states:
"This event classification should only be considered if, in the opinion of the Site Emergency Director, the water level decrease is substantial enough to ultimately result in increased dose rates in the area of the Spent Fuel Storage Pool due to loss of shielding by water covering irradiated fuel."
The basis statement adds an extra dimension to the EAL that is not contained in the EAL specific criteria.
TVA Res onse b.
TVA assumes this refers to TVA EAL 1.1-U2, instead of 1.1-U1.
EAL 1.1-U2 has been revised to add "expected" as part of the EAL.
The basis has been expanded to include example indicators of uncontrolled water level decrease.
- However, TVA believes there remains some judgement to this decision based on what the SED determines to be valid indications other than by visual observation only.
The statement establishes a subjectivity that relies on the opinion of the SED.
NUMARC requires that model EALs be objective and have observable values.
The licensee EAL does not meet that criteria.
E1-6
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TVA Res onse TVA believes that this comment and II.A.3.a are one and the same and the above response also applies to this statement.
(See TVA response to Comment II.A.3.a)'RC Comment ZZ.A.4 The NUMARC criteria for IC AU2 and EAL AU2-4 state:
AU2 Unexpected increase in plant radiation or airborne concentration.
4.
Valid direct area radiation monitor readings increase by a factor of 1000 over normal levels.
The licensee equivalent EAL states:
6.
1-U Unusual Event Valid, unexpected increase of ANY in plant Area Radiation Monitor (ARM) reading to 1000 mrem/hr (except TIP room)
'J Valid, unexpected increase of ANY in plant Continuous Air Monitor (CAM) reading Co an airborne radioactivity of 4.0 X 106 uCi/cc.
a.
The NUMARC criteria for ARM increase is a factor of 1000 over normal levels.
The licensee sets the level at 1000 mrem/hr.
No justification for the setpoint is provided in the basis or the deviation document.
TVA Res onse The deviation document has been revised to add the following justification for using 1000 mr/hr.
The instruments contain an internal source which maintains a minimum reading of approximately 1 mr/hr.
Continuous tracking of normal background levels for all of the Area Radiation Monitors would add an additional burden on the control room staff.
BFN used a fixed 1000 mr/hr as recommended by the plant Radiological Controls staff.
b.
Nhile the NUMARC IC suggests inclusion of airborne concentrations, the example EALs do not address airborne levels.
The NUMARC workshop conducted in September 1992 states:
"The inclusion of airborne E1-7
concentration in this IC is a typographical error and should be disregarded."
The licensee should determine the appropriateness of inclusion of airborne radioactivity in this EAL.
TVA Res onse The airborne concentration references in this EAL have been deleted.
NRC Comment II.A.5 The NUMARC criteria for EAL AAl-1 states:
1.
A valid reading on one or more of the following monitors that exceeds the "value shown" (site-specific monitors) indicates that the release may have exceeded the above criterion and indicates the need to assess the release with (site-specific procedure):
(site-specific list)'he licensee equivalent EALs state:
Gaseous release rates exceed ANY limit in Table 4.1-A AND Duration listed in Table 4.1-A will be exceeded.
a.
There is no clear direction in the EAL to assess the release with a site specific procedure, as required by the NUMARC criteria.
TVA Res onse EAL 4.1-A has been revised to add note 4.1-A which states; Prior to making this emergency classification based
,upon the WRGERMS indication, assess the release by either of the following:
1.
Actual field measurements exceed the limits in Table 4.1-A 2.
SI 4.8.B.l.a.l Release Fraction exceeds 200 If neither assessment can be conducted within 15 minutes then the declaration must be made on the valid WRGERMS reading.
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The NUMARC basis requires that monitor indications should be based on annual average meteorology where allowed.
The licensee does not address meteorology in the EAL or the technical'basis.
TVA Res onse There is reference to the Browns Ferry Offsite Dose Calculation Manuals (ODCM) for this EAL.
The ODCM calculations are based on historical annual average meteorology.
NRC Comment II.A.6 The NUMARC criteria for IC AA2 states:
Major Damage to Irradiated Fuel or Loss of Water Level that Has or Will Result in the Uncovering of Irradiated Fuel Outside the Reactor Vessel.
7 1.
A (site-specific setpoint) alarm on one or more of the following radiation monitors: (site-specific monitors).
Refuel Floor Area Radiation Monitor Fuel Handling Building ventilation Monitor Fuel Bridge Area Radiation Monitor The licensee equivalent EAL states:
3.2-A Alert Any of the following alarms on Panel 9-3:
RA-90-1A RA-90-142A RA-90-250A RA-90-140A AND Confirmation by Refuel Floor personnel that irradiated fuel damage may have occurred.
a.
The licensee's deviation 5 states that the alarms are not necessarily associated with irradiated fuel damage and that the added qualifying "AND" logic statement provides association.
The NUMARC criteria reguires the selection of monitors and setpoints that are associated with irradiated fuel damage or uncovery outside the reactor vessel; additional visual confirmation might delay the classification.
E1-9
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TVA Res onse The identified alarms will respond if there has been damage to irradiated fuel.
These alarms are also subject to alarm for other reasons (i.e.,
movement of contaminated material, moving Reactor-vessel internals, etc.).
The "AND" logic was included to differentiate between these occurrences and actual damage to fuel.
TVA does not believe this poses any delays in making the declaration.
The logic for using "confirmation by refuel floor personnel that irradiated fuel damage may have occurred" is:
~
If at any time fuel handling is underway personnel will be stationed on the refuel floor.
~
Any time the reactor cavity is open a security post is manned on the refuel floor.
If irradiated fuel has been dropped or may have possibly been
- damaged, the refuel floor personnel will report it as soon as possible without delay.
NRC Comment 1I.A.7 The NUMARC criteria for EALs AA2-3 and AA2-4 state:
1.
Water Level less than (site-specific) feet for the Reactor Refueling Cavity that will result in irradiated fuel uncovering.
2.
Water Level less than (site-specific) feet for the Spent Fuel Pool and Fuel Transfer Canal that will result in irradiated fuel uncovering.
The licensee's equivalent EALs state:
1.1-A1 Alert
'ncontrolled water level decrease in Reactor Cavity AND Irradiated fuel assemblies uncovered.
1.1-A2 Alert Uncontrolled water level decrease in Spent Fuel Storage Pool.
AND
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Irradiated fuel assemblies uncovered.
a.
The NUMARC criteria requires a site specific level for the reactor cavity and the spent fuel pool that results in irradiated fuel uncovering.
b.
The licensee's EAL does not provide the site specific level.
TVA Res onse TVA has revised EAL 1.1-A1 and 1.1-A2 to add "expected" as part of these EALs.
The basis was also expanded to include indicators for uncontrolled water level and expected fuel uncovery.
BFN does not have a required installed means for monitoring the level for fuel uncovery.
TVA believes there remains some judgement on this decision based on what the SED determines to be valid indicators.
NRC Comment II.A.S NUMARC example 2, Report of visual observation of irradiated fuel uncovered, provides for visual observation as a stand-alone EAL.
The licensee's deviation 6 states that NUMARC AA2-2 is covered by spent fuel storage pool water levels EALs and is not specifically addressed elsewhere.
No stand-alone, visual observation, licensee EAL is evident.
TVA Res onse EALs 1.1-Al and 1.1-A2 have been revised to include visual observation as an indicator.
Therefore, TVA does not believe a separate EAL is necessary.
Deviation 6 has been revised to address this.
Contrary to the NUMARC criteria the licensee requires both "uncovery" and uncontrolled water level decrease in these EALs.
No criteria is specified (visual, radiation level, water level alarm) for determination that the irradiated fuel is uncovered.
TVA Res onse EALs 1.1-A1 and 1.1-A2 have been revised to include criteria for determination of irradiated fuel uncovery.
NRC Comment XI.A.9 The NUMARC criteria for IC AS1 and EAL ASl-1 and AS1-3 state:
AS1 Boundary dose resulting from actual or imminent release of gaseous radioactivity exceeds 100 mr Whole body or 500 mr Child Thyroid for actual or projected duration of the release.
1.
A valid reading on one or more of the following monitors that exceeds or is expected to exceed the value shown indicates that the release may have exceeded the above criterion and indicates the need to assess the release with (site-specific procedure):
(site-specific list)
Note: If the monitor reading(s) 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 100 mr whole body or 500 mr child thyroid.
The licensee equivalent EALs states:
4.1-S Site Area Emergency EITHER of the following conditions exists:
Gaseous release exceeds or is expected to exceed ANY limit in Table 4.1-S Dose assessment indicates actual or projected dose consequences greater than 100 mrem TEDE OR 500 mrem thyroid CDE AND Duration listed in Table 4.1-S will be exceeded.
a.
There is no clear direction in the EAL to assess the release with a site specific procedure, as required by the NUMARC criteria.
E1-12
TVA Res onse EAL 4.1-S was revised such that the durations listed in table 4.1-S were associated only with the gaseous release rate and not actual dose assessment.
Also the EAL was revised to add note 4.1-S to state:
Prior to making this emergency classification based on the Gaseous Release Rate indication, assess the release by either of the following methods:
1.
Actual field measurements exceed the limits in Table 4.1-S 2.
Projected or Actual Dose Assessments exceed 100 mrem TEDE or 500 mrem CDE.
If neither assessment can be conducted within 15 minutes then the declaration must be made on the valid WRGERMS reading.
The basis was revised to list the specific procedures for these assessments.
The NUMARC basis requires that monitor indications should be based on FSAR source terms and annual average meteorology.
The licensee does not address the source term or meteorology conditions used in the EAL or the technical basis.
TVA Res onse BFN FSAR does not contain accident source term information.
The release rates calculated to determine monitor readings are those required to deliver the EAL dose in one hour.
To perform the calculation, the mix fractions used by the TVA Emergency Preparedness dose assessment code FRED (Forecast Radiological Emergency Dose) and the dose factors from EPA-400 (Manual of Protective Action Guides and protective Actions for Nuclear Incidents)
Tables 5.1 and 5.2 are used in conjunction with the annual average meteorology used in the ODCM.
Release rates for both noble gases and iodines are calculated, for both types of nuclide mixes considered by this code (Type I being a release of the gap activity, and Type II is a mix used if there has been a release of large mounts of particulates from the core).
Comment II.A.10 The NUMARC criteria for IC AG1 and EAL AGl-1 state:
AG1 Boundary dose resulting from actual or imminent
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release of gaseous radioactivity exceeds 1000 mr Whole Body or 5000 mr Child Thyroid for actual or projected duration of the release using actual meteorology.
1.
A valid reading on one or more of the following monitors that exceeds or is expected to exceed the value shown indicates that the release may have exceeded the above criterion and indicates the need to assess the release with (site-specific procedure):
(site-specific list)
Note:
If the monitor reading(s) 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 eguivalent EAL states:
4.1-G General Emergency EITHER of the following conditions exists:
Gaseous release exceeds or is expected to exceed ANY limit in Table 4.1-G
~
Dose assessment indicates actual or projected dose consequences greater than 100 mrem TEDE or 500 mrem thyroid CDE AND Duration listed in Table 4.1-G will be exceeded.
a ~
There is no clear direction in the EAL to assess the release with a site specific procedure using actual meteorology when the monitor setpoint is
- exceeded, as required by the NUMARC criteria.
TVA Res onse EAL 4.1-G was revised such that the durations listed in table 4.1-G were associated only with the gaseous release rate and not actual dose assessment.
Also the EAL was revised to add note 4.1-G to state:
Prior to making this emergency classification based upon the Gaseous Release Rate indication, assess the release by either of the following methods:
1.
Actual field measurements exceed the limits in Table 4.1-G.
T II
2.
Projected or Actual Dose Assessments exceed 1000 mrem TEDE or 5000 mrem CDE.
If neither assessment can be conducted within 15 minutes then the declaration must be made on the valid WRGERMS reading.
Also, the basis was revised to list the specific procedures for these assessments.
NRC Comment II.B.1:
NUMARC Reco nition Cate or F-Fission Product Barrier De radation The NUMARC guidance for fission product barrier EAL presentation prescribes the use of a matrix of loss and potential loss of each barrier.
Classification level is then dependent on the number of loss or potential loss barriers.
This approach is suggested to show the synergism among the EALs and to support more accurate dynamic assessments.
Other NUMARC acceptable methods of achieving these goals include flow charts, block diagrams, and check lists.
The licensee does not use these suggested fission product barrier approaches.
The licensee incorporates the barrier criteria into the EALs by approaching each symptom listed in the NUMARC matrix with individual EALs.
These individual EALs take into account the barriers lost or potentially lost, based on the symptom, to arrive at a classification.
The user, classifier, does not need to sum the lost or potential lost fission product barriers, as in the NUMARC scheme.
However, the classification level results achieved with this method are the same as those specified in the NUMARC guidance.
The following is an example:
If reactor vessel water level 'is at TAF, NUMARC methodology requires that (1) the fuel clad 'barrier is considered potentially lost, (2) the RCS barrier is considered lost, and (3) a site area emergency exists if Potential loss of EITHER Fuel Clad OR RCS, and ANY Additional barrier.
The licensee implemented the low (TAF) reactor water level Initiating Condition with the following:
Water Level, 1.1-S1, Site Area Emer enc Reactor water level cannot be maintained above -162 in (TAF)
The licensee basis information stated:
If Reactor water level cannot be maintained above TAF the potential
'xists(s) for fuel cladding damage.
Events most likely to result in coolant inventory loss to this extent are RCS boundary degradation events or station blackout events.
Other combinations of barrier integrity failure were
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similarly classified without reference to individual barrier integrity before proceeding to the classification.
The licensee did not justify (in the basis documentation) the departure from the NUMARC methodology.
TV% Res onse TVA has revised the deviation document to state why we use the symptom based EAL.
This was the direction we received from the NUMARC EAL workshop in St. Louis conducted September 22 and 23,
- 1992, and it is our understanding that it remains an acceptable approach.
This symptom based approach and the method of formatting and presentation is consistent with the approach taken in development of the BFN EOIs and therefore enhances the integration of the EOIs and the REP.
TVA believes that taking this approach is consistent with the NUMARC philosophy as described on page viii of the Executive Summary in Reg.
Guide 1.101.
Also, the SED judgement EALs 8.4-U, 8.4-A, 8.4-S and 8.4-G have been revised to incorporate and ensure the understanding of the overall NUMARC fission product barrier concept.
NRC Comment II.B.2 The licensee Reactor Coolant Activity EAL 1.3-S states:
1.3-S Site Area Emergency Reactor coolant activity exceeds 1100 uCi/gm dose equivalent Iodine-131 as determined by chemistry sample.
The licensee's basis states that:
"Reactor coolant activity samples exceeding 1100 uCi/gm dose equivalent Iodine-131 are indicative of gross cladding failures of 20 percent clad damage.
This condition is indicative of a major failure of plant functions needed for protection of the public and warrants declaration of a Site Area Emergency."
The licensee's deviation 17 states that:
"BFN 1.3-S is not derived from NUMARC EAL. It is a logical progression from Alert to General Emergency and represents coolant chemistry conditions for approximately 20 percent clad failure with no RCS leakage into containment."
a.
The licensee classification of the EAL at the Site Area Emergency level is inconsistent with the NUMARC
classification approach for fission product barrier degradation.
Fuel failure, in the absence of other fission product barrier loss or potential loss, is classified, by the NUMARC approach, at the Alert level.
As written, this licensee EAL does not exhibit RCS or containment loss or potential loss.
TVA Res onse EAL 1.3-S has been deleted.
NRC Comment IX B 3 The licensee EAL states:
2.2-A Alert Drywell or Suppression Chamber H2 concentration at or above 2.4 percent.
AND Indications of fuel cladding damage.
Refer to Table 2.2-A.
a ~
The licensee's basis states that the presence of hydrogen in the primary containment is indication of fuel failure. If the hydrogen concentration is valid then the requirement for.additional indication of fuel cladding damage, Table 2.2-A, is unclear.
The basis also says that the mechanism for release of hydrogen to the primary containment may be through relief valves and not necessarily indicate RCS breech.
The rational for this path is not explained.
In licensee EAL 3.1-G General Emergency the hydrogen indication of potential or significant fuel failure is: Hydrogen detectable in primary containment. following any severe transient.
For Alert hydrogen indications is "2.44":, for General Emergency hydrogen indication is "detectable."
The selected setpoints are inconsistent.
It is not apparent how EAL 2.2-A enhances the licensee's classification scheme or why the hydrogen limits are different for EAL 2.2-A and EAL 3.1-G.
TVA Res onse EAL 2.2A has been deleted.
Also, the reference to minimum detectable hydrogen has been deleted in EAL 3.1-G.
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NRC Comment II.B.4 The NUMARC criteria for EAL RCS loss
- 1. states:
(site-specific) indication of Main Steam Line Break There is no equivalent licensee EAL evident.
a \\
The NUMARC workshop conducted in April 1993 stated that the NUMARC main steam line break criteria should be removed from the fission product barrier chart but must still be classified under system failures due to the probable offsite dose release from the puff release.
The licensee does not address the puff release in other EALs.
TVA Res onse TVA has added EALs 4.2-U to the gaseous release section to address the main steam line break criteria.
TVA recognizes that the NUMARC criteria relates to a main steam line break assuming isolation.
TVA has added an additional EAL (4.2-S) to address an unisolable main steam line break based upon it, is a specific condition identified in the BFN EOIs.
NRC Comment II.B.5 The licensee EAL states:
2.5-U Inability to maintain Primary Containment pressure boundary.
Refer to Table 2.5-U Table 2.5-U lists five indications of primary containment loss:
Unexplained loss of pressure Exceeding SI 4.7.A.2.a limits Both isolation valves in any one line fail open Bypass of PCIS interlocks and venting per EOIs Unisolable primary containment gross external leakage a.
The reference to SI 4.7.A.2.a requires the classifier to consult a separate document to determine the limits, a time consuming effort.
The limits should be included in the EAL to facilitate timely classification.
TVA Res onse SI 4.7.A.2.a is a routine surveillance that is performed once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to calculate primary containment leakage.
If the limits are exceeded, it is reported to the SOS that acceptance criteria for the SI
~
~
U1 e.,
e~'
has been exceeded.
Therefore, placing a specific limit in the EAL is not consistent with indicators used by the SOS.
The results of the SI is an indicator that primary containment has been lost.
NRC Comment II.B.6 There is no definition of gross external leakage.
The lack of definition could result in inconsistent or inaccurate classification.
TVA Res onse TVA has deleted "unisolable primary containment gross external leakage" from EAL 2.5-U.
Therefore, there is not a need to define external leakage.
NRC Comment II.B.7 The NUMARC criteria specifies an EAL for Drywell Pressure loss:
Drywell pressure response not consistent with LOCA conditions.
a.
No licensee directly related EAL is evident.
TVA Res onse TVA EAL 3.1S and 3.2S address the primary to secondary containment leak condition.
This has been added to the deviation document.
NRC Comment II.C.1:
NUMARC Reco nition Cate or H-Hazards and Other Conditions Affectin Plant Safet The NUMARC criteria for IC HU1 and EAL HU1-3 state:
HU1 Natural and destructive phenomena affecting the protected area E
3.
Assessment by the control room that an event has occurred.
No licensee equivalent EALs are evident.
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TVA Res onse BFN EAL 7.1-U specifically addresses earthquake situations.
The Basis for 7.1-U has been revised to add "the assessment by control room personnel includes a determination considering the following:
Apparent ground motion Report by other plant personnel Verification from the National Earthquake Center (refer to-AOI-100-5, Earthquake)"
There are no other site specific occurrences that are not covered in other EALs.
(The deviation document has been revised to address this).
NRC Comment II.C.2 The NUMARC. criteria -for EAL HUl-4 states:
4.
Vehicle crash into plant structures or systems within protected area boundary.
The licensee equivalent EAL states:
6.6-U Unusual Event Vehicle crash (aircraft, truck, or barge) into permanent plant structures or equipment with potential to affect functions or equipment required for safe shutdown.
a.
'The NUMARC criteria addresses a crash into a plant structure that contains functions or systems required for safe shutdown and that the structure is potentially damaged.
The potential effect to functions or equipment required for safe shutdown might not be known until a full assessment of the structural damage is completed.
A crash with sufficient impact to cause structural damage should trigger the classification.
TVA Res onse BFN EAL 6.6U (vehicle, crash).
has been renumbered to 6.8U (vehicle crash) due to the revision of earlier EALs.
BFN has revised EAL 6.8-U to read as follows:
"Vehicle crash (for example; aircraft or barge) into plant structure or systems within the protected area boundary."
The basis was also revised to be consistent with the NUMARC wording.
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NRC Comment II.C.3 The NUMARC criteria for EAL HU2-1 states:
1.
Fire in buildin s or a g
reas contiguous to any of th o
owing (site-specific) areas not extin uished w'Site-specific) list The licensee equivalent EAL states:
6.4-U1 Confirmed fire in ANY plant ar
d ea xs e
xn Table AND NOT extinguished within 15 minutes.
a.
The licensee EAL omits the criteria for areas contiguous to the listed buildings and areas TVA Res onse BFN EAL 6.4-U1 TTable 6.4-U1 includes areas that have been identified as "areas contiguous to."
This table identifies vital areas and areas t'as con iguous to vital s.
er significant areas having potential to as cause significant release of radioactive t
- Radwaste, have also been includ d
'ive ma erial such e
zn hzs table.
NRC Comment II.C.4 The NUMARC criteria for EAL HA1-1 states:
1.
(Site-specific) method indicates Seismic Event greater than Operating Basis Earthquake (OBE).
The licensee equivalent EAL states:
7.1-A Alert Annunciation in Unit 1 Control Room, Panel 1-XA-55-4B
~
Window 22 SEISMIC TRIGGER A
~
"Window 23 SEISMIC TRIGGER B Window 30 SEISMIC TRIGGER C
AND'ssessmentby Control Room Personnel th t has occurred.
e a
an earthquake
a ~
The licensee EAL should specify the number of annunciators needed to classify.
The EAL should be specific regarding the event initiator.
TVA Res onse BFN EAL 7.7.1-A has been revised to read
"~An of the following annunciations in Unit 1 Control Room Panel 1-XA-55-4B.
I Window 22, Seismic Trigger A Window 23, Seismic Trigger B
Window 30, Seismic Trigger C
AND Assessment by Unit 1 and Unit 2 Control Room personnel that an earthquake has occurred."
b.
It z.s not clear which control room, Unit. 1, Unit 2, or Unit 3 or whether consensus of all t
room erson a
con rol p
onnel xs required for the assessment.
The control room assessment comment also a
lies to licensee EAL 7.1-U.
a so applies TVA Res onse c ~
The revised EAL is specific and EAL 7.1-U has also been revised accordingly.
No assessment criteria is provid d
'd e
as gus. ance for the determination that an earthquake h
The lack of qua e
as occurred.
o speczfz.c assessment criteria results in subjective and inconsistent classification.
TVA Res onse BFN EAL 7.1A has been revised to include the following assessment criteria for consideration Apparent. ground motion Report by other plant personnel Verification from the national Earthquake Center.
(Refer to O-AOI-100-5, Earthquake)
NRC Comment II.C.5 The NUMARC criteria for EAL HA1-2 states:
2.
Tornado or high winds striking plant vital. areas:
~
~
~
Tornado or high winds greater than
( 't-n (sz e-specific) mph strzke within protected area boundary.
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The 'licensee equivalent EAL states:
7.2-A Alert Tornado striking plant vital area OR High winds with suspected velocity of greater than 100 MPH onsite.
a.
The licensee basis includes a note that states:
"Instantaneous wind speed history must be obtained from the strip chart recorders at the Environmental Data Station.
The Control Room printout is a 15 minute average."
The specific monitor used to determine the EAL trigger level should be included within the EAL, not in supplemental notes.
TVA Res onse BFN EAL 7.2-A has been revised as follows:
"Tornado striking plant vital area OR Onsite wind speed above 90 MPH as indicated using the meteorological data screen of the Integrated Computer
'System (ICS)".
Also, the threshold was changed from 100 mph to 90 mph, because the instrument fails to 0 at speeds in excess of 100 mph..
NRC Comment II.C.6 The NUMARC criteria for EAL HA1-3 and HA1-4 state:
3.
Report of any visible structural damage on any of the following plant structures:
Reactor Building Intake Building Ultimate Heat Sink Refueling Water Storage Tank Diesel Generator Building Turbine Building Condensate Storage Tank Control Room Other ('site-specific)
Structures.
(Site-Specific) indications in the control room.
a ~
No licensee equivalent EALs,. are evident.
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TVA Res onse BFN covers this example in various EAL's addressing fires, explosions, tornadoes, etc. It does not seem necessary to include an EAL such as this when all conceivable hazards have been addressed separately.'his explanation has been added to the deviation document.
NRC Comment II.C.7'he NUMARC criteria for HA1-5 states:
5.
Vehicle crash affecting plant vital areas.
The licensee equivalent EAL states:
6.6-A Alert Vehicle crash (aircraft, truck, or barge) into ANY area affecting equipment required for safe shutdown.
a.
The NUMARC basis criteria for alert is "crash into a plant vital areas."
The licensee modified the EAL to "crash into ANY area affecting equipment required for safe shutdown."
The classifier should be able to make the classification based only on "where the event occurred without assessing the effect on equipment required for safe shutdown.
TVA Res onse Some BFN EALs have been renumbered due to previous revisions.
EAL 6.6-A from the original submittal is now 6.8-A.
BFN EAL 6.8-A has been revised to read as follows:
"Vehicle crash (for example; aircraft or barge) into any plant vital area."
NRC Comment II.C.S The NUMARC criteria for IC HA3, EAL HA3-1, and HA3-2 state:
HA3 release of toxic of flammable gases within a facility structure which jeopardizes operation of systems required to maintain safe operations or to establish or maintain cold shutdown.
1.
Report or detection of toxic gases within a Facility Structure in concentrations that will be life threatening to plant personnel.
1 J
2.
Report or detection of flammable gases within a Facility Structure in concentrations that will affect the safe operation of the plant.
The licensee equivalent EALs state:
6.5-A Alert Report or detection of flammable gases within the plant in concentrations that will affect the safe operation ANY unit OR Report or detection of toxic gases within the plant in concentrations that may be life threatening to plant personnel.
a ~
The license does not provide criteria for determination of flammable gas concentrations or life threatening concentrations of toxic gas.
The method for ascertaining the concentrations should be included in the EAL.
TVA Res onse EAL 6.5-A has been revised and separated into two EALs (6.5-A and 6.6-A) to address flammable and toxic gases separately.
These revised EALs contain specific criteria to assist in making classifications NRC Comment II.C.9 The NUMARC criteria for IC HA5 and EAL HA5-1 states:
HA5 Control Room Evacuation Has Been Initiated.
1.
Entry into (site-specific) procedure for control room evacuation.
The licensee equivalent EAL states:
6.2-A Alert Evacuation of ANY control room is required.
a.
The NUMARC criteria is specific about the
'lassification being declared on entry into the control room evacuation procedure.
The licensee's EAL is not clear as to the timing of the classification and does not specify the site specific procedure.
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er
TVA Res onse BFN EAL 6.2-A has been revised to read as follows:
"Entry into AOI-100-2, Control Room Abandonment, for ANY Unit Control Room."
NRC Comment II.C.10 The NUMARC criteria for HS2-1 states:
HS2 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 licensee equivalent EAL states:
6.2-S Site Area Emergency Evacuation of ANY control room is required AND Control of Reactor water level and Reactor pressure (for hot conditions) or decay heat removal (for cold conditions)
CANNOT be established within 15 minutes after evacuation is initiated.
a ~
The NUNARC criteria requires a site specific procedure that provides determination of
-plant control.
No site specific procedure is provided in the licensee's EAL.
TVA Res onse BFN EAL 6.2-S has been revised to read as follows:
"Entry into AOI-100-2, Control Room Abandonment, for ANY Unit Control Room.
AND E1-26
Control of Reactor water level, Reactor pressure, Reactor power, (for hot conditions) or decay heat removal (for cold conditions) per AOI-100-2 cannot be established within 15 minutes after evacuation is initiated."
NRC Comment II.C.11 The NUMARC criteria for EAL HS1-2 states:
Other security events as determined from (site-specific)
There is no licensee EAL that addresses other security events.
TVA Res onse There are no other security events defined in the BFN Physical Security Plan other than those previously identified.
This explanation has been added to the deviation document.
NRC Comment II.C.12 The NUMARC criteria for IC HG1 and EAL HG1-1 and HG1-2 state:
HG1 Security Event Resulting in Loss of Abilityto Reach and Maintain Cold Shutdown.
1.
Loss of physical control of the control room due to a security event.
2.
Loss of physical control of the remote shutdown capability due to a security event.
The licensee equivalent EAL states:
6.7-G General Emergency Intrusion by a hostile force into Control Rooms, backup control areas, or plant vital areas which results in loss of physical control of equipment or functions required to reach and maintain safe shutdown or remove decay heat from any unit.
a.
The licensee's phrasing of "intrusion by a hostile force into......or plant vital areas" is similar to the wording for the site area emergency "Intrusion into ANY plant vital area by a hostile force."
The general emergency is qualified by continuing with, "which results
'in loss of physical control'...."
The
0 f
possibility for inaccurate classification is present.
It is suggested that the licensee reword this EAL to provide a clear distinction between the site area emergency and the general emergency.
TVA Res onse TVA believes this EAL is consistent with the NUMARC initiating condition HG-1.
NRC Comment II.D.1.:
NUMARC Reco nition Cate or S-S stem Malfunction The NUMARC criteria for SU1-1 states:
SUl Loss of All Offsite Power to Essential Busses for Greater Than 15 Minutes.
1.
The following conditions exist:
a.
Loss of power to (site-specific) transformers for greater than 15 minutes.
'AND b.
At least (site-specific) emergency generators are supplying power to emergency busses.
The licensee equivalent EAL states:
5.1-U Unusual Event Loss of normal and alternate supply voltage to ALL unit specific 4KV shutdown boards from Table 5.1 for greater than 15 minutes.
a.
The NUMARC criteria in part b. is not included in the licensee's EAL.
A note below table 5.1 provides the information that at least two boards must be energized from diesel power to meet this classification.
The note information should be part of the EAL.
TVA Res onse BFN EAL 5.1-U has been revised to add the following:
AND At least two Diesel Generators supplying powei to unit specific 4KV Shutdown Boards listed in Table 5.1."
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4 1
~
NRC Comment ZX.D.2 The NUMARC criteria for SU3 states:
SU3 Unplanned Loss of Most or all Safety System Annunciation or Indication in the control Room for Greater Than 15 minutes.
1.
The following conditions exist:
a.
Loss of most or all (site-specific) annunciators associated with safety systems for greater than 15 minutes.
AND b.
Compensatory non-alarming indications are available.
AND c ~
In the opinion of the Shift Supervisor, the loss of the annunciators of indicators requires increased surveillance to safely operate the unit(s).
AND d.
Annunciator or Indicator loss does not result from planned action.
The licensee equivalent EAL state:
8.3-U Unusual Event Unplanned loss of most or all safety system annunciators which causes a significant loss of plant assessment capability for greater than 15 minutes.
AND Compensatory non-alarming safety system indications are available.
AND In the opinion of the Shift Operations supervisor, increased surveillance is required to safely operate the plant.
a.
The NUMARC criteria includes the loss of safety system indicators in the EAL.
Loss of safety system indication is not included in the licensee's EAL.
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j:
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TVA Res onse BFN EAL 8.3-U has been revised to include loss of safety system indicators.
NUMARC criteria requires site specific identification of the relevant annunciators and indications included in
No site specific identification is provided in the licensee's EAL.
TVA Res onse Since this EAL requires substantial Emergency Director judgement, it was believed that. adequate guidance could be provided in the basis for the Emergency Director to properly classify. It was not felt that the use of a site specific list would be beneficial to the Emengency Director due to the extent of their training and ability to interpret the intent of the basis.
NRC Comment II.D.3 The NUMARC criteria for EAL SU4-1 states:
SU4 Fuel Clad Degradation 1.
(Site-Specific) radiation monitor readings indicating fuel clad degradation greater than Technical Specification allowable limits.
The licensee equivalent EAL states:
1.4-U Unusual Event Valid MAIN STEAM LINE RADIATION HIGH-HIGH alarm, 2-XA-55-3A, Window 27 a.
The licensee does not relate the HIGH-HIGH alarm to the technical specification allowable limit in the basis, as required by the NUMARC criteria.
TVA Res onse The Main Steam Line Radiation High-High alarm setpoint does not relate to the technical specification.
The alarm setpoint is above what would be indicative of fuel cladding damage above Technical Specifications allowable limits.
The deviation document was revised to include this explanation.
E1-3 0
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b.
The licensee EALs do not mention other monitors (reactor water cleanup, air ejector, off-gas) that might be used to indicate fuel clad degradation greater than technical specification allowable limits.
TVA Res onse BFN EAL 1.4-U has been revised to add the Off Gas Pretreatment Radiation High alarm.
This alarm, setpoint is set at a value that is indicative of the ODCM allowable limits for radiation release.
NRC Comment II.D.4 The NUMARC criteria for EAL SU5-1 states:
1.
The following conditions exist:
a.
Unidentified or pressure boundary leakage greater than 10 gpm.
OR b.
Identified leakage greater than 25 gpm.
The licensee equivalent EAL states:
2.4-U Unusual Event Drywell unidentified leakage exceeds 10 gpm.
OR Drywell identified leakage exceeds 40 gpm.
a.
The licensee's basis justifies the 40 gpm because it is approximately two times the licensed operating value of 25 gpm, within the capacity of the sump pumps if only one pump is operating, it is observable using control room instrumentation, and compatible with surveillance instructions.
Both NUMARC and the licensed operating limit is 25 gpm for identified leakage.
With identified leakage beyond the licensed operating limit events are in process that. indicate potential degradation of the level of safety, and an unusual event is warranted.
The selection of the higher value is inappropriate.
E1-31
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(
TVA Res onse Page 5-2 of NUMARC/NES R007, "Methodology for Development of Emergency Action Levels," Revision 2, specifies that the primary threshold for Unusual Event is operations outside the safety envelope of Technical Specifications to provide a clear demarcation between UEs and 10 CFR 50.72 notification.
The value of 10 gpm unidentified and 40 gpm identified was chosen based upon this NUMARC specification.
These values are approximately 2 times Technical Specifications which are outside the "safety envelope" of Technical Specifications.
NRC Comment ZI.D.5 The NUMARC criteria for IC SU7 and EAL SU1-1 state:
SU7 Unplanned Loss of Required DC Power During cold shutdown or Refueling Mode for Greater than 15 Minutes 1.
Either of the following conditions Exist:
a
~
Unplanned loss of vital DC power to required DC busses based on (site-specific) bus voltage indications.
OR b.
Failure to restore power to at least one required DC bus within 15 minutes from the time of loss.
The licensee equivalent EAL states:
5.2-U Unusual Event Loss of 250V DC control power to ALL unit specific 4KV shutdown boards from table 5.2-U for greater than 15 minutes.
OR Loss of 250V DC control power to unit specific 480V shutdown boards A and B for greater. than 15 minutes.
E1-32
~
I
TABLE 5.2-U UNIT 4KV SHUTDOWN BOARD APPLICABILITY APPLICABLE UNIT APPLICABLE 4KV SHUTDOWN BOARDS a ~
UNIT 1 A, B, C,
AND D UNIT 2 AJ Bf Cg AND D UNIT 3 3AJ 3B~
3Cg AND 3D NOTE 5.2:
250V DC bus voltage of less than 247 volts constitutes a loss of voltage for. that bus.
The minimum required voltage, 247 volts, is specified in a note below the tables.
The site speci.fic required voltage should be incorporated directly into the EALs.
TVA Res onse TVA concurs with the NRC comment.
TVA has revised the BFN EPIP-1 matrix to incorporate the notes and tables in the EAL block.
The notes and tables are located on the facing page.
c ~
d.
No meter or specific indicator for determination of the minimum voltage is specified.
TVA Res onse Note 5.2 to Table 5.2-U was revised to add "The voltage readings are obtained at the 250V Battery Boards feeding the referenced boards."
The NUMARC criteria for EAL SU-7 is specific that the event is unplanned.
The licensee EAL 5.2-U does not include the characteristic of an unplanned.
TVA Res onse BFN EAL 5.2-U has been revised to include the characteristic of an unplanned loss of 250 V DC control power.
It is not clear that the 247 volts provides a
15 minute margin of operation before the onset of inability to operate the required loads, as specified by the NUMARC EAL SU7 basis.
TVA Res onse BFN EAL 5.2-U basis has been revised to clarify that 247 volts provides at least a 30 minute margin of operation before the onset of inability to operate the required loads.
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Comments c.
and d. also apply to licensee EAL 5.2-S, but will not be commented on separately.
TVA Res onse ci d.
NUMARC EAL SS-3 does not refer to "unplanned."
BFN EAL 5.2-S basis has been revised to clarify that 247 volts provides at least 30 minutes margin of operation before the onset of inability to operate the required loads.
NRC Comment ZZ.D.6 The NUMARC criteria for IC SA2 and EAL SA2-1 state:
SA2 Failure or Reactor Protection System Instrumentation to Complete or Initiate an Automatic Reactor Scram Once a Reactor Protection System Setpoint Has Been Exceeded and Manual Scram Was Successful.
1.
(Site-specific) indication(s) exist that indicate that reactor protection system setpoint was exceeded and automatic scram did not occur, and a successful manual scram occurred.
The licensee equivalent EAL states:
1.2-A Alert Failure of automatic scram functions to bring the Reactor subcritical AND Manual scram or alternate rod Insertion (ARI) was successful.
a.
The NUMARC criteria requires site specific indication(s) to determine that the automatic scram setpoint was exceeded and the automatic scram was unsuccessful.
The required indication(s) are not included in the licensee's EAL.'VA Res onse The BFN philosophy that is used to determine subcriticality (or other reactor parameters) is to use all available instrumentation and not to list specific instruments.
E1-34
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s't "f!I
This philosophy is consistent with the BFN EOIs and the BWROG recommendations.
Also, the term "subcritical" has been defined in note 1.2, to be consistent with the definitions used in the BFN EOIs.
NRC Comment II.D.7 The NUMARC criteria for IC SA3 states:
SA3 Inability to Maintain Plant in Cold Shutdown.
1.
The following conditions exist:
a.
Loss of (site-specific)
Technical Specification required functions to maintain cold shutdown.
AND b.
Temperature increase that either:
Exceeds Technical Specification cold shutdown temperature limits OR Results in uncontrolled temperature rise approaching cold shutdown technical specification limit.
The licensee equivalent EAL states:
1.5-A Alert Reactor moderator temperature CANNOT be maintained below 212'F whenever Technical Specifications require cold conditions or during refueling.
a.
The NUMARC criteria requires site specific identification of the technical specification functions necessary to maintain cold shutdown and provides an anticipatory concern with, uncontrolled temperature rise.
The licensee does not provide the site specific identification or address the anticipatory concern.
TVA Res onse The BFN primary means of maintaining cold shutdown is not a technical specification function..
The glossary in the BFN EPIP-1 defines "cannot be maintained below" and includes anticipatory wording which is consistent with the EOI definitions.
This explanation has been added to the deviation document.
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NRC Comment XI.D.S The NUMARC criteria for EAL SA4 states:
/
SA4 Unplanned Loss of Most or All Safety System Annunciation of Indication in the Control Room With Either (1) a Significant Transient in Progress, or (2)
Compensatory Non-Alarming Indicators are Unavailable.
1.
The following conditions exist:
a.
Loss of most or all (site-specific) annunicators associated with safety systems for greater than 15 minutes.
AND b.
In the opinion of the Shift Supervisor, the loss of the annunciators or indicators requires increased surveillance to safely operate the unit(s).
AND c.
Annunciator or Indicator loss does not result from planned action.
AND d..
Either of the following:
1.
A significant plant transient is in progress.
OR 2.
Compensatory non-alarming indications are unavailable.
The licensee equivalent EAL states:
8.3-A Alert Unplanned loss of most or all safety system annunicators which causes a significant loss of plant assessment capability for greater than 15 minutes AND In the opinion of the Shift Operations Supervisor, increased surveillance is required to safely operate the plant AND E1-36
EITHER of the following conditions exists:
~
Compensatory non-alarming safety system indications are NOT available.
a ~
A significant transient is in-progress.
The NUMARC criteria includes the loss of safety system indicator(s) in the EAL.
Loss of safety system indication is not included in the licensee's EAL.
TVA Res onse b.
The BFN EAL 8.3-A has been revised to include loss of safety system indicators.
NUMARC requires a site specific identification of the relevant annunciators and indications included in AOPs,
No site specific identification is provided in the licensee's EAL.
TVA Res onse Since this EAL requires substantial Emergency Director judgement, it was believed that adequate guidance could be provided in the basis for the Emergency Director to properly classify. It was not felt that the use of a site specific list would be beneficial to the Emergency Director due to the extent of their training and ability to interpret the intent of the basis.
c ~
There is no definition of significant transient.
TVA Res onse Significant transient 'is defined in the glossary in EPIP-1.
Also a note was added to EAL 8.3.A that defines significant transient.
Comment IZ.D.9 The NUMARC criteria.a for EAL SS2-1 states:
(Site-specific) indication exist that automatic and manual scram were not successful.
The licensee equivalent EAL states:
1.2-S Site Area Emergency Failure of automatic
- scram, manual
a ~
The licensee has not provided site specific E1-37
1 4,
. ~
indication of unsuccessful scram as required by the NUMARC criteria.
TVA Res onse The site specific indication of a successful SCRAM is subcritical.
The BFN philosophy that is used to determine subcriticality (or other reactor parameters) is to use all available instrumentation not to list specific instruments.
T This philosophy is consistent with the BFN EOIs and the BWROG recommendations.
Also, the term "subcritical" has been defined in Note 1.2 to EAL 1.2-S to be consistent with the definition used in the BFN EOI's.
NRC Comment II.D.10 The NUMARC criteria for EAL SS4-1 state:
1 ~
Complete loss of any (site-specific) function required for hot shutdown.
, The BF equivalent EALs state:
1.5-S Site Area Emergency Suppression Pool temperature and RPV pressure CANNOT be maintained in the safe area of Curve, 1.5-1S (Heat Capacity Temperature Limit)
OR Suppression Pool level CANNOT be maintained in the safe area of Curve 1.5-S-2 (Heat Capacity Level Limit).
2.1.S Site Area Emergency Suppression Chamber pressure CANNOT be maintained in the safe area in Curve 2.1-S (Pressure Suppression Pressure Curve).
a ~
The licensee relates NUMARC SS4 to licensee EAL 1.5-S, which is the suppression pool heat capacity temperature limit and heat capacity level limit and licensee EAL 2.1-S, which is suppression pool pressure suppression pressure curve.
The E1-38
licensee's EAL meet the intent of the NUMARC criteria for loss of heat sink.
Other functions necessary for hot shutdown, such as reactivity control are not addressed.
TVA Res onse Other functions identified were level control and reactivity control.
These functions are covered by BFN EAL 1.1-S1 for level control and 1.2-S for reactivity control.
The basis has been revised to reference SS4.
NRC Comment XI.D.11 The NUMARC criteria for IC SS5 and EAL SS5-1 state:
SS5 Loss of Water Level in the Reactor Vessel That Has or Will Uncover Fuel in the Reactor Vessel.
1.
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-specific) indicators that the core is or will be uncovered.
The licensee equivalent EAL states:
1.1-S1 Site Area Emergency Reactor water level cannot be maintained above 162 in.
(TAF) a.
The NUMARC criteria for SS5 is for cold shutdown and refueling operating modes.
The licensee has combined SS5 with fission product barrier EAL 1.1-Sl.
Deviation 13 states that this is to avoid having 2 EALs only separated by operating modes..
The licensee's EAL 1.1-S1 does not address the NUMARC, criteria for loss of decay heat removal.
The licensee's basis for EAL 1.1-S1 does not include any of the applicable information regarding inadvertent reactor vessel draining. during cold shutdown and refueling.
The licensee should include a specific EAL that incorporates the NUMARC criteria for EAL SS5-1 or provide additional information that explains how the NUMARC criteria is accomplished.
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TVA Res onse The deviation document has been revised to address why loss of.,decay heat removal cooling is not included in the EAL.
The basis for EAL 1.1-S1 has been revised to include inadvertent draining of the reactor vessel during cold shutdown and refueling with the reactor vessel head installed.
NRC Comment XX.D.12 The NUMARC criteria for EAL SS6-1 states:
SS6 Inability to Monitor a Significant Transient in Progress.
1.
The following conditions exist:
a.
Loss of (site-specific) annunciators associated with safety systems.
AND b.
Compensatory non-alarming indications are unavailable.
AND c.
Indications needed to monitor (site-specific) safety functions are unavailable.
AND d.
Transient in progress.
The licensee equivalent EAL states:
8.3-S Site Area Emergency Unplanned loss of most or all safety system annunciators which causes a significant loss of plant assessment capability for greater than 15 minutes AND Compensatory non-alarming safety system indications are NOT available.
I AND A significant transient is in progress.
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4
The NUMARC criteria includes the loss of site specific safety system indicators in the EAL; Loss of site specific safety system indication is not included in the licensee's EAL.
TVA Res onse BFN EAL 8.3-S has been revised to include site specific safety system indications.
NUMARC requires a site specific identification of the relevant annunciators and indications included in AOPs,
No site specific identification is provided in the licensee's EAL.
TVA Res onse Since this EAL requires substantial Emergency Director judgement, it was believed that adequate guidance could be provided in the basis for the Emergency Director to properly classify. It was not felt that the use of a site specific list would be beneficial to the Emergency Director due to the extent of their training and ability to interpret the intent of the basis.
The use of "unplanned" is not required in the site area emergency EAL.
TVA 'Res onse The term "unplanned" has been removed from EAL 8.3-5.
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ENCLOSURE 2
TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)
REVISED COPY OF APPENDIX A EMERGENCY ACTION LEVELS UNITS 1q 2q AND 3 See the attached REP Appendix A, 133 pages