ML20043A280

Forwards G Bryan Review of Plant Emergency Action Levels

ML20043A280
Person / Time
Site:	Catawba
Issue date:	05/04/1990
From:	Jamison J Battelle Memorial Institute, PACIFIC NORTHWEST NATION
To:	Khadijah West Office of Nuclear Reactor Regulation
References
NUDOCS 9005210139
Download: ML20043A280 (13)

Text

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OBallelle Pacific Northwest Laboratories Battelle Boulevard '

P.O. Box 999

- Richland, Washington 99M2 - 1 Teicphone tso9) 375-3782 : '

'May 4, 1990 '

i

,  :)

Mr.- K. S. West- -

~

' Planning, Program, 'and Management Support Branch

-0ffice of Nuclear; Reactor Regulation '

U. S. Nuclear Regulatory. Commission Washington, D. C.~20555 L

Dear Steve:

i CATAWBA NUCLEAR STATION.EAL REVIEW 4 t

Attached is the report'of Gordon LBryan's' review of the Catawba EALs. If I can' -t be~of further' assistance on this matter please call me on FTS~(509).375-3782.  ;

FeelfreetocontactGordondirectly~on(206):779-4596 concerning-the contents:  :

of-the review. ,

Sincerely, y) -

J. D. Jamison 1

Project Manager .i Operational Health Physics Group' "

HEALTH PHYSICS DEPARTMENT p

JDJijw '

Enclosure.

f cc: WH Rankin, w/ enclosure- '

RA Erickson, w/ enclosure i

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Twenty nve ye.us of scence for DOE and the Northwest

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i EMERGENCY ACTION LEVEL (EAL) REVIEW CATAWBANUCLEARSTATION(CNS)

EMERGENCY PLAN (EPLAN) REV. 90-2 May.2, 1990-I.

SUMMARY

For each of the.four accident' classifications, an audit was conducted of the:NUREG-0654 Appendix- 1 Initiating Conditions (ICs) and the corresponding-Emergency Action Levels-(EALs) contained in Catawba EPLAN rev. 90-2.- Where-  !

questions as to implementation arose, Emergency Plan Implementing-Procedure (EPIP) RP/0/A/5000/01,. change 11 retype 5, " Classification of_ Emergency" was consulted.

With the exception of the 6 ICs identified as de'viations from NUREG-0654 ini "

.the CNS Technical-Basis (TB) and NUREG-0654 Notification of unusual Event- ,

(N0VE) IC 3c '(failed fuel indication based on failed fuel monitor), all-NUREG-0654 ICs were addressed in the CNS plan and EPIP; although often in significantly modified form.

This review was made in office without access'to the Duke-standardized system nomenclature coding Westinghouse Owner's Group (WOG). Emergency Response Guidelines (ERGS),and CNS-Emergency Operating Procedures (E0Ps),-

I or the CNS Technical Specifications.and FSAR. -The McGuire SGTR AIT report was not available and would have been helpful-in evaluating CNS SGTR-,

related EAls. In addition, lack of specific knowledge of the CNS Reactor Vessel Level Indicating (RVLIS), Subcooling Monitoring (SCM)'and H2 analyzer installations -created some problems during. the review. Because of '

these limitations, the reviewer's comments.often 'nclude. questions or are based upon stated assumptions.

It appeared to the reviewer that Duke had revised its masterLEAL. guidance-based on the results of earlier McGuire and Oconet EALL reviews. Some of the problems identified in those reviews did not recur in-_the-CNS review. '

L Many of the problems identified below stem from one or more of

! the fol?owing:

Failure to include NUREG-0654 anticipatory features in CNS  !

EAls.

Conscious decisions to make the CNS EALs more constrained than [

e the NUREG-0654 1Cs intended. '

Omission of time factors included in the NUREG-0654 ICs.- l A marginal asterisk indicates those items which appeared to reduce EPLAN effectiveness in the area of EAls. A double asterisk indicates the most u important 10 items.

I 1

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5 4 .

II. ' DETAILED EAL REVIEW'AND EVALUATION COMMENTS:

1. General:

The CNS EPLAN revision and classification EPIP weie reviewed against the requirements of 10 CFR 50 and the guidance of NUREG-0654, specifically:

10 CFR 50.47, 50.72 and 10 CFR 50, Aptendix'E IV B & C

NUREG-0654 II. D. .1'. and D. 2., Emergency Classification SystemL NUREG-0654, Appendix 1 EAL Guidance In addition,-some of the-reviewer's~ decisions were based on the~ content of the following internal NRC memos:

Kane/Miraglia, Proposed Task Interface Agreement Regarding '

Review of Loss of Control Room Annunciator Events, dated 4/8/8d Congel/Boger,-Loss of Control Room Annunciator Events, dated 6/23/88 Erickson/EP' staff, NRC Approval of EALs, dated 2/23/90 The CNS TB identified 6 instances where the NUREG-0654 ICs were not L included in the CNS EAL scheme. In addition, the reviewer noted that NUREG-0654'NOUE IC 3c was not addressed in the'CN! EALs. With those L exceptions, all of the NUREG-0654 initiating conditions'were contained in l the CNS EAL scheme, although often in different form. When the' reviewer '

I concluded that the differences were acceptable, tlose differences were not l listed in'this report.

2. Review Comments: ,

NOTE: The organization of this paragra)h follows that of the CNS EPLAN revision (e,g by event category, ay classification, by IC, by-EAL)..Since multiple CNS EALs under a single IC were not numbered,'~

when necessary the EALs were identified by the sequence in which they }

appeared. Corresponding NUREG-0654 ICs.were listed parenthetically.

GENERAL: The EAL TB document basis makes. frequent use of the-statement "This EAL was taken directly from NUREG-0654", implying- >

that the CNS and'NUREG EALs agree. This-is rarely the case,

a. Event category 4.1.1, primary coolant leak

1. NOUE 1, EALs 1-7 (5): Contrary to the NUREG guidance, all EALs were constrained as follows:

Applicable only in modes 1-4. 1 Applicable only if Tech Specs required load reduction or.

cooldown.

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2. NOUE 1 (5) and elsewhere: .Although the EPLAN TB basis .

~ indicated-"...: declaration of?.....is required when the decision is made to begin a load. reduction or plant'cooldown",

the guidance on-declaration time was not incorporated into the .,

classification EPIP, the document which would actually govern R during accident classification.: ,

1

- 3. NOVE 2 (Alert'5): CNS has' reduced the classification of this 1 accident from Alert to NOUE for. mode 5 & 6~ accidents. The.

Alert classification was retained for accidents originating in:

modes 1-4 (ref. Alert 4.1'.1, EAL 1). ,

l 4.. -NOVE 2 (Alert 5): The last sentence of the' basis defined the-

~ term "unisolable" as a leak which "cannot be.readily isolated ~

from the control room or locally. in'the plant. That.

definition was not. incorporated into:the classification EPIP,

-the document which would actually' govern during accident  :

classification- .

5. NOUE 3 (6): CNS constrained'this EAL to unisolable primary. .

PORVs and code safety valves.. (NOTE: If CNS Tech Specs allow i operation with one or both pressurizer PORV block valves shut, [

this departure-from the NUREG-0654 guidance is acceptable; the accident would probably be classified as an Alert under NUREG-0654 Alert 5 in any event.)

6. Alert 1 (5): This accident is constrained to modes 1-4 under the present CNS EALs since mode 5 or 6 leakage >50 gpm is defined (in contrast to 0654)'as a NOVE. See 2A11above'.

7. Alert-1 (5): Contrary to the NUREG guidance, this EAL'was _

constrained to those leaks which cannot be isolated.in 15 -

minutes and which have resulted in a loss of SCM.'-

8. Alert 2 (2): The basis statement that SGTR~ leakage >10 gpm L represents a " primary coolant system pressure . boundary -... 4

breach (ed) which results in a loss of one fission product '

l barrier" is inconsistent with the >50 gpm definition of barrier failure contained in the basis for CNS Alert 4.1.1 EAL 1 and< ,

l also in the General Emergency. (GE) barrier criteria EAL, "

! 4.1.1.B.

L L 9. Alert 2.(2): Contrary to the NUREG guidance, this EAL' was i

constrained by the requirements that the leak rate be L identified as greater than 10 gpm and that.SCM be >0.

L 10.. Alert 3 EAL 1 and 4.1.3 Alert 1 EALs 1 and 2 (4): Small (as distinct from major fault / rapid depressurization) . steam breaks j inside containment with SGTR leakage >10'gpm were not covered.:

11. Alert 3 EAL 1 (4): Contrary to the NUREG guidance, this EAL was constrained by the requirements that the steam leak be 3

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unisolable and that SCM be >0.-

. NOTE: In the- reviewer's opinion, the overall CNS EAL treatment of'a faulted and a ruptured S/G has merit. However,-since it deviates from NUREG-0654, the reviewer did not pursue the concurrent' failings of this treatment, y

• ' 12. ' Alert 3,'EAL 2 and 4.1.3 IC l'EAL 2 (t,): The CNS EALs require field' monitoring team data. Field monitoring teams _would not

~

'be available until1after the Alert declaration.- a

-1

• • 13. SAE 1 (1): 'The CNS'IC and EAL were based ~upon exceeding . a available ECCS, capacity" asLopposed'to the NUREG-0654~IC l

" greater than makeup pump capacity.". Historically, the. f reviewer has understood the latter'to mean greater than the capacity of the available. charging pumas. The "available ECCS capacity" EAL issue was evaluated by tie McGuire SGTR AIT' team. ,

However, those findings were not :available to the reviewer. ~

The acceptability'of the " makeup-pump capacity" definition should be checked against.the AIT report findings.

14. SAE'l-EAL 1 (1): CNS added a requirement for) loss;of.SCM. ]

Although this would verify the inventory = loss,. it might also '

delay classification. If- verification was desired,' 'SCM or

.RVLIS decreasing should suffice.- (NOTE: . There11s probaETy  :

some limitation on the validity of the CNS RVLIS indication- 1 under these conditions. -If-so, it is recommended that this; a classification capacity", however be based on SI and that.. capacity exceeding)the-'"

is de fined makeup pump-j

15. SAE 2 EALs.I and 2 (5):. CNS added a tequirement that'the ,

1 affected S/G be both faulted and ruptured. Since it is .

J unlikely that this-can be determined early ln such an accident, 1 L the requirement should be deleted. 1

15. SAE 2 EAL 1.(5): The TB~ basis statement that this accident  !

constitutes' a loss of 2 barriers is incorrect. _ Although the primary) leakage ,barrier neitherhas bee'n lost- (CNS the-containment criteria nor the'. fuelisbarriers

>50 gpm have been lost by the CNS definitions. -CNS 4.1.2 GE EAL 1 defines loss of containment as incomplete-integrity or leakage greater i than tech specs or pressure greater than-60 psig or hydr _ ogen  :

greater than.9%. Loss of the fuel barrier is defined as chemistry results indicating greater than.20% clad failure or 1

EMF-53A/53B reading greater than 1100R/hr or entry into 1 i EP/1(2)/A/5000/281,ICC. .None of those conditions have been- 4 met.

17. SAE 2 EAL 2 (5): The TB states the EPs (E0Ps) will define'an  !

unisolable steam line break outside containment. Due to the WOG ERG entry limitations, this EAL is'only responsive to accidents initiated from mode 1 or 2 conditions.

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18.- GE 1 EALs 1 and 2'(Sa): CNS has constrained the NUREG-IC by requiring that SCM be lost.

• • 19. .GE 1 EALs 1 and 2 (Sa): CNS has-2 ECCS-oriented EALs. One ,

treats loss of ECCS injection and the other, loss of ECCS '

recirculation. The only-apparent reason >for this is to avoid declaring a GE if recirculation is inoperative but injection flow can be restored (see EAL 2 TB statement "If adequate ECCS-injection-flow from the FWST can be restored, then this EAL would not be applicable"). The reviewer' disagrees with that conclusion. There must be a calculated maximum water. level '

limit imposed on containment level as the recirculation shift'  :

point is exceeded due to continued injection. 'Beyond that, l containment failure and/or core melt are assured and therefore a GE:is warranted.

20. GE 1 EAL 3 (Sa):- Not recuired if the SCM corstraints Added to the NUREG-IC were removec from'CNS. EAl s 1 and 2.

21. GE 2 (Sc): Typo in NUREG reference quote, change "an" to "and".

22. GE 2 (Se): Since ECCS may be initially successful and-subsequently lost' in either the injection"or the recirculation mode, the EAL should be' revised to read "LOCA and Loss of ECCS' injection or recirculation heat-sink and....".

b. Event Category 4.1.2, fuel damage, j l'. NOUE 1 EAL 1-3 (3b): These EALs.were constrained by mode 1-5.

applicability and " load reduction or plant cooldown initiated pursuant to technical. specification 3.4.8". Tech specs were not available to the reviewer. However,:since fuel damage

. detected in mode 5 (temperature <200 degrees) could hardly result in TS-initiated cooldown and load reductions are not possible below mode 2, it appears that the EALs were,.in

~

reality, limited to modes 1-4. Mode 5-and 6.fue1~ damage.N0VEs did not appear to be covered. i

2. Alert 1 EALs 1 and 2 (1b and Ic): The reviewer assumed that ,

the 1000 times background caused an instrument alarm and that i

it equated to the NUREG-0654 criteria of 300 uCi/cc and 5% fuel failure.

If this is correct,.the Eats are acceptable, j

3. Alert-1 EAL 2 (1b and Ic): The reviewer assumed that EMF 48 .

was the letdown monitor and that 1000. times background was "

higher than the letdown isolation signal. If that were true, 1 EMF 48 would not be a valid. indicator since letdown isolation '

would have occurred,-stopping flow past.the sensor.

4. Alert 1 EAL 2: The TB indicates that a crud burst should be 5

. .. . ~

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taken into account. The EAL'does not mention crud' burst.  :

5. Alert 1 EAL 3: Typo ih basis, line 2 "does" vice " dose".

6. Alert 1 EAL 4 (Ic): The' reviewer ~ assumed that chemical _ _

I analysis would not be timely-enough.to detect an increase of 1%

failed fuel within 30 minutes. However,fthe EAL should be ,

retained as one of several alternatives. Even if it were l necessary_ to fair a curve between 2 samples taken an hour

apart, one hour recognition is better than none.

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7. SAE 1 (2): The EALs did not incorporate coolant activity '

indicators as required by NUREG-0654 IC 2. -

8. SAE 1 EAL 1 (2): _ThislEAL.was effectively.limite'd to modes 1-3 since it is contingent on' entry into. an EP procedure. The WOG -

ERG Usage Rules limit E-0 applicability to modes 1-3 and limit  !

entry into the E0P family of procedures' to entry via E-0 '(or ECA-0.0). The licensee should review this IC to determine.

whether any modification is required to cover-lower modes.  !

9. SAE'l EAL 2 (2): -The-reviewer-assumed-that CNS:followed the normal practice of valveing the H2 analyzers off service, to be placed in service within 1/2 hour:per the WOG' ERG requirement.

In some 3 loop Westinghouse. plants, the H2 analyzers are ,

rendered inoperative by a common modelfailure,; loss of the "B"- '

4160 volt vital bus, because the containment isolation inboard MOVs fail as is, closed. The reviewer recommends that the licensee evaluate the application of these comments at CNS'and,

~

if applicable, revise the-EALs accordingly.

u i

10. GE 1-EAL Al and-A2 (2): These EALs drfine clad failure'as- -

>20%, a value that exceeds the design basis, accident. Thus, CNS would not classify a GE with _a detign basis accident using. o p these EAls and the barrier criteria.  !

• • 11. GE 1 (2): This EAL would not classify an interfacing LOCA or SGTR as a GE based on the barrier criteria. None of the 7 L

containment conditions (incomplete integrity as defined by log-or critical safety function tree; containment leakage greater a than tech specs; pressure greater than 60 psig; Lor H2= greater  !

than 9%) would epply to those accidents

c. Event Category 4.1.3, Steam System Failure.

l

1. NOVE-1 (17): This EAL was constrained by the requirement that-SI or MSIV closure occur. This constraint was an attempt to define " rapid" as used in the NUREG IC. The reviewer recommends that it be accepted as a v4.11d EAL,

2. Alert 1 EAL 1 (4): This EAL is constrained by the nee'd for the '

steam line break to be outside contairiment, for the SGTR to be-6 '

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"known" and for SCM to be >0.

• - -3. This EAL requires input from field

-Alert 1 EAL 2 (4):

monitoring teams. However,-i.; formation -from those teams is usually not available'until some timea'fter the declaration of

.an Alert. ,

1 4.- SAE 1lEAL 1 (5): This-EAL requires that the steam break be on

• j the -

b than; 290 ruptured R/hr,S/G. Given the the'o)erator EMF-53A could. or 53B presume reading

~the fault togreater be on the ruptured S/G. Tierefore, the. requirement:for the operator to ensure that the break is,on the-ruptured S/G is redundant, i

confusing and should be-eliminated,

d. Event Category 4.1;4, High Radiation / Radiological Effluents.

1. Alert.1 EAL 2 (6): It appears that EAL 2 isLincluded in EAL'1,

2. GE 1 EAL 4:(la): The reviewer did.not understand the'CNS constraint to a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> dose calculation.

e. Event Category 4.1.5, Loss of Shutdown Functions.

1.. Alert 1 (10): The EAL was_ deficient'in that'it applied only to mode 5 or 6 entry. Alert would not be declared if there were a  ;

loss of any function needed for plant cold shutdown while'in '

modes 1-4.

2. Alert 1 (10):1 CNS added the constraint'that SCM be lost.

, 3. Alert 2 (11): The reviewer disagrees strongly with the last 2 sentences in the basis which state that the EAL does not apply if an inadvertent reactor trip signal is initiated which does not involve an actual transient and results in a. failure to trip. This disagreement is based on-the assumption that-the NUREG IC was intended to cover both an ATWSiand a non-ATWS failure to complete a scram (e.g. an RPS system failure without a transient). '-

i l 4. SAE 1 EAL 1 & 2 (8): CNS addition of the requirement-that SCM l

be lost is inconsistent with NUREG-0654.

5. SAE 1 EAL 2 (8): This EAL is oriented to feed flow. A '

steaming path is also required.

6. SAE 2 EAL 1-(9): The NUREG-0654 IC qualification of no core damage immediately obvious was not included in the CNS EAL.  !

7. SAE 3 & GE 3: These EALs cover.the mode 5/6 loss of DHR and appear to be an excellent addition to-those required by the i NUREG.

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U ** 8. The IC and EAL both constrain the.NUREG-0654 IC by GE 1 (5b):

the additional requirement that feed'and bleed cannot bel

' established or maintained. The reviewer strongly. disagrees with that constraint. The intent of the guidance is that GE: ,

should be declared. based on the-loss:of the secondary heat. '

sink,'regardless of whether: feed and bleed is-in progress. .

9. . GE 2 (Sc): This EAL' omits the portion of the IC concerningc core damage,

f. Event Category 4.1.6, Loss of Power'.

1. NOUE 2, EALs 1 & 2.(7): The issue here should be:whether both' vital 4160 volt buses are: energized, not-EDG operability..

J3

2. Alert 1/ Alert 2 (Alert 7/SAE 6):' In modes 5 & 6, CNS EAls do-

-not require an Aler.t declaration;for a loss of"all'AC powerefor-less than 15 minutes, nor~do they require.a SAE for loss of'all AC for more than 15 minutes. Although the reviewer noted that loss-of-DHR-related EALs were treated. adequately and separately from the power outage problem, he concluded that the CNS-constraints on the-AC power outage EALs were not justified. g

3. Alert -3/ Alert 4 (Alert 8/SAE '7): Refer to previous comment .

t (paragraph.II.2.f.2.). The same comments apply here, although 3 to DC rather than AC power.

g. Event Category 4.1.7, Fires'and Security Actions..

1. NOUE 1 (10): The CNS constraint " takes mo're than 10 min.-to. t extinguish" differed from the NUREG-0654 IC " lasting more than 3 10 minutes". 'While the reviewer agrees:that verification of a i' fire should be required before declar,. tion, he disagrees with '

the modif.ication which counts all timm asidead time until the fire brigade arrives on_ scene.

2. NOUE 2 EAL 3 (12): The NUREG IC states "attempte_d. entry"; the

CNS EAL requires actual entry into the protected area, t l

l 3. Alert 1 (13): The CNS~EAL is constrained to safety systems f required for the current operating mode. j

4. Alert 1 EAL 2 & SAE 1 EAL 2: These EALs are~ redundant to ,

4.1.10 Alert J (20) and SAE 1 (18)'. (Redundancy is' acceptable).

5. SAE 1 EAL 1 (11): The IC discusses fire " compromising" the-  !

functions of safety systems. The CNS EAL requires that the fire defeat both trains of a safety system. . Using the

' dictionary definition of compromising,(something midway), the CNS EAL is more constrained-than intended by the NUREG IC.

h. Event Category 4.1.8, Spent Fuel Damage.

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• • 1. Alert 1 EALs 1 & 2L(12): ' The CNS EALs are based on i "significant" spent fuel handling accidents which release 10 times Tech Spec effluent levels . The. basis also states that the release is " grossly" in excess of Tech Specs and indicates- -

. a " serious" breach" of the fuel clad. The Alert-IC addresses-(any) fuel damage' accident with (any) release of radioactivity.

Major accidents are covered in. SAE 10 IC..

2. SAE1EALs1-4-(10): The'CNS EALs were constrained by the requirement for an actual release.- 1 Major damage with an impending release would not result in an.SAE declaration.- '

F

i. Event' Category 4.1.9,-Naturali Disaster's andL0ther Hazards.

1. General-Comment: In this and other. event categories,.the CNS-  ;

ICs and EALs generally omit the "potentially":and " projected" 4 aspects of the guidance,.thus eliminating the anticipatory intent of the NUREG-0654 ICs.

2. NOUE 1 IC.(13a): To be consistent with.the NUREG-0654 guidance, the IC should be revised to ".... felt in plant OR' -

detected ...".

' ~

3. . NOUE 1 (13a): The EALs did not include an earthquake felt'in-plant.

4. NOUE 3,-S (13c, 14b): Contrary'to.NUf.EG-0654 guidance,-these.  ;

-EALs require damage to occur as a prerequisite to NOVE  ;

declaration.

5. NOVE 3 (13b, c, d defines " severe we).and ather" Alert 2 (A17flood..

to include b-d, 18 a-c): .The tsunami TB rhurricane, hurricane surge, seiche or sustained winds >60 mph. That s definition is not included in'the EPIPJEALs. l

6. NOUE 5, 6 (14b, 14c): These'EALs are-constrained by the.

l requirement that damage occur to equipment' or structures needed for plant operation. .

7. NOVE 6, 7 (14c, 14d): These EALs did not apply "near site". -l l 8. NOUE 7 (14d): This EAL was constrained to instances involving  ;

evacuation or injury.  ;

i l- 9. Alert 1 (17a): Typo; NUREG reference should be Alert 17a, not-  :

l- NOVE 17a.

t

10. Alert 2 (A17 b-d, 18 a-c): Contrary to NUREG-0654 guidance, this EAL requires damage to occur as a prerequisite to Alert -!

declaration, b

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11. Alert 2 (A17 b-d, 18 a-c): This EAL is constrained to modes 5 and 6 only and then only to instances which cause damage resulting in inability to maintain cold shutdown and which have progressed to loss of SCM.

12. Alert 3(18d): This EAL is constrained by mode 5 and 6 applicability plus the recuirements for loss of SCM and access denied to systems requirec to maintain cold shutdown.

13. SAE1(15a): .The TB acknowledges that an earthquake beyond SSE has the potential to cause damage which may not be readily ap)arent to equipment needed for plant control. It also states "T1e determination of whether an earthquake was greater than the SSE level will have to be made based on a technical review of the recording tape and seismic plates" and "may take a long period of time". In the reviewer's opinion, this EAL is unsatisfactory. Accident classification should be based on parameters that are readily observable, not values which take a long time to determine.

14. SAE 3 (15b c 16 a-b): This EAL is ct.nstrained by the requirements for mode 1-4 applicability, damage resulting in inability to establish or maintain hot shutdown, and loss of SCM.

15. SAE4(16c): This EAL did not include the IC " entry of uncontrolled flammt.ble gases into vital areas". (The CNS definitionof" plant"areasdoesnotincludeallvitalareas).

16.. SAE4(16c): The IC concerns constitutes a safety problem. prohibini access CNS defines thiswhich as pertaining to systems needed to establish or maintain hot shutdown.

17. SAE 4 (16c): The EAL is applicable only in modes 1-4 and then only if SCM has been lost,

j. Event Category 4.1.10, Other Abnormal Plant Conditions.

1. NOVE 1 (1): Inadvertent ECCS injection was included within the IC but excluded from the CNS EAL.

• 2. NOUECEAL1(4): It appeared that the EAL did not include tech spec mode temperature limits, e.g. inadvertent temperature escalation resulting in an unplanned mode change.

NOUE 2 EALs 1 and 2 (4): The CNS EAls were constrained to i particular modes.

4. NOVE2EAL2(4): The EAL does not include exceeding LTOP (low temperature overpressure protection) limits.

5. NOUE3(8): These EALs are constrained to mode 1-4 10

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• i 3..

- apnlicability(acceptable). EAL 1 considers only automatic i valves (probablyacceptablesincedesigncriteriausually j requires remote operators on valves in lines of more than 2  ;

inch diameter). The EAls are further constrained to require  ;

cooldown or load reduction (probably ok; tech specs not available to check).

6. NOVE 4 EAL 2 (9): This EAL assumed the only possible cause of l loss of the fire protection system fuiction was a loss of fire  :

protection water pumps. If this is the case, the EAL is -

acceptable. It also assumes there are no tech specs requiring ,

shutdown on inoperative Halon or C02 systems (probably true). l

7. NOVE5(11): CNS did not-include the plant computer or the i SPDS. The meteorological instrumentation EAL is constrained by the requirement to be unable to contact the NWS. ,

8. NOUE 6 EAL 1 and also in the EPIP (16): This EAL defines  ;

contaminated as 5000 dpm/100 cm2. Why not use cpm? The meter reads out in cpm, not dpm. The T8 notes that 5000 dpm corresponds to 150 c>m on a frisker, in the reviewer's experience, the fris <er efficiency factor is usually 10. In .

that case, 150 cpm corresponds to 1500 dpm.

9. NOUE6EAL1(16): This EAL defined " contaminated" as 150 cpm. ,

Although this may be the CNS definition, in the reviewer's experience, it is usually 100 cpm above background. ,

• 10. NOUE 7 (15): CNS has cou trained this EAL by eliminating plant staff and state authorities. (Eliminition of plant staff is acceptable; it will happen outside the EALrequirements).

11. NOVE 7 (15): The s ecific examples of pipe cracking and exceeding cooldown imits are contained in the TB but not in the EAL or the EPIP EAL.

12. Alert 1 (20): The EAL was constrained b in the process of being established ... y the statement "or is

13. SAE 1 (18): The EAL omitted the 15 minute time limit from NUREG-0654.

14. SAE 1 (18): The EAL is constrained by the requirements that control cannot be established from the auxiliary shutdown panels and control has or is being established frc,m the SSF. -

NOTE: The CNS EAL 1 would be acce> table to the reviewer, given elimination of the "or is being" pirase and addition of the 15 minute requirement, provided CNS continues to declare a GE based on the GE 1 EAL, evacuation of the CR with control not being established from any plant location.

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a III. DEVIATION REVIEW (pages 149 & 150 ofEPLANchange) i 1

NOTE: Paragraph numbers below correspond to CNS deviation numbers. l

1. Reviewer concurs.

2. Reviewer concurs. There is a typo; the NUREG-0654 reference should be 18e, not 14e.  ;

3. -For the current EALs the reviewer concurs. This logic should-bereviewedforapplIcabilityafterchangesresultingfromthis review are incorporated.

4. Reviewer concurs.

5. For the current EALs the reviewer concurs. This logic should bereviewedforappilcabilityafterchangesresultingfromthis review are incorporated. ,

6. Reviewer concurs. The first two bulleted internal NRC memos of paragraph-11.1 above pertain.

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