ML20059J342
| ML20059J342 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/04/1993 |
| From: | Kokajko L Office of Nuclear Reactor Regulation |
| To: | Cottle W HOUSTON LIGHTING & POWER CO. |
| References | |
| TAC-M87664, TAC-M87665, NUDOCS 9311120176 | |
| Download: ML20059J342 (15) | |
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(; E UNITED STATES
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- i NUCLEAR REGULATORY COMMISSION -
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- r wassincrow, o.c. nosswooi November 4, 1993 Docket Nos. 50-498 and 50-499.
Mr. William T. Cottle Group Vice-President, Nuclear Houston Lighting & Power Company Post Office Box 1700 Houston, Texas 77251 1
Dear Mr. Cottle:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION ON SOUTH TEXAS PROJECT, UNITS 1 AND 2 EMERGENCY ACTION LEVELS (TAC NOS. M87664 AND M87665)
The staff has completed its initial review of the proposed emergency action levels (EALs) in Revision 3 to the South Texas Project Emergency Classification Procedure, OERP01-ZV-IN01. The proposed EAls-.were reviewed against the guidance in NUMARC/NESP-007, " Methodology for Development of Emergency Action Levels." NUMARC/NESP-007 has been endorsed by the NRC in Regulatory Guide 1.101, " Emergency Planning and Preparedness for Nuclear Power Reactors," as an alternative means by which licensees can meet the' requirements in 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50.
Because of the staff's previous endorsement of the guidance in NUMARC/NESP-007, our review focused on those EALs that deviated from the guidance and those EALS that required the development of site-specific thresholds. As a result of our review, we have identified a number of EALS for which additional information is needed to determine whether the EALS conform with NUMARC/NESP-007.
We request your response to the questions within 30 days of the date of this letter to enable the staff to complete its review in a timely manner.
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100064 NRC FEE CBER COPY !
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o Mr. William T. Cottle November 4, 1993'
.g The reporting requirements contained in this letter affect fewer than-ten respondents; therefore, OMB clearance is not required under Public Law 96-511.
Sincerely, Original Signed By Lawrence E. Kokajko, Senior _ Project Manager Project Directorate IV-2 Division of Reactor Projects III/IV/V Office of Nuclear Reactor _ Regulation
Enclosure:
3 Request for Additional Information cc w/ enclosure:
See next page QlSTRIBUTION:
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Mr. William T. Cottle ~ November 4, 1993L '
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cc w/ enclosure:
Mr. David P. Loveless-
' Jack R. Newman, Esq.
Senior Resident Inspector' Newman & Holtzinger, P.C.
- l U.S. Nuclear Regulatory Commission 1615 L Street,-N.W.
P. O. Box 910-Washington, D.C.
20036 Bay City, Texas 77414 1
Licensing Representative Mr. J. C. Lanier/M. B. Lee Houston Lighting and Power Company:
1 City of Austin Three Metro Center Suite 610-1 Electric Utility Department 721 Barton Springs Road.
Bethesda, Maryland 208141 l
Austin, Texas 78704 Bureau of Radiation Control 1
Mr. K. J. Fiedler State of Texas Mr. M. T. Hardt 1101 West ~49th Street 1
Central Public Service Board Austin, Texas' 78756 P. O. Box 1771 San Antonio, Texas 78296 Rufus S. Scott Associate General Counsel Mr. G. E. Vaughn Houston Lighting.and Power Company Mr. T. M. Packett P. O. Box 61867 Central Power.and Light Company Houston, Texas 77208 P. O. Box 2121 Corpus Christi, Texas 78403 INPO Records Center 700 Galleria Parkway -
Atlanta, Georgia 30339-3064 Regional Administrator, Region-IV U.S. Nuclear Regulatory Commission 611 Ryan P1aza Drive, Suite'1000-Arlington, Texas 76011
'Mr. Joseph M. Hendrie 50 Bellport Lane Bellport, New York 11713 Judge, Matagorda County Matagorda County Courthouse 1700. Seventh Street Bay City, Texas 77414 Mr. James J..Sheppard.
General Manager, Nuclear Licensing Houston Lighting and Power Company P. O. Box 289 Wadsworth, Texas 77483
a RE00EST FOR ADDITIONAL INFORMATION SOUTH TEXAS PROJECT. UNITS 1 AND 2 EMERGENCY ACTION LEVELS REVISION TO NUMARC/NESP-007 METHODOLOGY The NRC has completed its initial review of the proposed emergency action levels (EALs) in Revision 3 to the South Texas Project (STP) Emergency Classification Procedure, OERP01-ZV-IN01. The proposed EAls were reviewed against the guidance in NUMARC/NESP-007, "Hethodology for Development of Emergency Action Levels." NUMARC/NESP-007 has been endorsed by the NRC in Regulatory Guide 1.101, " Emergency Planning and Preparedness for Nuclear Power Reactors," as an alternative means by which licensees can meet the requirements in 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50.
Because of the staff's previous endorsement of the guidance in NUMARC/NESP-007, the review focused on those EAls that deviated from the guidance and those EAls that required the development of site-specific thresholds. As a result of the initial review, a number of EALs were identified which required additional information in order to determine whether the EALs conform with NUMARC/NESP-007.
Please provide this additional information as discussed below.
1.
Fission Product Barrier Table - General a.
Note #2 on page 3 of 27 of the Emergency Classification Tables states that "CSF indicators must be valid; outside the immediate control of the operator."
It is not clear how this guidance would be applied during event classification.
Provide information regarding the use of note #2 during event classification.
b.
The NUMARC/NESP-007 guidance includes an EAL for Emergency Director Judgement in the Fission Product Barrier Table to determine whether a fission product barrier is lost or potentially lost.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
2.
Fission Product Barrier Table - Fuel Clad Barrier a.
In the " FISSION PRODUCT BARRIER DEGRADATION INITIATING CONDITION MATRIX" table under the column for the " FUEL CLAD" barrier, Failed fuel Monitor, RT-8039, greater than 8.7E2 yCi/ml is specified as an indication of a potential loss of the fuel clad barrier.
NUMARC/NESP-007 does not specify an EAL for the potential loss of fuel clad barrier based on coolant activity level.
It is not clear whether the EAL for the potential loss of fuel clad is based upon a
~
percentage of clad damage which is less than the percentage of clad damage for which the EAL for the loss of fuel clad barrier is based.
Provide justification for including this potential loss of fuel clad barrier EAL which deviates from the NUMARC/NESP-007 guidance.
In addition, provide information regarding the relationship between the potential loss of clad and the loss of fuel clad EALs.
b.
In the " FISSION PRODUCT BARRIER DEGRADATION INITIATING CONDITION MATRIX" table under the column for the " FUEL CLAD" barrier, no EALs were specified corresponding to the NUMARC/NESP-007 example EALs for core exit thermocouple readings or reactor vessel water level.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
3.
Fission Product Barrier Table - RCS Barrier a.
The " FISSION PRODUCT BARRIER DEGRADATION INITIATING CONDITION
[
MATRIX" table under the column for the loss of "RCS" barrier does not include an EAL under the RCS leak rate heading corresponding to the NUMARC/NESP-007 example EAL leak rate greater than makeup capacity as indicated by a loss of RCS subcooling.
STP did include an EAL, not specified in the NUMARC/NESP-007 guidance, under the column for the loss of "RCS" barrier i.e., critical safety function (CSF) - Yellow with subcooling <0*F.
It is not clear if this EAL is intended to substitute for the missing NUMARC/NESP-307 EAL and i
whether there is a one-to-one relationship between this STP EAL and i
the missing NUMARC/NESP-007 EAL.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
b.
The " FISSION PRODUCT BARRIER DEGRADATION INITIATING CONDITION MATRIX" table under the column for the "RCS" barrier includes the following EALs as indication of the potential loss of RCS, unisolable leak greater than 240 gpm and SG tube has ruptured and the primary to secondary leak rate is greater than 240 gpm. The basis for this EAi. states that the 240 gpm corresponds to the design flow rate of the charging pump. The concern with this EAL is that specifying a specific leak rate in this EAL may delay classification due to actions taken to determine the leak rate.
It is more appropriate to include the NUMARC/NESP-007 example EAL, unisolable leak exceeding the capacity of one charging pump..., rather than including a specific leak rate setpoint.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
q 3-l 4.
Fission Product Barrier Table - Containment Barrier l
a.
In the " FISSION PRODUCT BARRIER DEGRADATION INITIATING CONDITION MATRIX" table in the column for the potential loss of " CONTAINMENT" barrier, STP did not include an EAL which corresponds to.the NUMARC/NESP-007 EAL core exit themocouples in excess of 1200"F'and restoration procedures not effective within 15 minutes or, core exit thermocouples in excess of 700*F with reactor vessel level below top 1
of active fuel and restoration procedures not effective within 15-1 minutes. STP did include an EAL not specified in the NUMARC/NESP-i 007 guidance under the column for potential loss of containment, 1.e., critical safety function core cooling - Orange > 15 minutes.
It is not clear if this EAL is intended to substitute for the missing NUMARC/NESP-007 EAL and whether there is a one-to-one relationship between this STP EAL and the missing NUMARC/NESP-t 007 EAL.
E 1
Provide justification for this deviation from the NUMARC/NESP-007 i
guidance.
t b.
In the " FISSION PRCDUCT BARRIER DEGRADATION INITIATING CONDITION MATRIX" table in the column for the " CONTAINMENT" barrier, STP did not include an EAL corresponding to the NUMARC/NESP-007 example EAL, 1
(site-specific) PSIG and increasing.
i Provide justification for this deviation from the NUMARC/NESP-007 guidance.
c.
In the " FISSION PRODUCT BARRIER DEGRADATION INITIATING CONDITION j
MATRIX" table in the column for the " CONTAINMENT" barrier, STP included the following EAL, unexplained VALID increase in reading on i
area or ventilation monitors in adjacent areas with known LOCA. The-l wording of this EAL may cause difficulties. For example, if the i
cause of the increase in radiation monitor reading is known to be a containment bypass, it can be interpreted that the EAL no longer applies. Also, " adjacent area" is vague.
l This EAL should be reworded and/or justification provided regarding' i
how this EAL can be used by the licensee's staff to make the correct classification.
d.
In the " FISSION PRODUCT BARRIER DEGRADATION INITIATING CONDITION MATRIX" table in the column for the " CONTAINMENT" barrier, STP l
included the following EAL, primary to secondary leakage greater r
than 500 gpd'or I gpm as a potential loss of containment. There is i
no corresponding EAL in the NUMARC/NESP-007 guidance. This EAL does not appear to be adequate for inclusion in the fission product j
matrix table as a threshold for the potential loss of the i
containment fission product barrier.
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' Provide justification for this deviation from the NUMARC/NESP-007 guidance.
5.
SSI - Loss of AC Power IC SS1, " Loss of Offsite and Onsite Power to All Three 4160 V AC ESF Busses" contains the following EAL, entry into OPOP05-E0-EC00, " Loss of All AC Power,"
for greater than 15 minutes.
It is not clear whether entry into the specified procedure for 15 minutes is an adequate indication that the IC is met. One concern is that event declaration may be delayed due to the time it takes to enter the specified procedure. Another concern is that it may take longer than 15 minutes to exit the specified procedure even though power was restored in less than 15 minutes, due to administrative constraints, thereby potentially resulting in inappropriate classification of an event.
Provide information justifying the adequacy of this EAL.
In addition, provide details on the entry conditions to the referenced procedure which justifiec that these entry conditions are appropriate indicators for this IC.
6.
sal - Loss of Offsite and Onsite Power IC SA1, " Loss of Offsite and Onsite Power to All Three 4160V AC ESF Busses During Cold Shutdown or Refueling" deviates from the NUMARC/NESP-007 guidance in that no site-specific indications for the loss of AC power are specified in the STP EAL.
The STP EAL, loss of all onsite and offsite power to all AC ESF busses for greater than 15 minutes, should specify site specific indications used to determine that the IC is met, instead of the general statement concerning the loss of onsite and offsite power.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
7.
SAS - AC Power Capability Reduced to a Sinale Supply IC SAS "AC Power Capability to the Three 4160 AC ESF Busses is Reduced to a Single Power Source for Greater than 15 Minutes Such that Any Additional Single failure Would Result in loss of All AC power" contains the following EAL, only one AC ESF bus is energized and no redundant power supply is available for greater than 15 minutes. It is not clear what the " redundant power supply" is referred to in this EAL and why this EAL is not a subset of the other EAL associated with this IC, i.e., all energized AC ESF Busses are powered from the same source with no other power source available for greater than 15 minutes.
Provide information regarding the source of the redundant power referred to in this EAL and the relationship of the two EALs under IC SA5.
8.
Sul - Loss of Offsite Power to All Three AC ESF Busses a.
IC SUI, " Loss of Offsite Power to all Three 4160V AC ESF Busses for Greater than 15 minutes" deviates from the NUMARC/NESP-007 guidance
- in that no site-specific indications for the loss of AC power are specified in the STP EAL.
The STP EAL, loss of all onsite power to all ESF busses for. greater than 15 minutes, should specify site specific indications used to determine that the IC is met, instead of the general statement concerning the loss of offsite power.
Provide justification for th*s deviation from the NUMARC/NESP-007 guidance.
b.
IC SUI, " Loss of Offsite Power to All Three 4160V AC ESF Busses for Greater than 15 minutes" deviates from the NUMARC/NESP-007 guidance in that the EAL under this IC is only applicable in Modes 1,2,3, and 4.
The corresponding NUMARC/NESP-007 EAL is applicable in all Modes.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
9.
SG2 - Failure of RPS IC SG2, " Failure of the Reactor Protection System...." contains EALs which are l
indications of an extreme challenge to the ability to cool the core, i.e.,
degradation of core cooling is indicated by a valid Red or Orange path on the core cooling critical safety function status tree or degradation of heat sink is indicated by a valid Red or Orange path on the heat sink critical safety function status tree. The corresponding NUMARC/NESP-007 IC includes only CSF core cooling Red and heat sink Red as EALs for this condition.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
10.
SS4 - Complete loss of Anv Function Needed to Achieve or Maintain Hot Shutdown a.
IC SS4, " Complete Loss of Any function Needed to Achieve or Haintain Hot Shutdown" deviates from the NUMARC/NESP-007 guidance in that the EAL is only applicable in Modes 3 and 4.
The corresponding NUMARC/NESP-007 EAL is applicable in Modes 1,2,3 and 4.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
b.
The STP EAL for this IC refers to the loss of all RCS loops without specifying the indications used to determine that the RCS loops are lost.
Provide information concerning what indications are to be used as 1
evidence of the loss of all RCS loops and justification for why
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these indications are not included in the EAL.
1
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II.
SA3 - Inability to Maintain Plant in Cold Shutdown a.
IC SA3, " Inability to Maint in Plant in Cold Shutdown" contains the following EAL, I.a., loss of technical specifications required functions to maintain cold shutdown (T.S. 3.4.1.4.1, Action a., or T.S. 3.4.1.4.2, Action b).
It is not clear whether the referenced technical specifications are appropriate thresholds. for this EAL nor, if these referenced conditions are appropriate, why they could l
not be included in the EAL directly rather than referencing the i
technical specification in the EAL.
I Provide justification for the appropriateness of the referenced I
technical specifications and for not including the corresponding plant conditions directly in the EAL.
b.
Mode 5 is specified as the only applicable mode for this IC while the corresponding NUMARC/NESP-007 IC is applicable in Modes 5 and 6.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
12.
SU6 - Fuel Clao Deoradation IC SU6, " Fuel Clad Degradation," contains the following EAL, Failed Fuel Monitor, RT-8039, indicates greater than or equal to 3.0E2 pCi/ML and this reading is not the result of a crud burst as confirmed by a grab sample. The corresponding NUMARC/NESP-007 EAL is (site-specific) radiation monitor readings indicate fuel clad degradation greater than technical specification allowable limits.
It is not clear how the STP EAL relates to the feel clad degradation technical specification limits.
Provide information regarding the relationship between the STP EAL and fuel clad degradation technical specification limits.
13.
555 - Loss of Water level IC SS5, " Loss of Water Level in the Reactor Vessel that Has or Will Uncover Fuel in the Reactor Vessel" contains the following EAL, loss of reactor vessel water level as indicated by:
- a. loss of all decay heat removal cooling as determined by entry into, OPOPO4-RH-0001, " Loss of Residual Heat Removal, and, b.
the necessity for establishing a secondary heat sink, and, c.
the core is or will be uncovered as indicated by: RCS narrow range.... or RCS is saturated or approaching saturation uncontrollably...
It is not clear whether these EALs are appropriate for this IC.
For example, in Mode 6 the RCS would be saturated as a normal condition.
In addition, it is not clear what criteria would be used to determine the necessity for establishing a secondary heat sink.
Provide information justifying each of the EAls for this IC.
- . 14.
SU7 - RCS Leakaoe The basis for this IC contains the following statement, "A reasonable time is allowed to determine the source and curtail the leakage prior to declaring this event (loss of inventory, 500 gal)."
A leak of the magnitude specified in the EAls associated with this IC meets the definition for an Unusual Event and should be declared imediately.
Revise the basis for this IC or provide justification for including time to identify and stop the leak prior to declaring an Unusual Event.
15.
RG1 - Site Boundary Dose Exceeds 1000 mrem TEDE a.
TC RGI, " Site Boundary Dose Resulting from an Actual or Imminent Release of Gaseous RuMoactivity that Exceeds 1000 mrem TEDE......"
deviates from NUMARC/hiSP-007 guidance in that a note indicating the time allowed for assessing the release, i.e., 15 minutes, is not included in the EAL.
In addition the STP EAL specifies that the reading should be sustained for 30 minutes while the bases for the STP EAL contains a note which indicates that if the monitor reading is sustained for longer than 15 minutes to declare on the reading.
Provide justification for this deviation from the NUMARC/NESP-007 guidance and an explanation for the apparent contradictory time frames for the sustained release.
b.
STP did not include an EAl corresponding to the NUMARC/NESP-007 example EAL a valid reading sustained for 15 minutes or longer on perimeter radiation monitoring system greater than 1000 mrem /hr.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
16.
RS1 - Site Boundary Dose Exceeds 100 mrem TEDE a.
IC RS1, " Site Boundary Dose Resulting from an Actual or Imminent i
Release of Gaseous Radioactivity that Exceed 100 mrem TEDE......"
deviates from NUMARC/NESP-007 guidance in that a note indicating the time allowed for assessing the release.
i.e., 15 minutes, is not included in the EAL. In addition the STP EAL specifies that the reading should be sustained for 30 minutes while the bases for the STP EAL contains a note which indicates that if the monitor reading is sustained for longer than 15 minutes to declare on the reading.
Provide justification for this deviation from the NUMARC/NESP-007 guidance and an explanation for the apparent contradictory time frames for the sustained release.
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h
b.
STP did not include an EAL corresponding to the NUMARC/NESP-007 i
example EAL a valid reading sustained for 15 minutes or longer on perimeter radiation monitoring system greater than 100 mrem /hr.
Provide justification for this deviation from the NUMARC/NESP-007 1
guidance.
i 17.
RA) - Unclanned Release of Gaseous Radioactivity exceedina 200 tirnes TS Limits a.
IC RA1, "Any Unplanned Release of Gaseous Radioactivity to the Environment that Exceeds 200 times the Radiological Effluent Limits for 15 minutes or longer" deviates from NUMARC/NESP-007 guidance in that a note indicating the time for assessing the release is not included. The bases of this EAL does contain a note which correspor.ds to the note in the NUMARC/NESP-007 guidance regarding the assessment time but the time given for assessing the release is 60 minutes for STP compared to 15 minutes for the NUMARC/NESP-007 guidance.
Provide justification for this deviation from the NUMARC/NESP-007
- guidance, b.
The STP IC deviates from the corresponding NUMARC/NESP-007 IC in that EAls for unplanned liquid releases are not included.
r Provide justification for this deviation from the NUMARC/NESP-007 guidance.
c.
STP did not include an EAL corresponding to the NUMARC/NESP-007 example EAL a valid reading sustained for 15 minutes or longer on perimeter radiation monitoring system greater than 10 mrem /hr.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
18.
RU1 - Unplanned Release of Gaseous Radioactivity exceedino 2 times TS Limits t
IC RUI, "Any Unplanned Release of Gaseous Radioactivity to the Environment that Exceeds Two (2) times the Radiological Effluent t
Limits for 60 minutes or longer" deviates from NUMARC/NESP-007 guidance in that a note indicating the time for assessing the release is not included.
i Provide justification for this deviation from the NUMARC/NESP-007 guidance.
b.
The STP IC deviates from the corresponding NUMARC/NESP-007 It in that EALs for unplanned liquid releases are not included.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
c.
STP did not include an EAL corresponding to the NUMARC/NESP-007 example EAL a valid reading sustained for 60 minutes or longer on perimeter radiation monitoring system greater than.1 mrem /hr.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
19.
RA2 - Ma.ior Damaae to Irradiated Fuel IC RA2 " 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" does not contain en EAL corresponding to the NUMARC/NESP-007 EAL water level less than (site specific) feet for the reactor refueling cavity that will result in irradiai.ed fuel uncovering.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
20.
HUI - Security Event IC Hul, Confirmed Security Event Which Indicates a Potential Degradation in the Level of Safety of the Plant" includes EAL-1 extortion threat.
It is not clear how this EAL would be applied by users of the EAL procedure nor whether this EAL is an adequate plant specific indication for this IC.
Provide information describing how this EAL will be applied and justifying why this EAL is an adequate plant specific threshold for this IC.
21.
HA2 - Fire or Explosion in a Vital Area IC HA2, " Fire or Explosion in a Vital Area Potentially Affecting i
a.
Safe Shutdown or Decay Heat Removal" differs from the NUMARC/NESP-007 guidance in that the condition that more than one train of safe shutdown equipment is potentially affected is included in EAL-1.
The NUMARC/NESP-007 guidance does not contain an example EAL with this condition. The intent of the NUMARC/NESP-007 guidance for this l
IC is that only one of the redundant trains needs to be affected to declare an Alert. The concern is with the magnitude of the fire and damage to a single train of a safety system is used as an indication
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of a fire of sufficient magnitude to warrant an Alert to be decl ared.
Licensees may propose a different condition for this EAL which will be indicative of a fire of sufficient magnitude to
?
warrant an Alert declaration consistent with the basis for this NUMARC/NESP-007 10.
Provide justification for this deviation from the NUMARC/NESP-007 i
guidance.
i
b.
STP included the switchyard as one of the areas where a fire or explosion would warrant an Alert declaration.
Provide justification for including the switchyard area in this EAL.
22.
HU2 - Fire or Exolosion in the Protected Area IC HU2, " Fire or Explosion in the Protected Area or Switchyard which Affects Normal Operation" deviates from the NUMARC/NESP-007 guidance in that a condition is added to the EAL that the fire or explosion could affect normal plant operation. This added condition is not included in the corresponding NUMARC/NESP-007 ICs, i.e., IC HUI and HU2. The condition that a fire exists for greater than 15 minutes or that an explosion damages equipment or plant structures is sufficient to warrant declaration of an Unusual Event whether or not normal plant operation is affected.
In addition, the NUMARC/NESP-007 guidance specifies that a fire in buildings or in areas contiguous to (site-specific) areas are to be included as part of the EAL for this IC. The corresponding STP EAL does not include areas contiguous to (site specific) areas in the EAL.
Provide justification for this deviation from the NUMARC/NESP-007 guidance'.
P 23.
HA4 - Natural or Destructive Phenomena Potentially Affectina Safe Operation IC HA4, " Natural or Destructive Phenomena Potentially Affecting Safe a.
Operation" deviates from the NUMARC/NESP-007 guidance in that no EAL is specified for a vehicle crash. The corresponding NUMARC/NESP-007 IC includes the following EAL, vehicle crash affecting plant vital r
areas.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
b.
IC HA4 includes the following EAL, unmitigated entry of flood water into safety related structures. This EAL may result in an even' iot being appropriately classified.
For example, an event _where,..ood water is mitigated but the mitigation is ineffective, resulting in flood water potentially affecting the operability of safety related systems, may not exceed the EAL threshold for an Alert classification. On the other hand, a small amount of unmitigated flood water into a safety related structure which does not affect the operability of safety related systems could result in an Alert classification. This EAL should be evaluated to determine whether its application will result in the correct classification.
Provide justification regarding the appropriateness of this EAL.
1
J c.
IC HA4 includes the following EAL tornado or high wind causing visible structural damage which potentially affects the safety function of any of.... This EAL deviates from the corresponding NUMARC/NESP-007 EAL, i.e., tornado or high winds greater than (site-specific) mph strike within protected area boundary by specifying that a damage assessment be made and not specifying a site-specific wind speed. As stated in the NUMARC/NESP-007 guidance, this EAL is intended to address an event that may have resulted in plant vital areas being subjected to forces beyond design limits, and thus damage must be assumed to have occurred to plant safety systems.
The initial " report" should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt should be made to assess the actual magnitude of the damage.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
d.
IC HA4 includes the following EALs; EAL-4 Loss of all off-site power to all ESF busses concurrent with conditions which are predicted to make site inaccessible for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, EAL-5 Predicted or actual breach of main cooling reservoir retaining dike along North Wall, and EAL-6 essential cooling pond level less than 23.0 ft msl with no make-up available. Natural or destructive phenomena may result in the plant exceeding these EALs. However the emergency classification should be based upon the phenomena itself and not the resulting plant condition. The plant conditions specified under this IC may more appropriately be included under other ICs, e.g., system based ICs.
Provide justification for including these EALs under IC HA4 e.
IC HA4 includes the following EAL turbine failure generated missiles result in any visible structural damage potentially affecting the functionality of safety related structures, systems, or components.
This EAL deviates from the corresponding NUMARC/NESP-007 EAL, i.e.,
turbine failure generated missiles result in any visible structural 1
damage to or penetration of any of the following areas: (site-I specific list) by specifying that a damage assessment be made and not specifying a site-specific list of areas. As stated in the NUMARC/NESP-007 guidance this EAL is intended to address an event that may have resulted in plant vital areas being subjected to forces beyond design limits, and thus damage must be assumed to have occurred to plant safety systems. The initial " report" should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt should be made to assess the actual magnitude of the damage.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
i l
' j i
24.
HU4 - Natural or Destructive Phenomena Affectino Plant Operation l
IC HU4, " Natural or Destructive Phenomena Affecting Plant Operation" a.
deviates from the NUMARC/NESP-007 guidance in that no EAL is specified for a vehicle crash. The corresponding NUMARC/NESP-007 IC includes the following EAL, vehicle crash into plant structures or systems within the protected area boundary.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
i b.
IC HU4 includes the following EAL essential cooling pond level less than 25.0 ft msl.
Natural or destructive phenomena may result in j
the plant exceeding this EAL. However, the emergency classification should be based upon the phenomena itself and not the resulting plant condition. The plant conditions specified under this IC may more appropriately be included under other ICs, e.g. system based ICs.
Provide justification for including these EAls under IC HU4.
c.
IC HU4 did not include a flooding EAL as a precursor to the Alert level flooding EAL.
Provide justification for not including a flooding EAL under this IC.
l 25.
HA5/HS2 - Control Room Evacuation 2
a.
The EAL associated with IC HAS, " Control Room Evacuation" includes the condition that the plant is being controlled within 15 minutes.
IC HS2, " Control Room Evacuation and Plant Control Cannot be
~
Established" includes the condition that control...cannot be established by completion of step 12 within 15 minutes, therefore it 2
is not necessary to include the condition concerning plant control in IC HA5.
Furthermore, the statement in HA5 is not specific as to what constitutes plant control and therefore is not consistent with STP IC HS5 in this regard.
Provide justification for including this condition in this EAL.
i b.
The condition in HS2 that control...cannot be established by completion of step 12 within 15 minutes does not explicitly state the procedure the referenced step applies to.
Revise the EAL associated with HS2 to specify the procedure that step 12 is associated with or provide justification for not doing so.
In addition, provide justification as to how step 12 is indicative of establishing control.
i