ML20062J450

Requests Addl Info Re Proposed EAL Changes in Util Generating Station Emergency Plan Annexes.Proposed EALs Reviewed Against Guidance in NUMARC/NESP-007,rev 2, Methodology for Development of Eals

ML20062J450
Person / Time
Site:	Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle, 05000294
Issue date:	10/27/1993
From:	Randy Erickson Office of Nuclear Reactor Regulation
To:	Dyer J Office of Nuclear Reactor Regulation
References
NUDOCS 9311050278
Download: ML20062J450 (82)

Text

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October 27, 1993 MEMORANDUM 10:

James E. Dyer, Project Director i

Project Directorate III-2 1

Division of. Reactor Projects III/IV/V 1

Office of Nuclear Reactor Regulation d!

FROM:

Robert A. Erickson, Chief 1

Emergency Preparedness Branch Division of Radiation Safety and Safeguards-Office of Nuclear Reactor Regulation e

i

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED EAL CHANGES IN COMMONWEALTH EDISON'S GENERATING STATION EMERGENCY PLAN (GSEP) ANNEXES By letter dated September 1,1993, as supplemented by letter dated October 1, 1993, Commonwealth Edison Company (Ceco) submitted proposed changes to the emergency action levels (EALs) in their GSEP Annexes for the staff's review 1

and approval. The Emergency Preparedness Branch has completed its initial review of the proposed EALs and, as a result, a number of EAls were identified j

which require additional information in order to determine whether the EALs

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conform with applicable guidance and requirements.

The proposed EALs were reviewed against the guidance in NUMARC/NESP-007, Rev.

2, " 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 Reactors," as an alternative means by which

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licensees can meet the requirements of 10 CFR 50.47-(b)(4) and Appendix E to 10 CFR Part 50. Details of each review are enclosed.

If you have any questions concerning this matter, please contact Scott Boynton or Jim O'Brien at 504-3924.

Original signed by R. Erickson Robert A. Erickson, Chief Emergency Preparedness Branch Division of Radiation Safety and Safeguards Jld44M)

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Enclosures:

Dresden review

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Braidwood review 002056 a1 r v ew Quad Cities review Zion review DISTRIBUTION: See next page OFC 1 PEPB:NRR PEPB:NRR _

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UNITED STATES

-==.%g NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION

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• P DIVISION OF RADIATION SAFETY AND SAFEGUARDS EMERGENCY PREPAREDNESS BRANCH e

RE:

REQUEST FOR ADDITIONAL INFORMATION ON PROPOSED EMERGENCY ACTION LEVEL CHANGES IN REVISION LAS-93-02 7

OF THE LASALLE EMERGENCY PLAN TAC NOs:

M8733I and M87332 1

The NRC has completed its initial review of the proposed emergency action levels (EALs) in Revision LAS-93-02 to the Commonwealth Edison Generating Stations Emergency Plan (GSEP) Lasalle Station Annex. 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, 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 i

the EALs conform with NUMARC/NESP-007. Please provide this additional information as discussed below.

A.

GENERAL COMMENT

S The licensee did not include the NUMARC criteria relating to judgement of the Emergency Director for fission product barrier loss or potential loss in any of the fission product barrier EALs. These EALs should be incorporated into the emergency classification scheme orjustification should be provided for their omission.

3 Definitions between the plants are not consistent For example: Dresden defines Valid

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as " Reading are assumed valid unless circumstances cause the reading to be suspect."

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Inalle and Quad Cities define Valid as "A reading confirmed by redundant measurement, instrumentation, local reading or grab sample." The licensee should use the same definitions at all the nuclear plants.

i

i B.

EAL SPECIFIC COMMENTS Recoenition Category R - Abnormal Rad levels / Radiological Effluent 1.

Subcategory RG1 - 1 Rem Total Effective Dose Eauivalent (tede) OR 5 Rem Committed Dose Ecuivalent (cde) to the Thyroid NUMARC AG1 - Abnormal Rad Levels / Radiological Effluent example EALs state:

1.

A valid reading on one or more of thefollowing monitors that exceeds or is expected to exceed the value shown indicates that the release may have exceeded the abow criterion and indicates the need to assess the release with (site-specipcprocedure):

(site-specipc list)

Note: If the monitor reading (s) is sustainedfor longer than 15 minutes and the required assessments cannot be completed within this period, then the declaration must be made based on the valid reading.

+

2.

A valid reading sustainedfor 15 minutes or longer on perimeter radiation monitoring system greater than 1000 Mr/hr. (for sites hasing telemetered perimeter monitors]

3.

Valid dose assessment capability indicates dose consequences greater than 1000 mR whole body or 5000 mR child thyroid.

4.

Field sun'ey results indicate site boundary dose rates exceeding 1000 mR/hr expected to continuefor more than one hour; or analysis offeld survey samples indicate child thyroid commitment of 5000 mRfor one hour ofinhalation.

12salle EAL Abnormal Rad Levels / Radiological Effluent RG1 threshold values state:

ONE of thefollouing when Drywell Radiation level 2 94 Rfhr, or Reactor Vessel Level s -161 inches, or Radiation level 2 1 R/hr on Refuel Floor indicating clad / core damage:

1.

The station total release as indicated by the SUM of VALID readings of both units on thefollowing monitors indicate the release has or is ezpected to exceed 1 Rem total efective dose equivalent (tede) OR S 2

1

Rem committed dose equivalent (cde) to the thyroid and indicates the need to assess the release with dose projection models.

i The Sum op Vent Stack WRGM, AND SBGT WRGM 2 5.9E+08 pCi/sec 2.

Dose assessment results indicate dose consequences of1 Rem (tede), or Dose assessment results indicate dose consequences of 5 Rem (cde) to the thyroid.

3.

RESTRICTED AREA BOUNDARY dose rates 21 R/hr expected to continuefor 2 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or Analysis indicates 5 Rem (cde) to the thyroid at the RESTRICTED AREA BOUhDARY.

t 4.

Valid A-model EDluent Release Report indicating a General Emergency C_OMMENT: The licensee inclusion of drywell radiation level, vessel level, and refuel floor radiation level is inconsistent with the guidance and potentially confusing. A valid (confirmed) stack monitor release in excess of the calculated threshold value is sufficient to classify the event. All reactor emergency events that cause a high release nte may not trigger one of the three entry level conditions. The similar EALs for CECO PWRs do not include this entry condition requirement. The licensee should eliminate these conditions in the EAL or provide justification on their benefit.

RG1 does not include the following note which is contained in the corresponding NUMARC/NESP-007 IC, NOTE:

If the monitor reading (s) is sustainedfor longer than 15 minutes and the required assessments cannot be completed within this period, than the declaration must be made based on the valid reading.

l Providejustification for this deviation from the NUMARC/NESP-007 guidance.

The licensee basis for threshold value #4 states that the A-model reports at 1000 mrem /hr. No mention is made about the NUMARC criteria of 5000 mR child thyroid dose. Information should be provided on the capability of the A-model to assess thyroid dose.

3 i

2.

Subcategory RS1 - 100 mrem Total Effective Dose Eauivalent (tede) OR 500 mrem Committed Dose Eauivalent (cde) to the Thyroid NUMARC ASI - Abnormal Rad Levels / Radiological Effluent example EALs state:

1.

A valid reading on one or more of thefollowing 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-specipcprocedure):

(site-specipe list)

Note: If the monitor reading (s) is sustainedfor 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.

t 2.

A valid reading sustainedfor 15 minutes or longer on perimeter radiation monitoring system greater than 100 mR/hr. (for sites having telemetered perimeter monitors]

3.

Valid dose assessment capability indicates dose consequences greater than 100 mR whole body or 500 mR child thyroid.

4.

Field survey results indicate child indicate site boundary dose rates

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exceeding 100 mR/hr expected to continuefor more than one hour; or analysis offeld survey samples indicate child thyroid commitment of 500 mRfor one hour ofinhalation.

Lasalle EAL Abnormal Rad Levels / Radiological Effluent RSI threshold values state:

ONE of thefollowing yhen Drywell Radiation level k 94 R/hr, or Reactor Vessel Level s -161 inches, or Radiation level 21 R/hr on Refuel Floor indicating clad / core damage:

1.

The station total release as indicated by the SUM of VALID readings of Units 2 and 3 on thefollowing monitors indicate the release has or is expected to exceed 100 mrem total efective dose equivalent (tede) OR 500 mrem committed dose equivalent (cde) to the thyroid.

The Sum of-Vent Stack WRGM, AND 4

i SBGT WRGM:

2 5.9E+07 pCi/sec

(

2.

Dose assessment results indicate dose consequences of100 mrem (tede), or Dose assessment results indicate dose consequences of 500 mrem (cde) to the thyroid.

3.

RESTRICTED AREA BOUNDARY dose rates 2100 mR/hr expected to continuefor 21 hour2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br />, or Analysis indicates 500 mrem (cde) to the thyroid at the RESTRICTED AREA BOUhDARY.

4.

Valid A-model Ejluent Release Report indicating a SITE Emergency

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_ COMMENT: The licensee inclusion of drywell radiation level, vessel level,-

and refuel floor radiation level is inconsistent with the guidance and potentially confusing. A valid (confirmed) stack monitor release in excess of the calculated threshold value is sufficient to classify the event. Furthermore, all reactor emergency events that cause a high release rate may not trigger one of the three entry level conditions. The similar EALs for CECO PWRs do not include this entry condition requirement. The licensee should eliminate these conditions in the EAL or providejustification on their benefit.

RSI does not include the following note which is contained in the corresponding NUMARC/NESP-007 IC, NOTE:

If the monitor reading (s) is sustainedfor longer than 15 minutes and the required assessments cannot be completed within this period, than the declaration must be made based on the valid reading.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

The licensee basis for threshold value #4 states that the A-model repons at 100 mrem /hr. No mention is made about the NUMARC criteria of 500 mR child thyroid dose. Information should be provided on the capability of the A-model to assess thyroid dose.

3.

Subcategory RA2 - Release 2 10 X ODCM limits for 2 15 Minutes.

NUMARC AA1 - Abnormal Rad Ixvels/ Radiological Effluent example EALs state:

5 i

l 1.

A valid reading on one or more of thefollouing monitors that exceeds or is apected to aceed the value shown indicates that the release may have acceded the above criterion and indicates the need to assess the release with (site-specipcprocedure):

(site-specipc list)

Note: If the monitor reading (s) is sustainedfor longer than 15 minutes and the required assessments cannot be completed nithin this period, then the declaration must be made based on the valid reading.

2.

Conprmed sample analysisfor gaseous or liquid releases indicates

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concentrations or release rates in acess of(200 X site-specipc technical specipcations)for 15 minutes or longer.

3.

A valid reading on perimeter radiation monitoring system greater than 10 mR/hr sustainedfor 15 minutes or longer. [for sites having telemetered perimeter monitors]

4.

Valid ir.dication on automatic real-time dose assessment capability greater than (200 X site-specipe technical specipcations)for 15 minutes or longer. ffor sites having such capability]

Lasalle EAL Abnormal Rad Levels / Radiological Effluent RA2 threshold values state:

ONE of thefollowing wher1 Drywell Radiation level < 94 R/hr, or Reactor Vessel Level > -161 inches, or Radiation level < 1 R/hr on Refuel Floor indicating no clad / core damage:

1.

The station total release as indicated by the SUM of VALID readings of both units on thefollouing monitors indicates that the release may have aceeded k 10 X ODCM limits and indicates the need to assess the release:

The Sum of:

Vent Stack MRGM, AND SBGT MRGM:

a.

h 6.5E+06 pCi/sec b.

Liquid Releases:

t 6

7 UNPLANNED Liquid Releases k 10 X the ODCM maximum instantaneous release limit.

2.

Grab sample indicate concentrations or release rates 210 X she ODCM maximum instantaneous release limitfor h 15 minutes.

3.

RESTRICTED AREA BOUNDARY dose rates k 10 mR/hr expected to continuefor k 15 minutes.

4.

Valid A-model Efluent Release Report indicating an ALERT.

COMMENT: The licensee inclusion of drywell radiation level, vessel level, and refuel floor radiation level is inconsistent with the guidance and potentially confusing. A valid (confirmed) stack monitor release in excess of the calculated threshold value is sufficient to classify the event. Furthermore, all reactor emergency events that cause a high release rate may not trigger one of the three entry level conditions. The similar EALs for CECO PWRs do not include sis entry condition requirement. The licensee should eliminate these conditions in the EAL or provide justification on their benefit.

RA2 does not include the following note which is contained in the corresponding NUMARC/NESP-007 IC, NOTE:

If the monitor reading (s) is sustainedfor longer than 15 minutes and the required assessments cannot be completed within this period, than the declaration must be made based on the valid reading.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

IC RA2 deviates from NUMARC/NESP-007 in that the EAL for releases is set at 10 x ODCM limits whereas NUMARC/NESP-007 specifies 200 times the radiological technical specifications as the threshold for this EAL (ODCM values can be used for sites that have eliminated radiological technical specifications). The basis for the Lasalle IC states that "The Alert value for gaseous effluents was reduced to 10 x ODCM to ensure sequential classifications." It is not clear from the information provided why this reduction is necessary.

Provide justification for this deviation from the NESP guidance.

7

The licensee does not provide site specific monitor /s for a liquid release. If l

installed, the monitor /s should be specified and threshold values provided in the EAIJs.

4.

Subcategory RU2 - Release h 2 X ODCM for b 60 Minutes.

i NUMARC AUl - Abnormal Rad Levels /Radiologiul Effluent example EALs state:

1.

A valid reading on one or more of thefollouing monitors that exceeds the 'value shown" (site-specifc monitors) indicates that the release may hate exceeded the above criterion and indicates the need to assess the release with (site-specipcprocedure):

(site-specife list)

Note: If the monitor reading (s) is sustainedfor longer than 60 minutes and the required assessments cannot be completed within this period, then the declaration must be made based on the valid l

reading.

2.

Confinned sample analysisfor gaseous or liquid releases indicates concentrations or release rates with a release duration of 60 minutes or longer in excess of(2 X site-specifc technical specifcations).

7 L

3.

A valid reading on perimeter radiation monitoring system greater than i

0.10 mR/hr above nonnal backgroundfor 60 minutes. (for sites having i

telemetered perimeter monitors]

4.

Valid indication on automatic real-time dose assessment capability greater than (site-specifc value)for 60 minutes or longer. [for sites c

i having such capability]

Lasalle EAL Abnormal Rad Levels / Radiological Effluent RU2 threshold values state:

5 ONE of nefollowing when Drywell Radiation level < 94 R/hr, or Reactor l

Vessel avel > -161 inches, or Radiation level < 1 R/hr on Refuel Floor indicating no clad / core damage:

1.

The station total release as indicated by the SUM of VALID readings of both units on thefollowing monitors indicates that the release may have exceeded h 2 X ODCM limits.

i 8

i I

l

}

The Sum of:

Vent Stack WRGhl AND SBGT WRGM:

a.

2 1.3E+06 pCi/sec b.

Liquid Releases:

UNPLANNED Liquid Releases 2 2 X the ODCM maximum instantaneous release limitfor 60 minutes.

2.

Grab sample indicate concentrations or release retes 2 2 X the ODCM maximum instantaneous release limitfor 2 60 minutes.

3.

Valid A-model Efluent Release Report indicating an UNUSUAL EVENT.

.CQL* MENT: The licensee inclusion of drywell radiation level, vessel level, and refuel floor radiation level is inconsistent with the guidance and potentially confusing.. A valid (confirmed) stack monitor release in excess of the calculated threshold value is sufficient to classify the event. Furthermore, all reactor emergency events that cause a high release rate may not trigger one of the three entry level conditions. The similar EALs for CECO PWRs do not include this entry condition requirement. The licensee should eliminate these conditions in the EAL or provide justification on their benefit.

The licensee does not provide site specific monitor /s for a liquid release. If instalbd, the monitor /s should be specified and threshold values provided in the EAUs.

Reccenition Cateeorv F - Fission Product Barrier Deeradation 5.

Subcategory 1.a _ Containment pressure The NUMARC table 3, Primary Containment Barrier Example EALs, Loss example #1, Drywell Pressure states:

Rapid unexplained decreasefollowing initialincrease OR Drywellpressure response not consistent with LOCA conditions.

The Lasalle EAL 1.a - Containment Pressure threshold value for loss states:

i Rapid pressure decrease in containment after increase without containment spray.

9

COMMEN_n The licensee omitted the NUMARC criteria, Drywell pressure response not consistent with LOCA conditions, from this EAL. However, the licensee does explain in the basis for this EAL that " Containment pressure should increase as a result of mass and energy release into the containment from a LOCA."

The licensee should revise this EAL to be consistent with the NUMARC EALs or provide a rationale in the basis for the variations.

6.

Subcategory 1.c.2 - Cpntainment Breached /Bynassed The.Lasalle EAL 1.c.2 - Containment Breached / Bypassed threshold value for loss states:

UNISOLABLE breach ofprimary containment.

COMMENT: The licensee basis for this EAL basis states:

"UNISOLABLE - A breach that is not readily isolable OR attempts for immediate isolation of the breach have been made and were unsuccessful.

Attempts for isolation should be made prior to the accident classification.

LOSS - an unisolable breach implies that a breach is NOT readily isolable OR attempts for immediate isolation of the breach have been made and were unsuccessful. Attempts for isolation should be made prior to the accident classification. Ifisolable upon identification no declaration need be made under this EAL although other EALs may be applicable. A breach of primary containment refers to a loss of primary containment integrity as described in the Technical Specifications definitions or primary containment Limiting Conditions for Operation (LCO)."

The terms "readily" and "immediate" are not defined. The term " attempts" implies more than one try at isolation, but does not define the number of attempts. The wording "If isolable upon identification..." implies some time to identify the breach location, but no time period is provided. There is no NUMARC EAL that directly correlates to this licensee EAL.

The licensee should provide clear definition for the terms used in this EAL.

The licensee should provide additional information for the inclusion of this EAL in the classification scheme.

i 7.

Subcategory 1.d - Containment Radiation Monitors.

NUMARC Primary Containment Barrier, Example number 3, Significant l

Radioactive Inventory in Containment.

10

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m The Lasalle basis for this parameter states:

The value of 8000 R/hr uncorrected is conservative up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after shutdown. A four hour time is used to provide reasonable assurance that the Technical Support Center personnel uvuld be available to provide an evaluation to determine if cladfailure has exceeded 20%.

COMMENT: NUMARC does not discuss a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time for the corresponding EAL basis. The licensee use of a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> window is potentially confusing.

The licensee basis needs to be clear that the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time period does not delay the classification and that an assessment > 20% fuel clad will be treated as an equivalent threshold value.

8.

Subcategory 2.c -' Fuel Clad.

[

NUMARC Fuel Clad Barrier EAL example #3, Drywell Radiation Monitoring.

The Lasalle basis for this parameter states:

il 2000 R/hr uncorrected is a value which is conservative up to 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />sfollomng a reactor shutdown. A four hour time is used to provide reasonable assurance j

that the Technical Suppon Centerpersonnel svuld be available to provide an~

i evaluation to detennine ifcladfailure has exceeded 5%.

]

COMMENT: NUMARC does not discuss a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time for the corresponding EAL basis. The licensee use of a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> window is potentially confusing.

The licensee basis needs to be clear that the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time period does not delay -

l the classification that an assessment > 5% fuel clad will be treated as an i

equivalent threshold value.

9.

Subcategory 3.a.1 - RCS Leakrate

]

o The NUMARC table 3, RCS Barrier Example EALs, loss example #1, RCS Leak Rate states:

l fi The ' Loss" EAL is based on design basis accident analysis which show that j

. even ifMSIV closure occurs within design limits, dose consequences ofsite

]

from the 'puf release would be in excess of10 millirem. Thus, this FAL is

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includedfor consistency with the Alen emergency classification.

l The IAsalle EAL 3.a.l.- RCS Leakrate threshold value for loss states:

LOSS: UNISOLABLE Main Steam Line Break.

i

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11-l 1

i i

l a,

-v 9

A

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POTENTIAL LOSS: UNISOLABLE RCS Leakage k SO GPM.

COMMENT: The licensee basis defines UNISOLABLE as: "A leak that is NOT readily isolable OR attempts for immediate isolation of the leak have been made and were unsuccessful. Attemps for Isolation should be made prior to accident classification." The licenste deals with unisolable primary system leakage outside the drywell in EAL #3.a.2. This EAL, #3.a.1, is directed to RCS leakage inside containment however, it does not specifically state inside containment. NUMARC, in table 3, uses the qualifier UNISOLABLE for leakage outside the drywell and specifically does not qualify leakage inside the drywell. Inclusion of the qualifier "UNISOLABLE" is not consistent with the NUMARC criteria.

The licensee provides for " attempts to isolate" before accident classification, but does not provide any time limit or number of attempt limits. The licensee does not define "immediate" or "readily."

The licensee should revise this EAL to be consistent with the NUMARC EALs or provide a rationale in the basis for the variations.

10.

Subcategory 3.b - Drvwell Pressure The NUMARC table 3, RCS Barrier Example EALs, I.oss example #2, Drywell Pressure states:

The (site-specific) drywellpressure is based on the drywell high pressure alarm serpoint and indicates a LOCA. A higher value may be used ifsupporting documentation is provided which indicates the chosen value is less than the pressure which uvuld be reachedfor a 50 GPM Reactor Coolant Leak.

The Lasalle EAL 3.b - Drywell Pressure threshold value for loss states:

Drywell Pressure h 1.69 PSIG (ECCS serpoint) due to reactor coolant leakage.

COMMENT: The NUMARC criteria suggests the selection of the drywell high pressure alarm setpoint or a higher value may be used if documentation is provided which indicates the chosen value is less than the pressure which would be reached for a 50 gpm reactor coolant system leak. The licensee selected the ECCS setpoint. It is not clear that the ECCS setpoint is the same as the high pressure alarm setpoint or is equivalent to 50 gpm system leak.

The licensee basis for the selected value is not sufficient to determine if the conservative NUMARC criteria is met.

12

n The licensee should provide additional information before acceptance of this EAL.

Recognition Category M - System Malfunctions 11.

Subcategory NUMARC SS4 - Complete Imss of Function Needed to Achieve or Maintain Hot Shutdown example EAL number 1. states:

Complete loss of any (site-specific) function requiredfor hot shutdown.

COMMENT: There is no licensee EAL that specifically addresses loss of hot shutdown function.

In the October 1,1993 Revision package (attachment C) under NUMARC EAL SS4, CECO makes the statement "Not applicable to BWRs. Hot Shutdown is defined for BWRs as having the mode switch in shutdown with all control rods inserted and temperature > 212 *F. If these conditions are not met, an ATWS has occurred and the ATWS EALs cover the situation." While the reviewer would agree that the " reactivity control" function of this EAL is adequately addressed for BWRs in the ATWS EALs (because of no need to borate or maintain boration once the rods are inserted), the Heat Sink function still needs to be addressed.

The licensee should address the loss of hot shutdown function as suggested by the NUMARC criteria.

12.

Subcategory MS4 - Loss of 125 VDC Power 215 minutes The NUMARC SS3 example EAL #1 states:

Loss of all DC Power based on (site-specific) bus voltage indicationsfor greater than 15 minutes.

The Lasalle EAL MS4 E4L threshold value #1 states:

CONFIRMED loss of cil 125 VDCpower to required de buses 111Y (211Y) and 112Y (212Y)for h 15 ininutes.

COMMENT: The licensee does not provide a specific meter /s or control panel indication /s for use with this EAL. No minimum safe bus voltage is specified to ensure adequate voltage is supplied to vital DC equipment.

The licensee should consider providing a specific meter /s or control panel indication /s that can be used to determine the power status of the DC buses.

13

r k

13.

Subcategory MU4 - UNPLANNED Loss of 125 VDC Power h 15 minutes.

The NUMARC SU7 example EAL #1 states:

a.

UNPLANNED Loss of all Vital DCpower to required DC busses based on (site-specipc) bus voltage indications. AhD

b. Failure to restore poner to at least one required DC bus within 15 minutes from the time ofloss.

The Lasalle EAL MU4 EAL threshold values state:

1. UNPLANNED loss of all 125 VDC buses lily (211Y) and 112Y (212Y) is CONFIRMED. AND

2. Failure to restore power to at least one 125 VDC bus in < 15 minutes from the time ofloss.

COMMENT: The licensee does not provide a specific meter /s or control panel indication /s for use with this EAL. No minimum safe bus voltage is specified, as required by the NUMARC criteria, to ensure adequate voltage is supplied to vital DC equipment.

The licensee should provide a specific meter /s or control panel indication /s that can be used to determine the power status of the DC buses.

14.

Subcategory MU7 - Fuel Clad Degradation l

The NUMARC SU4 example EAL 1. states:

(Site-Specific) radiation monitor readings indicatingfuel clad degradation greater than Technical Specification allowable limits.

The Lasalle EAL MU7 - Fuel Clad Degradation EAL threshold value 1. states:

Ofgas system isolation has occurred on a VALID Ofgas Post-treatment radiation monitor high trip.

COMMENT: The Post-Treatment monitor reading versus coolant activity are i

dependent on the adsorber bed line up and hold up time. The licensee should consider use of other indications such as pre-treatment monitors and main steam line monitors. The licensee selection of the trip setpoint might not be as conservative as suggested by the NUMARC criteria " radiation monitor readings."

14 F

b

The licensee should provide information that the selected threshold value meets the NUMARC conservative criteria.

15.

Subcategory MU8 - RCS leakage.

The NUMARC SU5 example EAL 1. states:

Thefollowing conditions exist: a. Unidentified orpressure bound.try leakage greater than 10 gym. OR b. Idennfied leakage greater than 25 gpm.

The Lasalle EAL MU8 - RCS leakage EAL threshold value states:

1. UNIDENTIFIED RCS leakage into the primary containment 210 gpm.

OR 2. Total (IDENTIFIED + UNIDENTIFIED) RCS leakage into the primary containment 2 35 gpm.

COMMENT: The licensee use of total leakage is not consistent with the NUMARC criteria.

The licensee should revise this EAL to be consistent with the NUMARC EALs or provide a rationale in the basis for the variations.

16.

Subcategory Mall - Major Fuel Damage OR Fuel Uncovery Outside the Reactor Vessel.

The NUMARC AA2 example EAL 1. states:

A (site-specific set point) alann on one or more of thefollowing radiation monitors:

Refael Floor Area Radiation Monitor Fuel Handling Building Ventilation Monitor Fuel Bridge Area Radiation Monitor The Lasalle EAL Mall - Major Fuel Damage OR Fuel Uncovery Outside the Reactor Vessel EAL threshold value number 1 states:

Valid reading of 2100 R/hr on refuelfloor radiation monitor OD21-K604A.

COMMENT: The licensee selected value 2 100 R/hr seems high for this threshold value.

The licensee should confirm that the selected value is the alarm setpoint or provide a rationale in the basis for use of the 2 100 R/hr value.

15

17.

Subcategory MA12 - UNCONTROLLED Loss of Refueling Cavity Volume.

The NUMARC initiating condition states:

Major damage to irradiatedfuel or loss of water level that has or will result in uncovering ofirradiatedfuel outside the reactor vessel.

The Lasalle MA12 - UNCONTROLLED Iess of Refueling Cavity Volume initiating condition states:

Damage to spentfuel OR loss of water level such that irradiatedfuel will become uncovered.

COMMENT: The licensee initiating condition indicates damage to spent fuel.

However, no specific criteria is presented to define what is meant by damage.

i Only uncovery is presented as EAL threshold values.

The licensee should consider including a definition of damage to spent fuel in this EAL.

Recognition Category H - Hazards and Other Conditions.

i 18.

Subcategory HS1 - Security Event in a Vital Area.

The NUMARC HS1 example EAL #2 states:

Other security events as determinefrom (site-specifc) Safeguards Contingency t

Plan.

The 12salle basis for HS1 states:

A security event is as defned in the security plan, section 1.

COMMENT: The licensee reference to a separate document, security plan, for the definition of a security event places an unnecessary burden on the Emergency Director. The licensee should include those defined security events that result in emergency classification in the EAL threshold value section.

P 16

19.

Subcategory HA4 - Natural OR destructive phenomena inside Vital Area.

The NUMARC HAl example EALs state:

2. Tornado or high winds striking plant vital areas: Tornado or high winds greater than (site-specipc) MPH strike within protected area boundary.

3. Repon of any visible structural damage on any of thefollouing plant structures:

Reactor Building Intake Building Ultimate Heat Sink Refueling Water Storage Tank Diesel Generator Building Thrbine Building Condensate Storage Tank Control Room Other (site-specifc) Structures.

The Lasalle HA4 - Natural OR destructive phenomena inside Vital Area EAL threshold value states:

2. Tornado strike within the Protected Area which afects equipment or structures within a vital area.

3. Sustained high winds & 90 mph on A-model report, computerpoint OR meter reading.

4. Report of visible structural damage to a structure (building, tanks, etc) efecting operations ofsystems required to establish or maintain Cold Shutdoun.

COMMENT: The licensee use of the terms "affects" and "affecting" places a qualifying condition on these events that is not present in the NUMARC EALs. The NUMARC criteria only provides for tornado, high winds or report of visible structural damage (structure specific). Affecting operation of equipment is not part of the NUMARC criteria. The NUMARC basis for structure damage states that the EAL should specify a site-specific list of structures containing systems and functions required for safe shutdown of the plant. The licensee does not provide a complete list of specific structures.

The licensee should revise this EAL to be consistent with the NUMARC EALs -

E or provide a rationale in the basis for the variations.

17

T

?'

UNITED STATES ae;k NUCLEAR REGULATORY COMMISSION rF E

L -;

R OFFICE OF NUCLEAR REACTOR REGULATION

(

DIVISION OF RADIATION SAFETY F

AND SAFEGUARDS

~

E EMERGENCY PREPAREDNESS BRANCH RE:

REQUEST FOR ADDITIONAL INFORMATION_ON PROPOSED EMERGENCY ACTION LEVEL CHANGES IN REVISION QCA-93-01 OF TIIE QUAD CITIES EMERGENCY PLAN TAC NOs:

M87333 and M87334 The NRC has completed its initial review of the proposed emergency action levels (EALs) in Revision QCA-93-01 to the Commonwealth Edison Generating Stations Emergency Plan (GSEP) Quad Cities Station Annex. 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, 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.

A.

GENERAL COMMENT

S The licensee did not irclude the NUMARC criteria relating tojudgement of the Emergency Director for fission product barrier loss or potential loss in any of the fission product barrier EALs. These EALs should be incorporated into the emergency classification scheme orjustification should be provided for their omission.

Debstions between the plants are not consistent For example: Dresden defines' Valid.

as " Reading are assumed valid unless circumstances cause the reading to be suspect."

Lasalle and Quad Cities define Valid as "A reading confirmed by redundant measurement, instrumentation, local reading or grab sample." The licensee should '

use the same definitions at all the nuclear plants.

J B.

EAL SPECIFIC COMMENTS Recognition Category R - Abnormal Rad Izvels/Radiolonical Effluent 1.

Subcategory RG1 - 1 Rem Total Effective Dose Equivalent (tede) OR 5 Rem Committed Dose Equivalent (cde) to the Thyroid NUMARC AGl - Abnormal Rad Levels / Radiological Effluent example EALs state:

1.

A valid reading on one or more of thefollowing monitors that aceeds 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-specificprocedure):

(site-specipc list)

Note: If the monitor reading (s) is sustainedfor longer than 15 minutes and the required assessmerJs cannot be completed within this period, then the declaration must be made based on the valid reading.

2.

A valid reading sustainedfor 15 minutes or longer on perimeter radiation monitoring system greater than 1000 Mr/hr. [for sites having telemetered perimeter monitors]

3.

Valid dose assessment capability indicates dose consequences greater than 1000 mR whole body or 5000 mR child thyroid.

4.

Field suney results indicate site boundary dose rates exceeding 1000 mR/hr expected to continuefor more than one hour; or analysis offield sunty samples indicate child thyroid commitment of 5000 mRfor one hour ofinhalation.

Quad Cities EAL Abnormal Rad Levels / Radiological Effluent RG1 threshold values state:

ONE of thefollowing den Drywell Radiation level h 80 R/hr, or Reactor Vessel Level S -1d? inches, or Radiation level h 1 R/hr on Refuel Floor indicating clad / core damage:

1.

The station total release as indicated by the SUM of VALID readings of both units on thefollowing monitors indicate the release has or is expected to exceed 1 Rem total efective dose equivalent (tede) OR S 2

I Rem committed dose equivalent (cde) to the thyroid and indicates the need to assess the release with dose projection models.

The Sum of Reactor Building SPING channel 5, 7, or 9, and Chimney SPING channel 5, 7, or 9:

2 2.1E+06 pCi/sec as detennined by QEP 155-S8 2.

Dose assessment results indicate dose consequences of1 Rem (tede), or Dose assessment results indicate dose consequences of5 Rem (cde) to the thyroid.

3.

RESTRICTED AREA BOUNDARY dose rates 21 R/hr expected to continuefor h 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or Analysis indicates 5 Rem (cde) to the thyroid at the RESTRICTED AREA BOUNDARY.

4.

Valid A-model Efluent Release Repon indicating a General Emergency COMMENT: The licensee inclusion of drywell radiation level, vessel level, and refuel floor radiation level is inconsistent with the guidance and potentially confusing. A valid (confirmed) stack monitor release in excess of the calculated threshold value is sufficient to classify the event. All reactor emergency events that cause a high release rate may not trigger one of the three entry level conditions. The similar EALs for CECO PWRs do not include this entry condition requirement. The licensee should eliminate these conditions in the EAL or provide justification on their benefit.

RG1 does not include the following note which is contained in the corresponding NUMARC/NESP-007 IC, NOTE:

if the monitor reading (s) is sustainedfor longer than 15 minutes and the required assessments cannot be completed within this period, than the declaration must be made based on the valid reading.

1 Provide justification for this deviation from the NUMARC/NESP-007 guidance.

The licensee basis for threshold value #4 states that the A-model reports at 1000 mrem /hr. No mention is made about the NUMARC criteria of 5000 mR child thyroid dose. Information should be provided on the capability of the A-model to assess thyroid dose.

3 i

2.

Subcategory RS1 - 100 mrem Total Effective Dose Equivalent (tede) OR 500 mrem Committed Dose Equivalent (cde) to the Thyroid NUMARC ASI - Abnormal Rad Levels / Radiological Effluent example EALs state:

1.

A valid reading on one or more of thefollowing 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-specifcprocedure):

(site-specifc list) t Note: If the monitor reading (s) is sustainedfor longer than 15 minutes and the required assessments cannot be completed within this period, then the declaration must be made based on the valid reading.

2.

A valid reading sustainedfor 15 minutes or longer on perimeter radiation monitoring system greater than 100 mR/hr. (for sites having telemetered perimeter monitors]

3.

Valid dose assessment capability indicates dose consequences greater than 100 mR whole body or 500 mR child thyroid.

4.

Field survey results indicate child indicate site boundary dose rates exceeding 100 mRihr expected to continuefor more than one hour; or analysis offield survey samp es indicate child thyroid commitment of 500 mRfor one hour ofinhalation.

Quad Cities EAL Abnormal Rad Levels / Radiological Effluent RSI threshold values state:

ONE of thefollowing when Drywell Radiation level 2 80 R/hr, or Reactor Vessel Level 1;; -142 inches, or Radiation level h 1 R/hr on Refuel Floor indicating clad / core damage:

1.

The station total release as indicated by the SUM of VALID readings of both units on thefollowing monitors indicate the release has or is expected to exceed 100 mrem total efective dose equivalent (tede) OR 500 mrem committed dose equivalent (cde) to the thyroid.

The Sum op Reactor Building SPING channel 5, 7, or 9, and 4

a Chimney SPING channel 5, 7, or 9:

h 2.1E+05 pCihec as determined by QEP 155-S8 1

2.

Dose assessment results indicate dose consequences of100 mrem (tede), or Dose assessment results indicate dose consequences of 500 3

mrem (cde) to the thyroid.

l 3.

RESTRICTED AREA BOUNDARY dose rates 2100 mRihr expected to i

continuefor 21 hour2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br />, or Analysis indicates 500 mrem (cde) to the thymid at the RESTRICTED AREA BOUNDARY.

4.

Valid A-model Efluent Release Repon indicating a SITE Emergency 1

COMMENT: The licensee inclusion of drywell radiation level, vessel level, I

and refuel floor radiation level is inconsistent with the guidance and potentially confusing. A valid (confirmed) stack monitor release in excess of the.

j calculated threshold value is sufficient to classify the event. Furthermore, all reactor emergency events that cause a high release rate may not trigger one of the three entry level conditions. The similar EALs for CECO PWRs do not l

include this entry condition requirement. The licensee should eliminate these-conditions in the EAL or provide justification on their benefit.

1 RS1 does not include the following note which is contained in the.

3 corresponding NUMARC/NESP-007 IC, l

NOTE:

If the monitor reading (s) is sustainedfor longer than 15 minutes and the required assessments cannot be completed within this d

period, than the declaration must be made based on the valid reading.

Provide justification for this deviation from the NUMARC/NESP-007 i

guidance.

l The licensee basis for threshold value #4 states that the A-model reports 'at'100

.i mrem /hr. No mention is made about the NUMARC criteria of 500 mR child -

thyroid dose. Information should be provided on the capability of the A-model to assess thyroid dose.

q

)

3.

Subcategory RA2 - Release 210 X ODCM limits for 215 Minutes.

NUMARC AAl - Abnormal Rad Levels / Radiological Effluent example EALs-state:

.j 5

i l

l r

h

1.

A valid reading on one or more of thefolloning 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-specipeprocedure):

(site-specifc list)

Note: If the monitor reading (s) is sustainedfor longer than 15 minutes and the required assessments cannot be completed within this period, then the declaration must be made based on the valid reading.

2.

Confirmed sample analysisfor gaseous or liquid releases indicates concentrations or release rates in excess of (200 X site-speci]ic technical specifications)for 15 minutes or longer.

3.

A valid reading on perimeter radiation monitoring system greater than 10 mR/hr sustainedfor 15 minutes or longer. [for sites having telemetered perimeter monitors]

4.

Valid indication on automatic real-time dose assessment capability greater than (200 X site-specific technical spect]ications)for 15 minutes or longer. (for sites having such capability]

Quad Cities EAL Abnormal Rad Levels / Radiological Effluent RA2 threshold values state:

ONE of thefollowing when Drywell Radiation level < 80 R/hr, or Reactor Vessel Level > -142 inches, or Radiation level < 1 R/hr on Refuel Floor indicating no clad / core damage:

1.

The station total release as indicated by the SUM of VALID readings of both units on thefollowing monitors indicates that the release may have exceeded h 10 X ODCM limits and indicates the need to assess the release:

P The Sum of Gaseous Releases:

Reactor Building SPING channel 5, 7, or 9, and Chimney SPING channel 5, 7, or 9:

a.

h 1.4E+05 pCi/sec as determined by QEP 155-S8 b.

Liquid Releases:

6 1

UNPIANNED Liquid Releases k 10 X the ODCM maximum instantaneous release limit.

2.

Grab sample indicate concentrations or release rates k 10 X the ODCM maximum instantaneous release limitfor h 15 minutes.

3.

RESTRICTED AREA BOUNDARY dose rates k 10 mR/hr expected to continuefor k 15 minutes.

4.

Valid A-model Epluent Release Report indicating an ALERT.

i COMMENT: The licensee inclusion of drywell radiation level, vessel level, and refuel floor radiation level is inconsistent with the guidance and potentially confusing. A valid (confirmed) stack monitor release in excess of the calculated threshold value is sufficient to classify the event. Furthermore, all reactor emergency events that cause a high release rate may not trigger one of the three entry level conditions. The similar EALs for CECO PWRs do not include this entry condition requirement. The licensee should eliminate these conditions in the EAL or provide justification on their benefit.

RA2 does not include the following note which is contained in the corresponding NUMARC/NESP-007 IC, NOTE:

If the monitor reading (s) is sustainedfor longer than 15 minutes and the required assessments cannot be completed within this period, than the declaration must be made based on the valid reading.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

IC RA2 deviates from NUMARC/NESP-007 in that the EAL for releases is set at 10 x ODCM limits whereas NUMARC/NESP-007 specifies 200 times the radiological technical specifications as the threshold for this EAL (ODCM values can be used for sites that have eliminated radiological technical specifications). The basis for the Dresden IC states that "The Alert value for gaseous effluents was reduced to 10 x ODCM to ensure sequential classifications." It is not clear from the information provided why this reduction is necessary.

Provide justification for this deviation from the NESP guidance.

i 7

f t

9 i

The licensee does not provide site specific monitor /s for a liquid release. If installed, the monitor /s should be specified and threshold values provided in the EAIJs.

4.

Subcategory RU2 - Release 2 2 X ODCM for 2 60 Minutes.

NUMARC AU1 - Abnormal Rad Ixvels/ Radiological Effluent example EALs j

state:

1.

A m!id reading on one or more of thefollouing monitors that exceeds the 'value shown" (site-specipe monitors) indicates that the release may have exceeded the above criterion and indicates the need to assess the release with (site-specifcprocedure):

(site-specifc list)

Note: If the monitor reading (s) is sustainedfor longer than 60 minutes and the required assessments cannot be completed uishin this c

period, then the declaration must be made based on the valid reading.

2.

Con)rmed sample analysisfor gaseous or liquid releases indicates concentrations or release rates uith a release duration of 60 minutes or longer in excess of(2 X site-specifc technical specipcations).

3.

A valid reading on perimeter radiation monitoring system greater than 0.10 mR/hr above normal backgroundfor 60 minutes. [for sites hasing telemetered perimeter monitors]

P 4.

Valid indication on automatic real-time dose assessment capability greater than (site-specifc value)for 60 minutes or longer. [for sites having such capability]

Quad Cities EAL Abnormal Rad 12vels/ Radiological Effluent RU2 threshold 4

values state:

?

ONE of thefollouing when Drywell Radiation level < 80 R/hr, or Reactor Vessel Level > -142 inches, or Radiation level < 1 R/hr on Refuel Floor indicating no clad / core damage:

1.

The station total release as indicated by the SUM of VALID readings of both units on thefollouing monitors indicates that the release may have exceeded h 2 X ODCM limits.

8 l

i

The Sum of Gaseous releases:

Reactor Building SPING channel 5, 7, or 9, and Chimney SPING channel 5, 7, or 9:

a.

k 2.8E+05 pCi/sec as determined by QEP 155-S8 b.

Liquid Releases:

UNPLANNED Liquid Releases k 2 X the ODCM maximum instantaneous release limitfor 60 minutes.

2.

Grab sample indicate concentrations or release rates 2 2 X the ODCM marimum instantaneous release limitfor h 60 minutes.

3.

Valid A-model Efluent Release Report indicating an UNUSUAL EVENT.

I COMMENT: The licensee inclusion of drywell radiation level, vessel level, and refuel floor radiation level is inconsistent with the guidance and potentially confusing. A valid (confirmed) stack monitor release in excess of the calculated threshold value is sufficient to classify the event. Furthermore, all reactor emergency events that cause a high release rate may not trigger one of the three entry level conditions. The sindlar EALs for CECO PWRs do not include this entry condition requirement. The licensee should eliminate these conditions in the EAL or provide justification on their benefit.

The licensee does not provide site specific monitor /s for a liquid release. If installed, the monitor /s should be specified and threshold values provided in the EAUs.

Recognition Category F - Fission Product Barrier Degradation 5.

Subcategory 1.a - Containment oressure The NUMARC table 3, Primary Containment Barrier Example EALs, I.oss example #1, Drywell Pressure states:

Rapid unexplained decrease following initial increase OR Drywellpressure response not consistent with LOCA conditions.

The Quad Cities EAL 1.a - Containment Pressure threshold value for loss states:

Rapidpressure decrease in containment after increase without containment spray.

9

~

t COMMENT: The licensee omitted the NUMARC criteria, Drywell pressure response not consistent with LOCA conditions, from this EAL. However, the licensee does explain in the basis for this EAL that " Containment pressure should increase as a result of mass and energy release into the containment from a LOCA."

The licensee should revise this EAL to be consistent with the NUMARC EALs or provide a rationale in the basis for the variations.

i 6.

Subcategory 1.c.2 - Containment Breached /Bynassed The Quad Cities EAL 1.c.2 - Containment Breached / Bypassed threshold value for loss states:

UNISOLABLE breach ofprimary containment.

COMMENT: The licensee basis for this EAL basis states:

"UNISOLABLE - A breach that is not readily isolable OR attempts for immediate isolation of the breach have been made and were unsuccessful.

Attempts for isolation should be made prior to the accident classification.

LOSS - an unisolable breach implies that a breach is NOT readily isolable OR l

attempts for immediate isolation of the breach have been made and were unsuccessful. Attempts for isolation should be made prior to the accident classification. If isolable upon identification no declaration need be made under this EAL although other EALs may be applicable. A breach of primary containment refers to a loss of primary containment integrity as described in the Technical Specifications definitions or primary containment Limiting l

Conditions for Operation (LCO)."

The terms "readily" and "immediate" are not defined. The term " attempts" implies more than one try at isolation, but does not define the number of attempts. The wording "Ifisolable upon identification..." implies some time to identify the breach location, but no time period is provided. There is no NUMARC EAL that directly correlates to this licensee EAL.

The licensee should provide clear definition for the terms used in this EAL.

The licensee should provide additional information for the inclusion of this EAL in the classification scheme.

1 7.

Subcategory 1.d - Containment Radiation Monitors.

NUMARC Primary Containment Barrier, Example number 3, Significant i

Radioactive Inventory in Containment.

I 10 j

' Die Quad Cities basis for this parameter states:

The value of 7000 R/hr uncorrected is conservative up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after shutdown. A four hour time is used to provide reasonable assurance that the Technical Suppon Center personnel would be available to provide an evaluation to determine ifcladfailure has exceeded 20%.

COMMENT: NUMARC does not discuss a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time for the corresponding EAL basis. The licensee use of a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> window is potentially confusing.

The licensee basis needs to be clear that the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time period does not delay the classification and that an assessment > 20% fuel clad will be treated as an equivalent threshold value.

8.

Subcategory 2.c - Fuel Clad.

NUMARC Fuel Clad Barrier EAL example #3, Drywell Radiation Monitoring.

The Quad Cities basis for this parameter states:

i 1750 Rfhr uncorrected is a value which is consenative up to 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />sfollowing a reactor shutdown. A four hour time is used to provide reasonable assurance that the Technical Support Centerpersonnel would be available to provide an evaluation to detennine if cladfailure has exceeded 5%.

COMMENT: NUMARC does not discuss a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time for the corresponding EAL basis. The licensee use of a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> window is potentially confusing.

i The licensee basis needs to be clear that the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time period does not delay the classification that an assessment > 5% fuel clad will be treated as an equivalent threshold value.

9.

Subcategory 3.a.1 - RCS Leaktate I

The NUMARC table 3, RCS Barrier Example EALs, Loss example #1, RCS Leak Rate states:

The ' Loss" EAL is based on design basis accident analysis which show that I

even ifMSIV closure occurs within design limits, dose consequences ofsite from the 'puf' release would be in excess of10 millirem. Thus, this EAL is includedfor consistency with the Alert emergency classification.

The Quad Cities EAL 3.a.1 - RCS Leakrate threshold value for loss states:

i LOSS: UNISOLABLE Main Steam Line Break.

I1 i

POTENTIAL LOSS: UNISOLABLE RCS Leakage 2 50 GPM.

r COMMENT: The licensee basis defines UNISOLABLE as: "A leak that is NOT readily isolable OR attempts for immediate isolation of the leak have been made and were unsuccessful. Attempts for Isolation should be made prior to accident classification." The licensee deals with unisolable primary system leakage outside the drywell in EAL #3.a.2. This EAL, #3.a.1, is directed to RCS leakage inside containment however, it does not specifically state inside containment. NUMARC, in table 3, uses the qualifier UNISOLABLE for leakage outside the drywell and specifically does not qualify leakage inside the drywell. Inclusion of the qualifier "UNISOLABLE" is not consistent with the NUMA.RC criteria.

The licensee provides for " attempts to isolate" before accident classification, but does not provide any time limit or number of attempt limits. The licensee does not define "immediate" or "readily."

The licensee should revise this EAL to be consistent with the NUMARC EALs or provide a rationale in the basis for the variations.

10.

Subcategory 3.b - Drywell Pressure The NUMARC table 3, RCS Banier Example EALs, loss example #2, Drywell Pressure states:

t The (site-specyic) drywellpressure is based on the dryell high pressure alarm serpoint and indicates a LOCA. A higher value may be used ifsupporting documentation is provided which indicates the chosen value is less than the pressure which would be reachedfor a 50 GPM Reactor Coolant Leak.

The Quad Cities EAL 3.b - Drywell Pressure threshold value for loss states:

Drywell Pressure h 2.5 PSIG (ECCS serpoint) due to reactor coolant leakage.

COMMENT: The NUMARC criteria suggests the selection of the drywell high pressure alarm setpoint or a higher value may be used if documentation is provided which indicates the chosen value is less than the pressure which would be reached for a 50 gpm reactor coolant system leak. The licensee selected the ECCS setpoint. It is not clear that the ECCS setpoint is the same as the high pressure alarm setpoint or is equivalent to 50 gpm system leak.

The licensee basis for the selected value is not sufficient to determine if the conservative NUMARC criteria is met.

12

k The licensee should provide additional information before acceptance of this EAL.

Recognition Category M - System Malfunctions 11.

Subcategory NUMARC SS4 - Complete loss of Function Needed to Achieve or Maintain Hot Shutdown example EAL number 1. states:

Complete loss of any (site-specifc) function requiredfor hot shutdown.

COMMENT: There is no licensee EAL that specifically addresses loss of hot shutdown function.

In the October 1,1993 Revision package (attachment C) under NUMARC EAL SS4, CECO makes the statement "Not applicable to BWRs. Hot Shutdown is defined for BWRs as having the mode switch in shutdown with all control rods inserted and temperature > 212 F. If these conditions are not met, an ATWS has occurred and the ATWS EALs cover the situation." While the reviewer would agree that the " reactivity control" function of this EAL is adequately addressed for BWRs in the ATWS EALs (because of no need to borate or maintain boration once the rods are inserted), the Heat Sink function t

still needs to be addressed.

The licensee should address the loss of hot shutdown function as suggested by the NUMARC criteria.

12.

Subcategory MS4 - Loss of 125 VDC Power 2 15 minutes.

The NUMARC SS3 example EAL #1 states:

Loss of all DC Pouer based on (site-specifc) bus voltage indicationsfor greater than 15 minutes.

The Quad Cities EAL MS4 EAL threshold value #1 states:

CONFIRMED loss of all VITAL 125 VDCpowerfor 215 minutes.

COMMENT: The licensee does not provide a specific meter /s or control panel indication /s for use with this EAL. No minimum safe bus voltage is specified to ensure adequate voltage is supplied to vital DC equipment.

The licensee should consider providing a specific meter /s or control panel indication /s that can be used to determine the power status of the DC buses.

l 13

13.

Subcategory MU4 - UNPLANNED Loss of 125 VDC Power d 15 minutes.

The NUMARC SU7 example EAL #1 states:

UNPLANNED Loss of all Vital DCpower to required DC busses based on a.

(site-specific) bus voltage indications. AND

b. Failure to restore power to at least one required DC bus within 15 minutes from the time ofloss.

The Quad Cities EAL MU4 EAL threshold values state:

1. UNPL4NNED loss of all 125 VDC buses is CONFIRMED. AND

2. Failure to restore poutr to at least one 125 VDC bus in < 15 minutes from the time ofloss.

COMMENT; The licensee does not provide a specific meter /s or control panel indication /s for use with this EAL. No minimum safe bus voltage is specified, as required by the NUMARC criteria, to ensure adequate voltage is supplied to vital DC equipment.

The licensee should provide a specific meter /s or control panel indication /s that can be used to determine the power status of the DC buses.

14.

Subcategory MU7 - Fuel Clad Degradation The NUMARC SU4 example EAL 1. states:

(Site-Specific) radiation monitor readings indicating fuel clad degradation greater than Technical Specification allowable limits.

The Quad Cities EAL MU7 - Fuel Clad Degradation EAL threshold value

1. states:

Ofgas system isolation has occurred on a V4 LID SJAE radiation monitor high trip.

COMMENT: It is assumed that the high trip is from the post-treatment monitor. The Post-Treatment monitor reading versus coolant activity are dependent on the adsorber bed line up and hold up time. The licensee should consider use of other indications such as pre-treatment monitors and main steam line monitors. The licensee selection of the trip setpoint might not be as 14

conservative as suggested by the NUMARC criteria " radiation monitor readings."

The licensee should provide information that the selected threshold value meets the NUMARC conservative criteria.

15.

Subcategory MU8 - RCS leakage.

t The NUMARC SUS example EAL 1. states:

Thefollowing conditions exist: a. Unidennfed orpressure boundary leakage greater than 10 gpm. OR b. Identiped leakage greater than 25 gpm.

The Quad Cities EAL MUS - RCS leakage EAL threshold value states:

1. UNIDENTIFIED RCS leakage into the primary containment 2 10 gpm.

OR 2. Total (IDENTIFIED + UNIDENTIFIED) RCS leakage into the primary containment h 35 gpm.

COMMENT: The licensee use of total leakage is not consistent with the NUMARC criteria.

The licensee should revise this EAL to be consistent with the NUMARC EALs or provide a rationale in the basis for the variations.

16.

Subcategory Mall - Maior Fuel Damage OR Fuel Uncovery Outside the Reactor Vessel.

l The NUMARC AA2 example EAL 1. states:

A (site-spectfc set point) alann on one or more of thefollowing radiation monitors:

Refuel Floor Area Radiation Monitor Fuel Handling Building Ventilation Monitor Fuel Bridge Area Radiation Monitor The Quad Cities EAL Mall - Major Fuel Damage OR Fuel Uncovery Outside the Reactor Vessel EAL threshold value number 1 states:

s Valid reading of k 100 Rlhr on refuelfloor radiation monitor 1(2)1743-A or B.

15

?

f

I COMMENT; The licensee selected value h 100 R/hr seems high for this threshold value.

The licensee should confirm that the selected value is the alarm setpoint or provide a rationale in the basis for use of the 2 100 R/hr value.

17.

Subcategory mal 2 - UNCONTROLLED loss of Refueline Cavity Volume.

l The NUMARC initiating condition states:

Major damage to irradiatedfuel or loss of water level that has or uill result in uncovering ofirradiatedfuel outside the reactor vessel.

The Quad Cities mal 2 - UNCONTROLLED Loss of Refueling Cavity f

Volume initiating condition states:

Damage to spentfuel OR loss of water level such that irradiatedfuel uill i

become uncovered.

l 5

COMMENT: The licensee initiating condition indicates damage to spent fuel.

However, no specific criteria is presented to define what is meant by damage.

Only uncovery is presented as EAL threshold values.

The licensee should consider including a definition of damage to spent fuel in this EAL.

Recognition Catecorv H - Hazards and Other Conditions.

18.

Subcategory HS1 - Security Event in a Vital Area.

The NUMARC HS1 example EAL #2 states:

l Other security events as determinefrom (site-specift) Safeguards Contingency Plan.

The Quad Cities basis for HS1 states:

i A security event is as defned in the security plan, section 1.

COMMENT: The licensee reference to a separate document, security plan, for the definition of a security event places an unnecessary burden on the Emergency Director. The licensee should include those defined security events that result in emergency classification in the EAL threshold value section.

16 4

19.

Subcategory HA4 - Natural OR destructive phenomena inside Vital Area.

The NUMARC HAl example EALs state:

2. Tornado or high winds striking plant vital areas: Tornado or high winds greater than (site-specific) MPH strike within protected area boundary.

3. Report of any visible structural damage on any of thefollouing plant structures:

Reactor Building intake Building Ultimate Heat Sink Refueling Water Storage Tank Diesel Generator Building Thrbine Building Condensate Storage Tank Control Room Other (site-specific) Structures.

i The Quad Cities HA4 - Natural OR destructive phenomena inside Vital Area EAL threshold value states:

2. Tornado strike within the Protected Area which afects equipment or structures uithin a vital area.

3. Sustained high uinds k 90 mph on A-model report, computerpoint OR meter reading.

4. Repon of visible structural damage to a structure (building, tanks, etc) afecting operations ofsystems required to establish or maintain Cold Shutdown.

COMMENT

• The licensee use of the terms "affects" and "affecting" places a qualifying condition on these events that is not present in the NUMARC EALs. The NUMARC criteria only provides for tornado, high winds or report of visible structural damage (structure specific). Affecting operation of l

equipment is not part of the NUMARC criteria. The NUMARC basis for structure damage states that the EAL should specify a site-specific list of structures containing systems and functions required for safe shutdown of the plant. The licensee does not provide a complete list of specific structures.

The licensee should revise this EAL to be consistent with the NUMARC EALs or provide a rationale in the basis for the variations.

17

)

UNITED STATES I

an.\\

NUCLEAR REGULATORY COMMISSION 1

T OFFICE OF NUCLEAR REACTOR REGULATION l

g DIVISION OF RADIATION SAFETY AND SAFEGUARDS EMERGENCY PREPAREDNESS BRANCH P

t RE:

REQUEST FOR ADDITIONAL INFORMATION ON PROPOSED EMERGENCY ACTION LEVEL CHANGES IN REVISION ZIN-93-01

.l OF THE ZION EMERGENCY PLAN l

TAC NOs:

M87335 and M87336 The NRC has completed its initial review of the proposed emergency action levels (EALs) in Revision ZIN-93-01 to the Zion Station Site Specific Generating Station Emergency Plan Annex. 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.

l 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 j

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.

RG1 - 1 Rem Total Effective Dose Eauivalent (tede) OR 5 Rem Commited Dose Ecuivalent (cde) to the Thyroid Initiating Condition (IC) RG1 does not include the following note which is contained in the

{

corresponding NUMARC/NESP-007 IC, l

NOTE:

If the monitor reading (s) is sustainedfor longer than 15 minutes and the required assessments cannot be completed within this period, then j

the declaration must be made based on the valid reading.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

l i

i i

?

!l l

i 2.

RS1 - 100 mrem Total Effective Dose Eauivalent (tede) OR 500 mrem Comming!

i Dose Ea_uivalent (ede) to the Th_yroid' d

i IC RS1 does not include the following note which is contained in the corresponding

~

NUMARC/NESP-007 IC,

+;

NOTE:

If the' monitor reading (s) is sustainedfor longer than 15 minutes and I

the required assessments cannot be completed within thisperiod, then-the declaration must be made based on the valid reading.

l l,

Provide justification for this deviation from the NUMARC/NESP-007 guidanc' e.

~

t

}

3.

RA2 - Release > 10 X ODCM limits for > 15 minutes a.

IC RA2 does not include the following note which is contained in the q

corresponding NUMARC/NESP-007 IC, j

NOTE:

If the monitor reading (s) is sustainedfor 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.

i i

Provide justification for this deviation from the NUMARC/NESP-007 l

guidance.

}

b.

IC RA2 deviates from NUMARC/NESP-007 in that site specific liquid effluent i

monitors and readings are not specified in the EAL under this IC. The Zion EAL specifies Liquid Releases: UNPLANNED Liquid Release 210 X the ODCM maximum instantaneous release limitfor k 15 minutes. ' The i

corresponding NUMARC/NESP-007 EAL is A valid reading on one or more of thefollowing monitors that exceeds the "value shown* (site spea]ic l

monitors) indicates that the release may have exceed the above criterion and

)

indicates the need to assess the release with (site-speaficprocedure):

l Providejustification for this deviation from the NUMARC/NESP-007 guidance.

l Zion Page 2

.)

i j

i l

J t

4 c.

IC RA2 deviates from NUMARC/NESP-007 in that the EAL for liquid release is set at 10 x ODCM limits whereas NUMARC/NESP-007 specifies 200 times the radiological technical specifications as the threshold for this EAL (ODCM values can be used for sites that have eliminated radiological technical specifications). The basis for the Zion IC states that "The Alert value for gaseous effluents was reduced to 10 x ODCM to ensure sequential classifications." It is not clear from the information provided why this reduction is necessary.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

4.

RU2 - Release > 2X ODCM for > 60 minutes IC RU2 deviates from NUMARC/NESP-007 in that site specific liquid effluent monitors and readings are not specified in the EAL under this IC. The Zion EAL specifies Liquid Releases: UNPLANNED Liquid Release X 2 X the ODCM maximum instantaneous release limitfor 160 minutes. The corresponding NUMARC/NESP-007 EAL is A valid reading on one or more of thefollowing monitors that exceeds the "value shown" (site specipe monitors) indicates that the release may have exceed the above criterion and indicates the need to assess the release with (site-specifc procedure):

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

5.

Mall - Maior Fuel Damage OR Fuel Uncoverv Outside the Reactor Vessd MA12 - Uncontrolled Loss of Refueling Cavity Volume ICs Mall and mal 2 deviate from the cenesponding NUMARC/NESP-007 IC (AA2)in that EALs contained in NUMARC/NESP-007 are not included. In particular the following NUMARC/NESP-007 example EALs for IC AA2 are not included:

3.

Water Level less than (Site-specific)feetfor the Reactor Refueling Cavity that will result in irradiated Fuel Uncovering.

4 Water Level less than (site-spenfic)feetfor the Spent Fuel Pool and Fuel Transfer Canal that will result in irradiated Fuel Uncovering.

t Provide justification for this deviation from the NUMARC/NESP-007 guidance.

Zion Page 3

-l 6.

1.b - Containment Critical Safety Function EAL 1.b, entitled " Containment Critical Safety Function" deviates from the corresponding NUMARCINESP-007 EAL, Containment pressure greater than containment depressurization system serpoint with less than onefull train ofdepressurization equipment operating in thet the Zion EAL includes the condition of No Containment Spray Available. It is not clear why the term "available" was substituted for the phrase "less than one full train of depressurization equipment operating" for this EAL.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

7.

CONTAINMENT 1.a - Containment Radiation The basis for this EAL contains the following statement; POTENTIAL LOSS

......This value corresponds to 20% clad damage and represents a direct (uncorrected) value which is conservativefor up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after reactor shutdown. A 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time is used to provide reasonable assurance that the Technical Support Center (TSC) uvuld be available to provide evaluation to detennine if clad damage has exceeded 20%.

This statement can be read as directing the licensee staff to delay classifying events on r

Containment Radiation indications until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the initiation of the event.

Revise this statement to clarify its intent or provide additional information justifying retaining the basis in its present form.

8.

FUEL CLAD 2.c - Containment Radiation The basis for this EAL contains the following statement; LOSS

......The value of represents a direct (uncorrected) value which is conservativefor up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after reactor shutdown. A 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time is used to provide reasonable assurance that the Technical Support Center (TSC) personnel uvuld be available to provide evaluation to determine ifcladfailure has exceeded 5%.....

This statement can be read as directing the licensee staff to delay classifying events on Containment Radiation indications until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the initiation of the event.

Revise this statement to clarify its intent or provide additional information justifying retaining the basis in its present form.

Zion Page 4

9.

Zion Station Fission Product Barrier Matrix The Zion fission product barrier matrix did not contain an EAL which corresponds to NUMARC fission product barrier EALs contained under the heading of Emergency Director Judgement.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

10.

MUl. Loss of All Offsite Power for d 15 minutes This IC contains the following EAL, ESF busses are energized. It is not clear whether including the general term "ESF busses" in this EAL is adequate to ensure accurate classification.

Provide information regarding the adequacy of the general term "ESF busses" in this EAL.

11.

MA2. Loss of All Offsite and Onsite AC Power > 15 minutes This IC contains the following EAL, Failure of...ESF buses. It is not clear whether including the general term "ESF busses" in this EAL is adequate to ensure accurate classification.

Provide information regarding the adequacy of the general term "ESF busses" in this EAL.

12.

MA3. Auto Trip NOT Successful a.

This IC deviates from NUMARC/NESP-007 in that the condition that a plant shutdown has commenced is included in the Zion EAL under this IC.

i NUMARC/NESP-007 Example EAL #1 for Initiating Condition SA2 states the following:

1.

(Site-Specific) indication (s) exist that indicate that reactor protection system serpoint was exceeded and automatic scram did not occur, and a successful manual scram occurred.

The corresponding Zion EAL for Initiating Condition MA3 on page 5.1-40 state the following:

1.

A Reactor Protection System actuation signal was recched AND automatic Reactor trip did not occur. A successful MANUAL TRIP occurred OR a plant shutdown has commenced.

R Zion Page 5 f

Revise this IC to delete the condition that a unit shutdown has commenced or provide addition justification for this deviation from the NUMARC/NESP-007 guidance'.

13.

MS4. Loss of Vital 125 Volt DC Power > 15 minutes The EAL for this IC deviates from the corresponding NUMARC/NESP-007 EAL in that a i

site-specific bus voltage indication was not included in the Zion EAL.

NUMARC/NESP-007 Example EAL #1 for Initiating Condition SS3 states the following:

1.

Loss ofAll Vital DC Power based on (site-specific) bus voltage indicationsfor greater than 15 minutes.

The corresponding Zion EAL for Initiating Condition MS4 states the following:

Loss of all 125V DCpower to a unit's ESF bussesfor.;>_15 minutes.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

14.

MU4. Unplanned Loss of 125V DC Power for > 15 minutes The EAL for this IC deviates from the corresponding NUMARC/NESP-007 EAL in that a site-specific bus voltage indication was not included in the Zion EAL.

NUMARC/NESP Example EAL #1 for Initiating Condition SU7 states the following:

i 1.

Either of thefollowing conditions exist:

Unplanned Loss of Vital DCpower to required DC busses based a.

on (site-specific) bus voltage indications.

AND b.

Failure to restore power to at least one required DC bus with 15 minutesfrom the time ofloss.

The corresponding Zion EALs for Initiating Condition MU4 on page 5-1.42 state the following:

Zion Page 6

I 1.

Loss of all 125V DCpower to a Unit.

AAD 2.

Failure to restore poner to at least one ESF DC bus within 15 minutes from the time ofloss.

P1 ovide justification for this deviation from the NUMARC/NESP-007 guidance.

15.

MS5. Imss of Hot Shutdown Capability This IC deviates from the corresponding NUMARC/NESP-007 IC in that the condition of Inadequate Shutdown Margin is "anded" with the other condition specified in this EAL, i.e.

Loss of all efective means requiredfor Hot Shutdown provided in AOP-6.3.

NUMARC/NESP-007 Example EAL #1 for Initiating Condition SS4 states the following:

1.

Complete loss of any (site-specific) function requiredfor hot shutdown.

The corresponding Zion EAL for Initiating Condition MS5 on page 5.1-43 states the following.

l.a.

Total Available Feedwaterflow s; 340 gym.

OR b.

Ixss of all efective means requiredfor Hot Shutdown provided in AOP-6.3 AND 2.

Inadequate Shutdown Margin Provide justification for this deviation from the NUMARC/NESP4K)7 guidance. In addition provide procedure AOP-6.3.

16.

MU7. Fuel Clad Degradation This IC deviates from the NUMARC/NESP-007 guidance in that site specific radiation monitor readings are not provided in the EALs for this IC.

NUMARC/NESP-007 Example EALs #1 and #2 for Initiating Condition SU4 state the following:

Zion Page 7

9 1.

(Site-Specifc) radiation monitor readings indicatingfuel clad degradation greater than Technical Specyicchn allowable limits.

2.

(Site-Specifc) coolant sample activity value indicatingfuel clad b

degradation greater than Technical Specifcation allowable limits.

The corresponding Zion EAL for Initiating Condition MU7 on page 5-1.52 states the following:

i VALID 1RE PR18/PR27 QB 2RE PR18/PR27 radiation monitor read lngs indicatingfuel clad degradation > Technical Specifcation allowed limits.

OR Coolant acchity value requiring implementation of an action statement in Technical Specifcation 3.3.6.

Revise this EAL to conform with the NUMARC/NESP-007 guidance or provide justification for this deviation from the NUMARC/NESP-007 guidance.

17.

HAl. Security Event in the Protected Area This IC deviates from the NUMARC/NESP-007 guidance in that the following EAL is

~

included, A bomb device is discovered inside the rital area. This EAL is indicative of a security event in a vital area and should therefore be included under Zion IC HS1 " Security Event in a Vital Area" which corresponds to NUMARC/NESP-007 IC HS1 " Security Event i

in a Vital Area."

Revise this IC and IC HS1 to be consistent with NUMARC/NESP-007 guidance or provide justification for this deviation from the NUMARC/NESP-007 guidance.

18.

HAl. Security Event in a Plant Protected Area This IC does not contain a list of (site-specific) security events.

NUMARC/NESP-007 Example EAL #2 for Initiating Condition HA4 states the following:

2.

Other security events as determinedfrom (site-specapc) Safeguards Contingency Plan.

Zion Page 8

The corresponding Zion Threshold Value #3 for Initiating Condition HAl on page 5.1-62 states the following:

3.

A security event ofincreasing severity that persistsfor 2: 30 minutes.

Revise the EAL to define and/or list specific security events that warrant classification or provide justification for maintaining this IC in its present form.

19.

HSI. Security Event in a Plant Vital Area The EAL for this IC does not contain a list of (site-specific) security events.

NUMARC/NESP-007 Example EAL #2 for Initiating Condition HS1 states as follows:

2.

Other security events as determinedfrom (site-specific) Safeguards Contingency Plan.

The corresponding Zion EAL for Initiating Condition HS1 on page 5.1-61 states the following:

2.

A security event which results in the loss ofcontrol of any vital area (other than the Control Room).

Revise the EAL to define and/or list specific security events that warrant classification or provide justification for maintaining this IC in its present form.

20.

HS3. Control Room Evacuated AND CONTROL NOT established in s 30 minutes The Zion EAL Threshold Value #2 on page 5.1-70 for Initiating Condition HS3, Evacuation of the Control Room AND CONTROL NOT established at remote locations in the plant in s 30 minutes, states the following:

2.

CON 7ROL of the plant cannot be established per AOP-7.4 in.130 minutes.

The licensees' basis information on page 5-1.70 for HS3 states:

Control - Control is defined as having placed all local control switches in local control necessaryfor operationfrom remote panels.

Zion Page 9

The criteria defining control is incomplete. Placing local control switches in local does not ensure control. This may be especially true considering the varied scenarios that may require control room evacuation (e.g., fire, electrical, security, sabotage, etc.). Placing local control switches in local should transfer control if all systems, controls, and interconnecting l

wiring are functional. The definition of " Control" should include a condition that functional control has been established per fie identified procedure, AOP-7.4, not just switch positions changed.

The basis for IC HS2 in NUMARC/NESP-007 states that a determination of whether or not control is established should be made within 15 minutes.

Revise the EAL include a condition that functional control is established or provide justification for maintaining this EAL in its present form. Also, provide justification for utilizing a 30 minute time requirement.

21.

HA4. Natural or Destructive Phenomena Inside a Vital Area.

This IC deviates from the NUMARC/NESP-007 guidance in that site specific areas, structures and buildings have not been identified.

NUMARC/NESP-007 Example EAL # 3 and #6 for Initiating Condition HAl state the following:

3.

Report of any visible structural damage on any of thefollowing plant structures:

- Reactor Building

- Intake Building

- Ultimate Heat Sink

- Refueling Water Storage Tank

- Diesel Generator Building

- Dirbine Building

- Condensate Storage Tank

- Control Room

- Other (Site-Specyic) Structures 6.

Darbinefailure generated missiles result in any visible structural damage to orpenetration of any of thefollowing plant areas: (Site-Specific) list.

The corresponding Zion EAL for Initiating Condition HA4 on page 5-1.72 state the following:

Zion Page 10

F I

4.

Report of visible structural damage to a structure (Building, tanks, etc.)

afecting operations ofsystems required to establish or maintain Cold Shutdown.

t 6.

Main 1hrbine rotating componentfailure which penetrates the casing and generates missiles causing damage to structures containing safety related equipment.

Revise the EAL to include specific areas, structure, and buildings or provide justification for this deviation from the NUMARC/NESP-007 guidance.

22.

HA2. Fire or Exolosion Affecting the Operability of Plant Safety Systems Reauired to Establish or Maintain Safe Shutdown.

This IC deviates from the NUMARC/NESP-007 guidance in that site specific areas, structures and buildings have not been identified.

NUMARC/NESP-007 Example EAL # 1.a for Initiating Condition HA2 states the following:

1.

Thefollowing Conditions exist:

1 Fire or explosion in any of thefollowing (Site-Specipc) areas:

a.

- (Site specifc) list Corresponding Zion EAL #1 for Initiating Condition HA5 on page 5-1.76 states the following.

1.

Fire OR EXPLOSION afecting operability ofsafety systems required to establish or maintain Cold Shutdown i

Revise the EAL to include specific areas, structure, and buildings or provide justification for this deviation from the NUMARC/NESP-007 guidance.

23.

HA3. Release of Toxic or Flammable Gases Within a Facility Structure Which Jeopardizes Operation of Systems Required to Maintain Safe Operations or to Establish or Maintain Cold Shutdown.

This IC deviates from the NUMARC/NESP-007 guidance in that the following condition was added to the EAL associated with this IC, toxic gases..... in hfe threatening concentrations that will afect the safe operation of the plant.

Zion Page 11

NUMARC/NESP-007 Initiating Condition HA3, example EAL #1 states:

1.

Repon or detection of toxic gases within a Facility Structure in concentrations that will be life threatening to plant personnel.

The licensees' corresponding Initiating Condition HA6, EAL Threshold Value 1 on page 5.1-80 states:

1.

Report or detection of toxic gases within a Facility Structure in life threatening concentrations that will a.fect the safe operation of the plant.

Under the NUMARC EAL, the emergency would be declared if the level of toxic gases were

" life threatening to plant personnel." Under the licensees' EAL the emergency would be declared for " life threatening concentrations that will affect the safe operation of the plant."

Life threatening levels to plant personnel would likely affect safe operations since the EAL in meant to exclude (see basis discussion) buildings or areas not contiguous or adjacent to plant vital areas. The presence of toxic or flammable gas in or near vital areas (the potential to affect) should warrant an Alert declaration. It may be difficult to determine how the life threatening levels to personnel would affect operation.

Revised this EAL to be consistent with NUMARC guidance or provide justification for this deviation from the NUMARC/NESP-007 guidance.

In addition, the following definition of " TOXIC" from Licensee Change Submittal, DRE 03, for the Dresden Facilities, i.e. TOX1C - Erposure to the worker in e.rcess of the limits specified in 29 CFR 1910.1000. In practice, this should be consideredfor concentrations which are capable ofproducing incapacitation of the worker, should be included in the basis for this EAL or justification should be provided for not including this dermition.

Zion Page 12

\\

UNITED STATES

,3n neog#

NUCLEAR REGULATORY COMMISSION j

OFFICE OF NUCLEAR REACTOR REGULATION

?

II!

DIVISION OF RADIATION SAFETY

% * *O AND SAFEGUARDS i

EMERGENCY PREPAREDNESS BRANCH RE:

REQUEST FOR ADDITIONAL INFORMATION ON PROPOSED EMERGENCY ACTION LEVEL CIIANGES IN REVISION BRW-93-01 OF THE BRAIDWOOD EMERGENCY PLAN TAC NOs:

M87325 and M87326 The NRC has completed its initial review of the proposed emergency action' levels (EALs) in Revision BRW-93-01 to the Braidwood Station Site Specific Generating Station Emergency Plan Annex. 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.

l 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 i

the EALs conform with NUMARC/NESP-007. Please provide this additional information as discussed below.

1.

RG1 - 1 Rem Total Effective Dose Equivalent (tede) OR 5 Rem Commited Dose Equivalent (cde) to the Thyroid Initiating Condition (IC) RG1 does not include the following note which is contained in the corresponding NUMARC/NESP 007 IC, NOTE:

If the monitor reading (s) is sustainedfor 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.

Provide justification for this deviation from the NESP guidance.

2.

RS) - 100 mrem Total Effective Dose Equivalent (tede) OR 500 mrem Committed Dose Equivalent (cdel to the Thyroid IC RS1 does not include the following note which is contained in the corresponding NUMARC/NESP 007 IC, NOTE:

If the monitor reading (s) is sustainedfor 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.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

3.

RA2 - Release > 10 X ODCM limits for > 15 minutes a.

IC RA2 does not include the following note which is contained in the corresponding NUMARC/NESP-007 IC, NOTE:

If the monitor reading (s) is sustainedfor 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.

Provide justification for this deviation from the NUMARC/NESP-007

guidance, b.

IC RA2 deviates from NUMARC/NESP-007 in that site specific liquid effluent monitors and readings are not specified in the EAL under this IC. The Braidwood EAL specifies Liquid Releases: UNPIANNED Liquid Release h 10 X the ODCM marimum instantaneous release limitfor k 15 minutes. The corresponding NUMARC/NESP-007 EAL is A valid reading on one or more of thefollowing monitors that exceeds the 'value shown" (site speapc monitors) indicates that the release may have e.tceed the above criterion and indicates the need to assess the release with (site-speapcprocedure):

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

Braidwood Page 2 l

9 c.

IC RA2 deviates from NUMARC/NESP-007 in that the EAL for liquid release is set at 10 x ODCM limits whereas NUMARC/NESP-007 specifies 200 times -

the radiole;ical technical specifications as the threshold for this EAL (ODCM values ce t. used for sites that have eliminated radiological technical specificativ w The basis for the Braidwood IC states that "The Alert value for gaseou; n.aents was reduced to 10 x ODCM to ensure sequential classifications." It is not clear from the information provided why this reduction is necessary.

Provide justification for this deviation from the NESP guidance.

4.

RU2 - Release > 2X ODCM for > 60 minutes IC RU2 deviates from NUMARC/NESP-007 in that site specific liquid effluent monitors and readings are not specified in the EAL under this IC. The Braidwood EAL speciEes Liquid Releases: UNPLANNED Liquid Release X 2 X the ODCM maximum instantaneous release limitfor 160 minutes. The corresponding NUMARC/NESP-007 EAL is A _ valid reading on one or more of thefollowing monitors that exceeds the "value shown" (site spec @c monitors) indicates that the release may have exceed the above criterion and indicates the need to assess the release with (site-specific procedure):

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

5.

MAI1 - Maior Fuel Damaec OR Fuel Uncovery Outside the Reactor Vessel mal 2 - Uncontrolled Loss of Refueline Cavity Volume ICs Mall and MA12 deviate from the corresponding NUMARC/NESP-007 IC (AA2) in that EALs contained in NUMARC/NESP-007 are not included. In particular the following NUMARC/NESP-007 example EALs for IC AA2 are not included:

3.

Water Levelless than (Site-specific)feetfor the Reactor Refueling Cavity that will result in irradiated Fuel Uncovering.

4.

Water Level less than (site-spec @c)feetfor the Spent Fuel Pool and Fuel Transfer Canal that will result in irradiated Fuel Uncovering.

Provide justification for this deviation from the NESP guidance.

Braidwood Page 3

6.

1.b - Containment Critical Safety Function EAL 1.b, entitled " Containment Critical Safety Function" deviates from the corresponding NUMARCINESP-007 EAL, Containment pressure greater than containment depressurization system setpoint uith less than onefull train ofdepressurization equipment operating in that the Braidwood EAL includes the condition of No Containment Spray Available. It is not clear why the term "available" was substituted for the phrase "less than full train of depressurization equipment operating" for this EAL.

Provide justification for this deviation from the NESP guidance.

7.

CONTAINMENT 1.a - Containment Radiation The basis for this EAL contains the following statement; POTENTIAL LOSS

......This value corresponds to 20% clad damage and represents a direct (uncorrected) value which is conservathe for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after reactor shutdown. A 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time is used to provide reasonable assurance that the Technical Support Center (TSC) would be available to provide evaluation to detennine ifclad damage has exceeded 20%.

This statement can be read as directing the licensee staff to delay classifying events on Containment Radiation indications until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the initiation of the event.

Revise this statement to clarify its intent or provide additional information justifying retaining the basis in its present form.

8.

FUEL CLAD 2.c - Containment Radiation The basis for this EAL contains the following statement; LOSS

......The value of represents a direct (uncorrected) value which is conservativefor up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after reactor shutdown. A 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time is used to provide reasonable assurance that the Technical Support Center (TSC) personnel would be available to provide evaluation to determine if cladfailure has e.tceeded 5%.....

This statement can be read as directing the licensee staff to delay classifying events on Containment Radiation indications until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the initiation of the event.

Revise this statement to clarify its intent or provide additional information justifying retaining the basis in its present form.

Braidwood Page 4

9.

Braidwood Station Fission Product Barrier Matrix The Braidwood fission product barrier matrix did not contain an EAL which corresponds to NUMARC fission product barrier EALs contained under the heading of Emergency Director Judgement.

Provide justification for this deviation from the NESP guidance.

10.

MUI. Loss of All Offsite Power for h 15 minutes This IC contains the following EAL, ESF busses are energized. It is not clear whether including the general term "ESF busses" in this EAL is adequate to ensure accurate classification.

Provide information regarding the adequacy of the general term "ESF busses" in this EAL.

11.

MA2. Ioss of All Offsite and Onsite AC Power h 15 minutes This IC contains the following EAL, Failure of...ESF busses. It is not clear whether including the general term "ESF busses" in this EAL is adequate to ensure accurate classification.

Provide information regarding the adequacy of the general term "ESF busses" in this EAL.

12.

MA3. Auto Trip NOT Successful a.

This IC deviates from NUMARC/NESP-007 in that the condition that a unit shutdmen has commenced is included in the Braidwood EAL under this IC.

NUMARC/NESP 007 Example EAL #1 for Initiating Condition SA2 states the following:

1.

(Site-Specific) indication (s) aist that indicate that reactor protection system serpoint was acceded and automatic scram did not occur, and a successful manual scram occurred.

The corresponding Braidwood EALs for Initiating Condition MA3 on page 5.1-40 state the following:

Braidwood Page 5

1.

A Reactor Protection System actuation signal was recebed AND automatic Reactor trip did not occur.

AND 2.

A successful MANUAL TRIP occurred OR a unit shutdown has commenced.

Revise this IC to delete the condition that a unit shutdown has commenced or provide addition justification for this deviation from the NUMARC/NESP-007 guidance.

13.

MS4. Loss of Vital 125 Volt DC Power > 15 minutes The EAL for this IC deviates from the corresponding NUMARC/NESP-007 EAL in that a site-specific bus voltage indication was not included in the Braidwood EAL.

NUMARC/NESP-007 Example EAL #1 for Initiating Condition SS3 states the following:

1.

Loss ofAll Vital DC Power based on (site-specific) bus voltage indicationsfor greater than 15 minutes.

The corresponding Braidwood EAL for Initiating Condition MS4 states the following:

Loss of all 125V DCpower to a unit's ESF bussesfor.;>_15 minutes.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

14.

MU4. Unplanned Imss of 125V DC Power for > 15 minutes The EAL for this IC deviates from the corresponding NUMARC/NESP-007 EAL in that a site-specific bus voltage indication was not included in the Braidwood EAL.

NUMARC/NESP Example EAL #1 for Initiating Condition SU7 states the following:

1.

Either of thefollowing conditions exist:

a.

Unplanned Loss of Vital DCpower to required DC busses based on (site-specific) bus voltage indications.

Braidwood Page 6 i

AND 1

' b.

Failure to restore power to at least one required DC bus with 15 minutesfrom the time ofloss.

The corresponding Braidwood EALs for Initiating Condition MU4 on page 5-1.42 state the following:

1.

Inss of all 125V DCpower to a Unit.

AND f

2.

Failure to restore power to at least one ESF DC bus within 15 minutes from the time ofloss.

Provide justification for this deviation from the NESP guidance.

15.

MSS. Imss of Hot Shutdown Canability This IC deviates from the corresponding NUMARC/NESP-007 IC in that the' condition of Inadequate Shutdown Margin is "anded" with the other condition specified in this EAL, i.e.

Loss of all efective means requiredfor Hot Shutdown provided in BwOA PR1-10, Table A.

NUMARC/NESP-007 Example EAL #1 for Initiating Condition SS4 states the following:

1.

Complete loss of any (site-specific) function requiredfor hot shutdown.

The corresponding Braidwood EAL for Initiating Condition MS5 on page 5.1-43 states the following:

1.

lxss of all efective means requiredfor Hot Shutdown provided in BwOA PRI-10, Table A.

AND 2.

Inadequate Shutdown Margin Provide justification for this deviation from the NUMARC/NESP-007 guidance. In addition i

provide procedure BwOA PRI-10.

t Braidwood Page 7 f

i

16.

MU7. Fuel Clad Degradation This IC deviates from the NUMARC/NESP-007 guidance in that site specific radiation monitor readings are not provided in the EALs for this IC.

t NUMARC/NESP 007 Example EALs #1 and #2 for Initiating Condition SU4 state the following:

1.

(Site-Specipc) radiation monitor readings indicatingfuel clad degradation greater thaa Technical Spec {}7 cation allowable limits.

2.

(Site-Specific) coolant sample activity value indicatingfuel clad degradation greater than Technical Specipcation allowable limits.

The corresponding Braidwood EAL for Initiating Condition MU7 on page 5-1.52 states the following:

VALID 1RE PR006B QB 2RE PROOO5B radiation monitor readings indicating fuel clad degradation > Technical Specipcation allowed limits.

OR Coolant activity value requiring implementation of an action statement in Technical Specipcation 3/4 4.8.

Revise this EAL to conform with the NUMARC/NESP-007 guidance or provide justification for this deviation from the NESP guidance.

17.

HA1. Security Event in the Protected Area This IC deviates from the NUMARC/NESP-007 guidance in that the following EAL is included, A bomb device is discovered inside the vital area. This EAL is indicative of a security event in a vital area and should therefore be included under Braidwood IC HS1

" Security Event in a Vital Area" which corresponds to NUMARC/NESP-007 IC HS1

" Security Event in a Vital Area."

Revise this IC and IC HS1 to be consistent with NUMARC/NESP-007 guidance or provide justification for this deviation from the NESP guidance.

Braidwood Page 8

18.

HAl. Security Event in the Protected Area This IC does not contain a list of (site-specific) security events.

NUMARC/NESP 007 Example EAL #2 for Initiating Condition HA4 states the following:

h 2.

Other security events as determinedfrom (site-specific) Safeguards Contingency Plan.

The corresponding Braidwood Threshold Value #3 for Initiating Condition HAl on page 5.1-62 states the following:

3.

A security event ofincreasing severity thatpersistsfor 2: 30 minutes.

Revise the EAL to define and/or list specific security events that warrant classification or provide justification for maintaining this IC in its present form.

19.

HSI. Security Event in a Plant Vital Area The EAL for this IC does not contain a list of (site-specific) security events.

NUMARC/NESP 007 Example EAL #2 for Initiating Condition HS1 states as follows:

2.

Other security events as determined from (site-specific) Safeguards Contingency Plan.

The corresponding Braidwood EAL for Initiating Condition HS1 on page 5.1-61 states the following:

2.

A security event which results in the loss of control of any vital area (other than the Control Room).

Revise the EAL to define and/or list specific security events that warrant classification or provide justification for maintaining this IC in its present form.

t Braidwood Page 9 w

20.

HS3. Control Room Evacuated AND CONTROL NOT established at remote locations in the olant in s 15 minutes.

The Braidwood EAL Threshold Value #2 on page 5.1-70 for Initiating Condition HS3, Evacuation of the Control Room AND CONTROL NOT established at remote locations in the plant in s 15 minutes, states the following:

2.

CONTROL of the plant cannot be establishedper BwOA PRI-5 in _< 15 minutes.

The licensees' basis information on page 5-1.70 for HS3 states:

Control - Control is defined as having placed all local control switches in local control necessaryfor operationfrom remote panels.

The criteria defining control is incomplete. Placing local control switches in local does not ensure control. This may be especially true considering the varied scenarios that may require control room evacuation (e.g., fire, electrical, seemity, sabotage, etc.). Placing local control switches in local should transfer control if all systems, controls, and interconnecting wiring are functional. The definition of " Control" should include a condition that functional control has been established per the identified procedure, BwOA PRI-5, not just switch positions changed.

Revise the EAL include a condition that functional control is established or provide justification for maintaining this EAL in its present form.

21.

HA4. Natural or Destructive Phenomena Inside a Vital Area.

This IC deviates from the NUMARC/NESP-007 guidance in that site specific areas, structures and buildings have not been identified.

NUMARC/NESP 007 Example EAL # 3 and #6 for Initiating Condition HA1 state the following:

3.

Report of any visible structural damage on any of thefollowing plant structures.

- Reactor Building

- Intake Building

- Ultimate Heat Sink

- Refueling Water Storage Tank

- Diesel Generator Building I

Braidwood Page 10

- Dtrbine Building

- Condensate Storage Tank

- Control Room

- Other (Site-Specipc) Structures 6.

Rtrbinefailure generated missiles result in any visible structural damage to orpenetration of any of thefollowing plant areas: (Site-Specific) list.

The corresponding Braidwood EAL for Initiating Condition HA4 on page 5-1.72 state the following:

4.

Repon of visible sinscrural damage to a structure (Building, tanks, etc.)

affecting operations ofsystems required to establish or maintain Cold r

Shutdown.

6.

Main Turbine rotating componentfailure which penetrates the casing and generates missiles causing damage to structures containing safety related equipment.

Revise the EAL to include specific areas, structure, and buildings or provide justification for this deviation from the NESP guidance.

22.

HA2. Fire or Explosion Affectine the Operability of Plant Safety Systems Recuired to Establish or Maintain Safe Shutdown.

This IC deviates from the NUMARC/NESP-007 guidance in that site specific areas, structures and buildings have not been identified.

NUMARC/NESP 007 Example EAL # 1.a for Initiating Condition HA2 states the following:

1.

Thefollowing Conditions exist:

a.

Fire or explosion in any of thefollowing (Site-Specific) areas:

- (Site specipc) list Braidwood Page 11

Corresponding Braidwood EAL #1 for Initiating Condition HA5 on page 5-1.76 states the -

followmg:

1.

Fire OR EXPLOSION afecting operability ofsafety systems required to establish or maintain Cold Shutdown Revise the EAL to include specific areas, structure, and buildings or provide justification for this deviation from the NESP guidance.

l 23.

HA3. Release of Toxic or Flammable Gases Within a Facility Structure Which Jeopardizes Ooeration of Systems Recuired to Maintain Safe Operations or to Establish or Maintain Cold Shutdown.

This IC deviates from the NUMARC/NESP-007 guidance in that the following condition was added to the EAL associated with this IC, toxic gases..... in life threatening concentrations that will afect the safe operation of the plant.

NUMARC/NESP 007 Initiating Condition HA3, example EAL #1 states:

1.

Report or detection of toxic gases uithin a Facility Structure in concentrations that will be life threatening to plant personnel.

The licensees' corresponding Initiating Condition HA6, EAL Threshold Value 1 on page 5.1-80 states:

1.

Report or detection of toxic gases within a Facility Structure in life threatening concentrations that will afect the safe operation of the plant.

Under the NUMARC EAL, the emergency would be declared if the level of toxic gases were

" life threatening to plant personnel." Under the licensees' EAL the emergency would be declared for " life threatening concentrations that will affect the safe operation of the plant."

Life threatening levels to plant personnel would likely affect safe operations since the EAL in meant to exclude (see basis discussion) buildings or areas not contiguous or adjacent to plant vital areas. The presence of toxic or flammable gas in or near vital areas (the potential to affect) should warmnt an Alert declaration. It may be difficult to determine how the life threatening levels to personnel would affect operation.

l Braidwood Page 12 l

i i

Revised this EAL to be consistent with NUMARC guidance or provide justification for this deviation from the NESP guidance.

In addition, the following definition of " TOXIC" from Licensee Change Submittal, DRE 03, for the Dresden Facilities, i.e. TOXIC - Exposure to the worker in excess of the limits specified in 29 CFR 1910.1000. In practice, itds should be consideredfor concentrations which are capable ofproducing incapacitation of the worker, should be included in the basis for this EAL or justification should be provided for not including this definition.

Braidwood Page 13

UNITED STATES

+#e==.\\

NUCLEAR REGULATORY COMMISSION I

v s

j OFFICE OF NUCLEAR REACTOR REGULATION

.g DIVISION OF RADIATION SAFETY AND SAFEGUARDS EMERGENCY PREPAREDNESS BRANCH RE:

REQUEST FOR ADDITIONAL INFORMATION ON PROPOSED EMERGENCY ACTION LEVEL CHANGES IN REVISION BYR-93-01 i

OF TIIE BYRON EMERGENCY PLAN l

TAC NOs:

M87327 and M87328 j

The NRC has completed its initial review of the proposed emergency action levels (EALs) in

[

Revision BYR-93-01 to the Bryon Station Site Specific Generating Station Emergency Plan -

l Annex. The proposed EALs were reviewed against the guidance in NUMARC/NESP-007,

" Methodology for Development of Emergency Action levels." NUMARC/NESP-007 has 1

been endorsed by the NRC in Regulatory Guide 1.101, " Emergency Planning and i

Preparedness for Nuclear Power Reactors," as an alternative means by which licensees can j

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 additionalinformation as discussed below.

l P

1.

RG1 - 1 Rem Total Effective Dose Ecuivalent (tede) OR 5 Rem Commited Dose Eauivalent (cde) to the Thyroid Initiating Condition (IC) RG1 does not include the following note which is contained in the corresponding NUMARC/NESP-007 IC, NOTE:

If the monitor reading (s) is sustainedfor longer than 15 minutes and l

the required assessments cannot bt completed within this period, then the declaration must be made based on the valid reading.

i Provide justification for this deviation from the NUMARC/NESP-007 guidance.

t

7 2.

RS1 - IC0 mrem Total Effective Dose Equivalent (tede) OR 500 mrem Committed Dose Equivalent (cde) to the Thyroid IC RSI does not include the following note which is contained in the corresponding NUMARC/NESP-007 IC, NOTE:

If the monitor reading (s) is sustainedfor longer than 15 minutes and the required assessments cannot be completed uithin this period, then the declaration must be made based on the valid reading.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

3.

RA2 - Release > 10 X ODCM limits for > 15 minutes a.

IC RA2 does not include the following note which is contained in the corresponding NUMARC/NESP-007 IC, NOTE:

If the monitor reading (s) is sustainedfor longer than 15 minutes and the required assessments cannot be completed uithin this period, then the declaration must be made based on the valid reading.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

b.

IC RA2 deviates from NUMARC/NESP-007 in that site specific liquid effluent monitors and readings are not specified in the EAL under this IC. The Bryon EAL specifies Liquid Releases: UNPL4NNED Liquid Release 210 X the ODCM maximum instantaneous release limitfor 215 minutes. The corresponding NUMARC/NESP-007 EAL is A valid reading on one or more of thefollouing monitors that acceds the "value shown' (site specyic monitors) indicates that the release may have e.xceed the above criterion and indicates the need to assess the release uith (site-specficprocedure):

Provide justification for this deviation from the NUMARC/NESP-007

guidance, Bryon Page 2

r c.

IC RA2 deviates from NUMARC/NESP-007 in that the EAL for liquid release is set at 10 x ODCM limits whereas NUMARC/NESP-007 specifies 200 times the radiological technical specifications as the threshold for this EAL (ODCM values can be used for sites that have eliminated radiological technical specifications). The basis for the Bryon IC states that "The Alert value for gaseous effluents was reduced to 10 x ODCM to ensure sequential classifications." It is not clear from the information provided why this reduction is necessary.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

4.

RU2 - Release > 2X ODCM for > 60 minutes IC RU2 deviates from NUMARC/NESP-007 in that site specific liquid effluent monitors and readings are not specified in the EAL under this IC. The Bryon EAL specific: Liquid Releases: UNPLANNED Liquid Release X 2 X the ODCAf maximum instantaneous release limitfor 160 minutes. The corresponding NUMARC/NESP-007 EAL is A valid reading on one or more of thefollowing monitors that exceeds the "value shown" (site speci]ic monitors) indicates that the release may have ezceed the above criterion and indicates the need to assess the release with (site-specificprocedure):

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

5.

Mall - Maior Fuel Damage OR Fuel Uncoverv Outside the Reactor Vessel mal 2 - Uncontrolled Loss of Refueling Cavity Volume ICs Mall and MA12 deviate from the corresponding NUMARC/NESP-007 IC (AA2) in that EALs contained in NUMARC/NESP-007 are not included. In particular the following NUMARC/NESP-007 example EALs for IC AA2 are not included:

3.

Water Level less than (Site-specific)feetfor the Reactor Refueling Cavity that will result in Irradiated Fuel Uncovering.

4.

Water Level less than (site-specific)feetfor the Spent Fuel Pool and Fuel Transfer Canal that will result in irradiated Fuel Uncovering.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

j

.Bryon Page 3 i

i

i 6.

1.b - Containment Critical Safety Function EAL 1.b, entitled " Containment Critical Safety Function" deviates from the corresponding NUMARCINESP-001 EAL, Containment pressure greater than containment depressurization system serpoint with less than onefull train ofdepressurization equipment operating in that the Bryon EAL includes the condition of No Containment Spray Available. It is not clear why the term "available" was substituted for the phrase "less than full train of depressurization equipment operating" for this EAL.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

7.

CONTAINMENT 1.a - Containment Radiation The basis for this EAL contains the following statement; POTENTIAL LOSS

......This value corresponds to 20% clad damage arut represents a direct (uncorrected) value which is conservativefor up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after reactor shutdown. A 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time is used to provide reasonable assurance that the Technical Support Center (TSC) would be available to provide evaluation to detennine if clad damage has exceeded 20%.

This statement can be read as directing the licensee staff to delay classifying events on Containment Radiation indications until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the initiation of the event.

Revise this statement to clarify its intent or provide additional information justifying retaining the basis in its present form.

8.

FUEL CLAD 2.c - Containment Radiation The basis for this EAL contains the following statement; LOSS

......The value ofrepresents a direct (uncorrected) value which is conservativefor up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after reactor shutdown. A 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time is used to provide reasonable assurance that the Technical Support Center (TSC) personnel would be available to provide evaluation to determine ifcladfailure has exceeded 5%.....

This statement can be read as directing the licensee staff to delay classifying events on Containment Radiation indications until 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the initiation of the event.

Revise this statement to clarify its intent or provide additional information justifying retaining the basis in its present form.

Bryon Page 4

I 9.

Bryon Station Fission Product Barrier Matrix The Bryon fission product barrier matrix did not contain an EAL which corresponds to NUMARC fission product barrier EALs contained under the heading of Emergency Director Judgement.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

10.

MUI. Loss of All Offsite Power for 215 minutes I

This IC contains the following EAL, ESF busses are energized. It is not clear whether including the generzl term "ESF busses" in this EAL is adequate to ensure accurate '

classification.

-l Provide information regarding the adequacy of the general 'n.n "ESF busses" in this EAL.

11.

MA2. Loss of All Offsite and Onsite AC Power h 15 minutes i

This IC contains the following EAL, Failure of...E5F busses. It is not clear whether including the general term "ESF busses" in this EAL is adequate to ensure accurate classification.

Provide information regarding the adequacy of the general term "ESF busses" in this EAL.

1 12.

MA3. Auto Trip NOT Successful I

a.

This IC deviates from NUMARC/NESP-007 in that the condition that a unit shutdoMM has Commenced is included in the Bryon EAL under this IC.

l NUMARC/NESP-007 Example EAL #1 for Initiating Condition SA2 states the following:

j 1.

(Site-Specific) indication (s) exist that indicate that recctor l

protection system setpoint was acceded and automatic scram l

did not occur, and a successful manual scram occurred.

The corresponding Bryon EALs for Initiating Condition MA3 on page 5.1-40 state the following:

1.

A Reactor Protection System actuation signal was received AND i

1 automatic Reactor trip did not occur.

1 i

Bryon Page 5

{

l

f AND 2.

A successful MANUAL TRIP occurred OR a unit shutdown has commenced.

Revise this IC to delete the condition that a unit shutdown has commenced or provide addition justification for this deviation from the NUMARC/hESP-007 guidance.

1 13.

MS4. Loss of Vital 125 Volt DC Power > 15 minutes The EAL for this IC deviates from the corresponding NUMARC/NESP-007 EAL in that a site-specific bus voltage indication was not included in the Bryon EAL.

i i

NUMARC/NESP-007 Example EAL #1 for Initiating Condition SS3 states the following:

1.

Loss ofAll Vital DC Power based on (site-specipc) bus voltage indicationsfor greater than 15 minutes.

The corresponding Bryon EAL for Initiating Condition MS4 states the following:

Loss of all 125V DCpower to a unit's ESF bussesfor.>._15 minutes.

i Provide justification for this deviation from the NUMARC/NESP-007 guidance.

4 14.

MU4. Unolanned Loss of 125V DC Power for > 15 minutes i

The EAL for this IC deviates from the corresponding NUMARC/NESP-007 EAL in that a site-specific bus voltage indication was not included in the Bryon EAL.

NUMARC/NESP Example EAL #1 for Initiating Condition SU7 states the following:

l 1.

Either of t*1efollowing conditions exist:

l Unplanned Loss of Vital DCpower to required DC busses based a.

on (site-specifc) bus voltage indications.

AND i

Bryon Page 6 1

i

)

a b.

Failure to restore power to at least one required DC bus with 15 minutesfrom the time ofloss.

The corresponding Bryon EALs for Initiating Condition MU4 on page 5-1.42 state the following:

1.

Loss of all125VDCponer to a Unit.

AAD 2.

Failure to restore power to at least one ESF DC bus within 15 minutes from the time ofloss.

i Provide justification for this deviation from the NUMARC/NESP-007 guidance.

3

+

15.

MSS. Loss of Hot Shutdown Capability This IC deviates from the corresponding NUMARC/NESP-007 IC in that the condition of Inadequate Shutdown Margin is "anded" with the other condition specified in this EAL, i.e.

Loss of all efective means requiredfor Hot Shutdown provided in BOA PRI-10, Table A.

NUMARC/NESP-007 Example EAL #1 for Initiating Condition SS4 states the following:

1.

Complete loss of any (site-specipc) function requiredfor hot shutdown.

The corresponding Bryon EAL for Initiating Condition MS5 on page 5.1-43 states the following:

1.

Loss of all efective means requiredfor Hot Shutdown provided in BOA PRJ-10, Table A.

r AND i

2.

Inadequate Shutdown Margin Provide justification for this deviation from the NUMARC/NESP-007 guidance. In addition provide procedure BOA PRI-10.

)

16.

MU7. Fuel Clad Degradation This IC deviates from the NUMARC/NESP-007 guidance in that site specific radiation j

I monitor readings are not provided in the EALs for this IC.

Bryon Page 7 i

NUMARC/NESP-007 Exampl:: EALs #1 and #2 for Initiating Condition SU4 state the following:

1.

(Site-Specifc) radiation monitor readings indicatingfuel clad degradation greater than Technical Specification allowable limits.

2.

(Site-Specipc) coolant sample activity value indicatingfuel clad degradation greater than Technical Specifcation allowable limits.

The correspondir.g Bryon EAL for Initiating Condition MU7 on page 5-1.52 states the following:

VALID 1RE PR006B QB 2RE PROOO6B radiation monitor readings indicating fuel clad degradation > Technical Specification allowed limits.

OR Coolant activity value requiring implementation of an action statement in Technical Specifcation.s/4 4.8.

Revise this EAL to conform with the NUMARC/NESP-007 guidance or provide justification for this deviation from the NUMARC/NESP-007 guidance.

17.

HAl. Security Event in the Protected Area This IC deviates from the NUMARC/NESP-007 guidance in that the following EAL is included, A bomb device is discovered inside the vital area. This EAL is indicative of a security event in a vital area and should therefore be included under Bryon IC HS1 " Security Event in a Vital Area" which corresponds to NUMARC/NESP-007 IC HS1 " Security Event in a Vital Area."

Revise this IC and IC HS1 to be consistent with NUMARC/NESP-007 guidance or provide justification for this deviation from the NUMARC/NESP-007 guidance.

18.

HAl. Security Event in the Protected Area This IC does not contain a list of (site-specific) security events.

NUMARC/NESP-007 Example EAL #2 for Initiating Condition HA4 states the following:

Bryon Page 8

l' 2.

Other security events as determinedfrom (site-specific) Safeguards Contingency Plan.

The corresponding Bryon Threshold Value #3 for Initiating Condition HA1 on page 5.1-62 states the following:

3.

A security event ofincreasing severity thatpersistsfor 2: 30 minutes.

l Revise the EAL to define and/or list specific security events that wamnt classification or provide justification for maintaining this IC in its present form.

19.

HSI. Security Event in a Plant Vital Area The EAL for this IC does not contain a list of (site-specific) security events.

NUMARC/NESP-007 Example EAL #2 for Initiating Condition HS1 states as follows:

2.

Other security events as determined from (site-specific) Safeguards Contingency Plan.

The corresponding Bryon EAL for Initiating Condition HS1 on page 5.1-61 states the following:

2.

A security event which results in the loss of control of any vital area (other than the Control Room).

Revise the EAL to define and/or list specific security events that warrant classification or i

provide justification for maintaining this IC in its present form.

20.

HS3. Co,aol Room Evacuated AND CONTROL NOT established at remote locations in the plant in s 15 minutes.

The Bryon EAL Threshold Value #2 on page 5.1-70 for Initiating Condition HS3, Evacuation of the Control Room AND CONTROL NOT established at remote locations in the plant in s 15 minutes, states the following:

2.

CONTROL of the plant cannot be established per BOA PRI-5 in.L 15 minutes.

The licenseef basis information on page 5-1.70 for HS3 states:

Bryon Page 9

)

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3

2 Control - Control is defined as hanng placed all local control switches in local l

control necessaryfor operationfrom remote panels.

i h

The criteria defining control is incomplete. Placing local control switches in local does not ensure control. Thi.s may be especially true considering the varied scenarios that may require control room evacuation (e.g., fire, electrical, security, sabotage, etc.). Placing local control switches in local should transfer control if all systems, controls, and interconnecting wiring are functional. The definition of " Control" should include a condition that functional control has been established per the identified procedure, BOA PRI-5, not just switch positions changed.

Revise the EAL include a condition that functional control is established or provide justification for maintaining this EAL in its present form.

21.

HA4. Natural or Destructive Phenomena Inside a Vital Area.

This IC deviates from the NUMARC/NESP-007 guidance in that site specific areas, structures and buildings have not been identified.

NUMARC/NESP-007 Example EAL # 3 and #6 for Initiating Condition HA1 state the following:

3.

Repon of any visible structural damage on any of thefollowing 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-Spec:fic) Structures 6.

Thrbinefailure generated missiles result in any visible structural damage to orpenetration of any of thefollowing plant areas: (Site-Specific) list.

t The corresponding Bryon EAL for Initiating Condition HA4 on page 5-1.72 state the following:

Bryon Page 10 i

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4.

Report of visible structural damage to a structure (Building, tanks, etc.)

afecting operations ofsystems required to establish or maintain Cold r

Shutdown.

6.

Main 7krbine rotating componentfailure which penetrates the casing l

and generates missiles causing damage to structures containing safety related equipment.

Revise the EAL to include specific areas, structure, and buildings or provide justification for i

this deviation from the NUMARC/NESP-007 guidance.

22.

HA2. Fire or Explosion Affecting the Operability of Plant Safety Systems Recuired to Establish or Maintain Safe Shutdown.

This IC deviates from the NUMARC/NESP-007 guidance in that site specific areas, structures and buildings have not been identified.

NUMARC/NESP-007 Example EAL # 1.a for Initiating Condition HA2 states the following:

1.

Thefollowing Conditions e.rist:

a.

Fire or explosion in any of thefollowing (Site-Specific) areas:

- (Site specific) list Corresponding Bryon EAL #1 for Initiating Condition HA5 on page 5-1.76 states the following:

1.

Fire OR DCPLOSION afecting operability ofsafety systems required to establish or maintain Cold Shutdouri Revise the EAL to include specific areas, structure, and buildings or provide justification for this deviation from the NUMARC/NESP-007 guidance.

23.

HA3. Release of Tc;ic or Flammable Gases Within a Facility Structure Which Jeopardizes Operativa of Systems Recuired to Maintain Safe Operations or to Establish or Maintain Cold Shutdown.

I This IC deviates from the NUMARC/NESP-007 guidance in that the following condition was added to the EAL associated with this IC, toxic gases..... in life threatening concentranons that will afect the safe operation of the plant.

Bryon Page 11

i NUMARC/NESP-007 Initiating Condition HA3, example EAL #1 states:

i 1.

Report or detection of toxic gases within a Facility Structure in concentrations that will be life threatening to plant personnel.

l The licensees' corresponding Initiating Condition HA6, EAL Threshold Value 1 on page 5.1-80 states:

1.

Repon or detection of toxic gases within a Facility Structure in hfe threatening concentrations that will afect the safe operation of the plant.

Under the NUMARC EAL, the emergency would be declared if the level of toxic gases were

" life threatening to plant personnel." Under the licensees' EAL the emergency would be declared for " life threatening concentrations that will affect the safe operation of the plant."

Life threatening levels to plant personnel would likely affect safe operations since the EAL in meant to exclude (see basis discussion) buildings or areas not contiguous or adjacent to plant vital areas. The presence of toxic or flammable gas in or near vital areas (the potential to affect) should warrant an Alert declaration. It may be difficult to determine how the life threatening levels to personnel would affect operation.

j Revised this EAL to be consistent with NUMARC guidance or provide justification for this i

deviation from the NUMARC/NESP-007 guidance.

In addition, the followiq: ilefinition of " TOXIC" from Licensee Change Submittal, DRE i 03, for the Dresden PaciH.1es, i.e. TQXIC - Exposure to the worker in excess of the limits l

specified in 29 CFR 1910.1000. In practice, this should be consideredfor concentrations which are capable ofproducing incapacitation of the worker, should '.>, Nded in the basis for this EAL or justification should be provided for not including this detmmn.

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Bryon Page 12 I

UNITED STATES ae \\

NUCLEAR REGULATORY COMMISSION

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y_.I a

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DIVISION OF RADIATION SAFETY OFFICE OF NUCLEAR REACTOR REGULATION h[A*64*

O AND SAFEGUARDS EMERGENCY PREPAREDNESS BRANCH RE:

REQUEST FOR ADDITIONAL INFORMATION ON PROPOSED EMERGENCY ACTION LEVEL CIIANGES IN REVISION DRE-93-03 OF TIIE DRESDEN EMERGENCY PLAN TAC NOs:

M87329 and M87330 The NRC has completed its initial review of the proposed emergency action levels (EALs) in Revision DRE-93-03 to the Commonwealth Edison Generating Stations Emergency Plan (GSEP) Dresden Station Annex. The proposed EAIS 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, 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.

A.

GENERAL COMMENT

S The licensee did not include the NUMARC criteria relating to judgement of the Emergency Director for fission product barrier loss or potential loss in any of the fission product barrier EALs. These EALs should be incorporated into the emergency classification scheme or justification should be provided for their omission.

Definitions between the plants are not consistent For example: Dresden defines Valid '

as " Reading are assumed valid unless circumstances cause the reading to be suspect."

12salle and Quad Cities define Valid as "A reading confirmed by redundant measurement, instrumentation, local reading or grab sample." The licensee should use the same defmitions at all the nuclear plants.

j l

B.

EAI,lEECIFIC COMMENTS Recognition Category R - Abnormal Rad Ixvels/ Radiological Effluent 1.

Subcategory RG1 - 1 Rem Total Effective Dose Equivalent (tede) OR 5 Rem Committed Dose Equivalent (cde) to the Thyroid NUMARC AGI - Abnormal Rad Levels / Radiological Effluent example EALs state:

1.

A valid reading on one or more of thefollowing monitors that acceds or is apected to acced the value shown indicates that the release may have acceded 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 sustainedfor longer than 15 minutes and the required assessments cannot be completed within this period, then the declaration must be made based on the valid reading.

2.

A valid reading sustainedfor 15 minutes or longer on perimeter radiation monitoring system greater than 1000 Mr/hr. [for sites having telemetered perimeter monitors]

3.

Valid dose assessment capability indicates dose consequences greater than 1000 mR whole body or 5000 mR child thyroid.

4.

Field survey results indicate site boundary dose rates acceding 1000 mR/hr expected to continuefor more than one hour; or analysis offield survey samples indicate child thyroid commitment of5000 mRfor one hour ofinhalation.

Dresden EAL Abnormal Rad Levels / Radiological Effluent RG1 threshold values state:

ONE of thefollowing when Drywell Radiation level 2100 R/hr, or Reactor Vessel Level s -143 inches, or Radiation level & 1 R/hr on Refuel Floor indicating clad / core damage:

1.

The station total release as indicated by the SUM of VALID readings of Units 2 and 3 on thefollowing monitors indicate the release has or is apected to aceed 1 Rem total efective dose equivalent (tede) OR 5 2

r Rem committed dose equivalent (cde) to the thyroid and indicates the need to assess the release with dose projection models.

The Sum of:*

2/3 Reactor Building SP1NG channel 3, 5, or 7, and 1 and 2/3 Chimney SP1NG channel 3, 5, or 7:

2 9.1E+06 pCi/sec as detennined by DOP 1700-10 2.

Dose assessment results indicate dose consequences of1 Rem (tede), or Dose assessment results indicate dose consequences of 5 Rem (cde) to the thyroid.

3.

RESTRICTED AREA BOUNDARY dose rates k 1 R/hr expected to continuefor k 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or Analysis indicates 5 Rem (cde) to the thyroid at the RESTRICTED AREA BOUNDARY.

4.

Valid A-model Efluent Release Report indicating a General Emergency COMMENT: The licensee inclusion of drywell radiation level, vessel level, and refuel floor radiation level is inconsistent with the guidance and potentially confusing. A valid (confirmed) stack monitor release in excess of the calculated threshold value is sufficient to classify the event. All reactor emergency events that cause a high release rate may not trigger one of the three entry level conditions. The si,milar EALs for CECO PWRs do not include this entry condition requirement. The licensee should eliminate these conditions in the EAL or provide justification on their benefit.

RG1 does not include the following note which is contained in the corresponding NUMARC/NESP-007 IC, NOTE:

If the monitor reading (s) is sustainedfor longer than 15 minutes and the required a:sessments cannot be completed within this period, than the declaration must be made based on the valid reading.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

The licensee basis for threshold value #4 states that the A-model reports at 1000 mrem /hr. No mention is made about the NUMARC criteria of 5000' mR child thyroid dose. Information should be provided on the capability of the A-model to assess thyroid dose.

3

r 2.

Subcategory RS1 - 100 mrem Total Effective Dose Eauivalent (tede) OR 500 mrem Committed Dose Ecuivalent (cde) to the Thyroid NUMARC AS1 - Abnoirmal Rad Levels / Radiological Effluent example EALs state:

1.

A valid reading on one or more of thefollowing 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 uith (site-speapcprocedure):

(site-speafc list)

Note: If the monitor readin[g(s) is sustainedfor longer than 15 minutes and the required assessments cannot be completed within this period, then the declaration must be made based on the valid reading.

2.

A valid reading sustainedfor 15 minutes or longer on perimeter radiation monitoring system greater than 100 mR/hr. [for sites having telemetered perimeter monitors]

3.

Valid dose assessment capability indicates dose consequences greater than 100 mR whole body or 500 mR child thyroid.

4.

Field survey results indicate child indicate site boundary dose rates exceeding 100 mR/hr expected to continuefor more than one hour; or analysis offeld survey samples indicate child thyroid commitment of 500 mRfor one hour ofinhalation.

l Dresden EAL Abnormal Rad levels / Radiological Effluent RS1 threshold values state:

ONE of thefollowing when Drywell Radiation level 2 100 R/hr, or Reactor Vessel Level :s; -143 inches, or Radiation level 2 1 R/hr on Refuel Floor indicating clad / core damage:

1.

The station total release as indicated by the SUM of VALID readings of Units 2 and 3 on thefollowing monitors indicate the release has or is expected to exceed 100 mrem total efective dose equivalent (tede) OR 500 mrem committed dose equivalent (cde) to the thyroid.

The Sum of:

2/3 Reactor Building SPING channel 3, 5, or 7, and 4

i 1 and 2/3 Chimney SPING channel 3, 5, or 7:

& 9.1E+05 pCi/sec as determined by DOP 1700-10 2.

Dose assessment results indicate dose consequences of100 mrem (tede), or Dose assessment results indicate dose consequences of 500 mrem (cde) to the thyroid.

3.

RESTRICTED AREA BOUNDARY dose rates k 100 mR/hr expected to continuefor h 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or Analysis indicates 500 mrem (cde) to the thyroid at the RESTRICTED AREA BOUNDARY.

4.

Valid A-model Efluent Release Report indicating a SITE Emergency COMMENT: The licensee inclusion of drywell radiation level, vessel level, and refuel floor radiation level is inconsistent with the guidance and potentially confusing. A valid (confirmed) stack monitor release in excess of the calculated threshold value is sufficient to classify the event. Furthermore, all reactor emergency events that cause a high release rate may not trigger one of the three entry level conditions. The similar EALs for CECO PWRs do not include this entry condition requirement. The licensee should eliminate these conditions in the EAL or provide justification on their benefit.

RSI does not include the following note which is contained in the corresponding NUMARC/NESP-0071C, NOTE:

If the monitor reading (s) is sustainedfor longer than 15 minutes and the required assessments cannot be completed within this period, than the declaration rmist be made based on the valid reading.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

The licensee basis for threshold value #4 states that the A-model reports at 100 mrem /hr. No mention is made about the NUMARC criteria of 500 mR child thyroid dose. Information should be provided on the capability of the A-model to assess thyroid dose.

3.

Subcategory RA2 - Release 2 10 X ODCM limits for d 15 Minutes.

NUMARC AAl - Abnormal Rad Ievels/ Radiological Effluent example EALs state:

5 1

B 1.

A valid reading on one or more of thefollowing 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-specipeprocedure):

(site-specifc list)

Note: If the monitor reading (s) is sustainedfor longer than 15 minutes and the required assessments cannot be completed uithin this period, then the declaration must be made based on the valid reading.

2.

Confrmed sample analysisfor gaseous or liquid releases indicates concentrations or release rates in excess of(200 X site-specifc technical specipcations)for 15 minutes or longer.

3.

A valid reading on perimeter radiation monitoring system greater than 10 mR/hr sustainedfor 15 minutes or longer. [for sites having telemetered perimeter monitors]

4.

Valid indication on automatic real-time dose assessment capability greater than (200 X site-specifc technical specifications)for 15 minutes or longer. (for sites having such capability]

Dresden EAL Abnormal Rad Levels /Radiolcgical Effluent RA2 threshold i

values state:

ONE of thefollowing when Drywell Radiation level < 100 R/hr, or Reactor Vessel Level > -143 inches, or Radiation level < 1 R/hr on Refuel Floor indicating no clad / core damage:

1.

The station total release as indicated by the SUM of VALID readings of Units 2 and 3 on thefollowing monitors indicates that the release may have exceeded k 10 X ODCM limits and indicates the need to assess the release:

The Sum of Gaseous Releases:

]

2/3 Reactor Building SPING channel 3, 5, or 7, and 1 and 2/3 Chimney SPING channel 3, 5, or 7:

a.

k 8.5E+05 pCi/sec as dctermined by DOP 1700-10 b.

Liquid Releases:

6 j

UNPLANNED Liquid Releases 2 10 X the ODCM maximum instantaneous release limit.

2.

Grab sample indicate concentrations or release rates 210 X the ODCM maximum instantaneous release limitfor 2 15 minutes.

3.

RESTRICTED AREA BOUNDARY dose rates 210 mR/hr expected to continuefor k 15 minutes.

4.

Valid A-model Efluent Release Repon indicating an ALERT.

COMMENT: The licensee inclusion of drywell mdiation level, vessel level, and refuel floor radiation level is inconsistent vith the guidance and potentially confusing. A valid (confirmed) stack monitor release in excess of the calculated threshold value is sufficient to classify the event. Furthermore, all reactor emergency events that cause a high release rate may not trigger one of the three entry level conditions. The similar EALs for CECO PWRs do not include this entry condition requirement. The licensee should eliminate these conditions in the EAL or provide justification on their benefit.

RA2 does not include the following note which is contained in the corresponding NUMARC/NESP-007 IC,

{

NOTE:

If the monitor reading (s) is sustainedfor longer than 15 minutes and the required assessments cannot be completed within this period, than the declaration must be made based on the valid reading.

Provide justification for this deviation from the NUMARC/NESP-007 guidance.

IC RA2 deviates from NUMARC/NESP-007 in that the EAL for releases is set at 10 x ODCM limits whereas NUMARC/NESP-007 specifies 200 times the radiological technical specifications as the threshold for this EAL (ODCM values can be used for sites that have eliminated radiological technical specifications). The basis for the Dresden IC states that "The Alen value for gaseous effluents was reduced to 10 x ODCM to ensure sequential classifications." It is not clear from the information provided why this reduction is necessary.

r Provide justification for this deviation from the NESP guidance.

k f

7 7

+

The licensee does not provide site specific monitor /s for a liquid release. If installed, the monitor /s should be specified and threshold values provided in the EAUs.

4.

Subcategory RU2 - Belease 2 2 X ODCM for 2 60 Minutes.

NUMARC AU1 - Abnormal Rad Levels / Radiological Effluent example EALs state:

1.

A valid reading on one or more of thefollning monitors that acceds the *value 51wwn" (site-specipc monitors) indicates that the release may have acceded the above criterion and indicates the need to assess the release with (site-specipcprocedure):

(site-specipe list)

Note: If the monitor reading (s) is sustainedfor longer than 60 minutes and the required assessments cannot be completed within this period, then the declaration must be made based on the valid reading.

2.

Co.: firmed sample analysisfor gaseous or liquid releases indicates concentrations or release rates with a release duration of 60 minutes or longer in acess of(2 X site-specific technical specifications).

3.

A valid reading on perimeter radiation monitoring system greater than 0.10 mR/hr above nonnal backgroundfor 60 minutes. (for sites having telemetered perimeter monitors]

4.

Valid indication on automatic real-time dose assessment capability greater than (site-specipe value)for 60 minutes or longer. fjor sites having such capability]

Dresden EAL Abnormal Rad Levels / Radiological Effluent RU2 threshold values state:

ONE of thefollowing when Drywell Radiation level < 100 R/hr, or Reactor Vessel Izvel > -143 inches, or Radiation level < 1 R/hr on Refuel Floor indicating no clad / core damage:

1.

The station total release as indicated by the SUM of VALID readings of Units 2 and 3 on thefollowing monitors indicates that the release may have acceded h 2 X ODCM limits.

8

P The Sum of Gaseous releases:

2/3 Reactor Building SPING channel 3, 5, or 7, and 1 and 2/3 Chimney SPING channel 3, 5, or 7:

a.

k 1.7E+05 pCi/sec as determined by DOP 1700-10 b.

Liquid Releases:

UNPLANNED Liquid Releases k 2 X the ODCM maximum instantaneous release limitfor 60 minutes.

2.

Grab sample indicate concentratioru or release rates k 2 X the ODCM maximum instantaneous release limitfor k 60 minutes.

3.

Valid A-model Efluent Release Reporr indicating an UNUSUAL EVENT.

COMMENT: The licensee inclusion of drywell radiation level, vessel level, and refuel floor radiation level is inconsistent with the guidance and potentially confusing. A valid (confirmed) stack monitor release in excess of the calculated threshold value is sufficient to classify the event. Furthermore, all reactor emergency events that cause a high release rate may not trigger one of the three entry level conditions. The similar EALs for CECO PWRs do not include this entry condition requirement. The licensee should eliminate these conditions in the EAL or provide justification on their benefit.

The licensee does not provide site specific monitor /s for a liquid release. If installed, the monitor /s should be specified and threshold values provided in the EAUs,

{

Recoenition Catecorv F - Fission Product Barrier Deeradation 5.

Subcategory 1.a - Containment pressure The NUMARC table 3, Primary Containment Barrier Example EALs, Loss example #1, Drywell Pressure states:

Rapid unaplained decrease following initial increase OR Dr)* ell pressure response not consistent with LOCA conditions.

i j

9

The Dresden EAL 1.a - Containment Pressure threshold value for loss states:

Rapid pressure decrease in containment after increase without containment spray.

COMMENT: The licensee omitted the NUMARC criteria, Drywell pressure response not consistent with LOCA conditions, from this EAL. However, the licensee does explain in the basis for this EAL that " Containment pressure -

should increase as a result of mass and energy release into the containment from a LOCA."

The licensee should revise this EAL to be consistent with the NUMARC EALs or provide a rationale in the basis for the variations.

6.

Subcategory 1.c.2 - Containment Breached /Bynassed The Dresden EAL 1.c.2 - Containment Breached / Bypassed inreshold value for loss states:

UNISOLABLE breach ofprimary containment.

COMMENT: The licensee basis for this EAL basis states:

"UNISOLABLE - A breach that is not readily isolable OR attempts for immediate isolation of the breach have been made and were unsuccessful.

Attempts for isolation should be made prior to the accident classification.

LOSS - an unisolable breach implies that a breach is NOT readily isolable OR attempts for immediate isolation of the breach have been made and were unsuccessful. Attempts for isolation should be made prior to the accident classification. Ifisolable upon identification no declaration need be made under this EAL although other EALs may be applicable. A breach of primary containment refers to a loss of primary containment integrity as described m the Technical Specifications definitions or primary containment Limiting Conditions for Operation (LCO)."

The terms "readily" and "immediate" are not defined. The term " attempts" implies more than one try at isolation, but does not define the number of attempts. The wording "Ifisolable upon identification..." implies some time to identify the breach location, but no time period is provided. There is no NUMARC EAL that directly correlates to this licensee EAL.

The licensee should provide clear definition for the terms used in this EAL.

The licensee should provide additional information for the inclusion of this EAL in the classification scheme.

10 l

7.

Subcategory 1.d - Containment Radiation Monitors.

NUMARC Primary Containment Barrier, Example number 3, Significant Radioactive Inventory in Containment.

The Dresden basis for this parameter states:

7he value of 7000 R/hr uncorrected is conservative up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after shutdown. A four hour time is used to provide reasonable assurance that the Technical Suppon Center personnel would be available to prwide an evaluation to determine ifcladfailure has exceeded 20%.

COMMENT: NUMARC does not discuss a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time for the corresponding EAL basis. The licensee use of a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> window is potentially confusing.

The licensee basis needs to be clear that the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time period does not delay the classification and that an assessment > 20% fuel clad will be treated as an equivalent threshold value.

8.

Subcategory 2.c - Fuel Clad.

NUMARC Fuel Clad Barrier EAL example #3, Drywell Radiation Monitoring.

The Dresden basis for this parameter states:

1750 R/hr uncorrected is a value which is conservative up to 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />sfollowing a reactor shutdown. A four hour time is used to provide reasonable assurance that the Technical Support Center personnel would be available to provide an evaluation to determine of cladfailure has exceeded 5%.

COMMENT: NUMARC does not discuss a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time for the corresponding EAL basis. The licensee use of a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> window is potentially confusing.

The licensee basis needs to be clear that the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time period does not delay the classification that an assessment > 5% fuel clad will be treated as an equivalent threshold value.

9.

Subcategory 3.a.1 - RCS Leaktate The NUMARC table 3, RCS Barrier Example EALs, Loss example #1, RCS Leak Rate states:

The ' Loss' EAL is based on design basis accident analysis which show that even if MSIV closure occurs within design limits, dose consequences offsite from the "puf* release would be in excess of10 millirem. Thus, this EAL is includedfor consistency with the Alen emergency classification.

I1

The Dresden EAL 3.a.1 - RCS Leakrate threshold value for loss states:

LOSS: UNISOLABLE Main Steam Line Break.

POTENTIAL LOSS: UNISOLABLE.RCS Leakage 2 50 GPM.

COMMENT: The licensee basis defines UNISOLABLE as: "A leak that is NOT readily isolable OR attempts for immediate isolation of the leak have been made and were unsuccessful. Attempts for Isolation should be made prior to accident classification." The licensee deals with unisolable primary system leakage outside the drywell in EAL #3.a.2. This EAL, #3.a.1, is directed to RCS leakage inside containment however, it does not specifically state inside containment. NUMARC, in table 3, uses the qualifier UNISOLABLE for leakage outside the drywell and specifically does not qualify leakage inside the drywell. Inclusion of the qualifier "UNISOLABLE" is not consistent with the NUMARC criteria.

The licensee provides for " attempts to isolate" before accident classification, but does not provide any time limit or number of attempt limits. The licensee does not defime "immediate" or "readily."

I The licensee should revise this EAL to be consistent with the NUMARC EALs or provide a rationale in the basis for the variations.

-10.

Subcategory 3.b - Drvwell Pressure The NUMARC table 3, RCS Barrier Example EALs, less example #2, Drywell Pressure states:

The (site-specific) drywellpressure is based on the drywell high pressure alarm serpoint and indicates a LOCA. A higher value may be used ifsupporting documentation is provided which indicates the chosen value is less than the pressure which would be reachedfor a 50 GPM Reactor Coolant Leak.

The Dresden EAL 3.b - Drywell Pressure threshold value for loss states:

Drywell Pressure k 2.0 PSIG (ECCS setpoint) due to reactor coolant leakage.

COMMENT: The NUMARC criteria suggests the selection of the drywell.

high pressure alarm setpoint or a higher value may be used if documentation is provided which indicates the chosen value is less than the pressure which would be reached for a 50 gpm reactor coolant system leak. - The licensee selected the ECCS setpoint. It is not clear that the ECCS setpoint is the same as the high pressure alarm setpoint or is equivalent to 50 gpm system leak.

12

The licensee basis for the selected value is not sufficient to determine if the conservative NUMARC criteria is met.

l The licensee should provide additional information before acceptance of this EAL.

Recognition Catecory M - System Malfunctions t

11.

Subcategory NUMARC SS4 - Complete less of Function Needed to Achieve.

f or Maintain Hot Shutdown example EAL number 1. states:

Complete loss of any (site-specyic) function requiredfor hot shutdown.

COMMENT: There is no licensee EAL that specifically addresses loss of hot shutdown function.

In the October 1,1993 Revision package (attachment C) under NUMARC EAL SS4, CECO makes the statement "Not applicable to BWRs. Hot Shutdown is defined for BWRs as having the mode switch in shutdo'wn with all control rods inserted and temperature > 212 *F. If these conditions are not met, an ATWS has occurred and the ATWS EALs cover the situation." While the reviewer would agree that the " reactivity control" function of this EAL is adequately addressed for BWRs in the ATWS EALs (because of no need to borate or maintain boration once the rods are inserted), the Heat Sink function l

still needs to be addressed.

The licensee should address the loss of hot shutdown function as suggested by I

the NUMARC criteria.

12.

Subcategory MS4 - Loss of 125 VDC Power 2 15 minutes.

i The NUMARC SS3 example EAL #1 states:

Loss of all DC Power based on (site-specific) bus witage indicationsfor greater than 15 minutes.

The Dresden EAL MS4 EAL threshold value #1 states:

CONFIRMED loss of all VITAL 125 VDCpowerfor 215 minutes.

COMMENT: The licensee does not provide a specific meter /s or control panel indication /s for use with this EAL. No minimum safe bus voltage is

~

specified to ensure adequate voltage is supplied to vital DC equipment.

13 i

k

The licensee should consider providing a specific meter /s or control panel indication /s that can be used to determine the power status of the DC buses.

13.

Subcategory MU4 - UNPLANNED Loss of 125 VDC Power h 15 minutes.

The NUMARC SU7 example EAL #1 states:

a. UNPMNNED Loss of all Vital DCponer to required DC busses based on (site-specific) bus voltage indications. AND

b. Failure to restore poner to at least one required DC bus within 15 minutes from the time ofloss.

The Dresden EAL MU4 EAL threshold values state:

1. UNPUNNED loss of all125 VDC buses is CONFIRMED. AND

2. Failure to restore power to at least one 125 VDC bus in < 15 minutes from the time ofloss.

COMMENT: The licensee does not provide a specific meter /s or control panel indication /s for use with this EAL. No minimum safe bus voltage is specified, as required by the NUMARC criteria, to ensure adequate voltage is supplied to vital DC equipment.

The licensee should provide a specific meter /s or control panel indication /s that can be used to determine the power status of the DC buses.

14.

Subcategory MU7 - Fuel Clad Degradation The NUMARC SU4 example EAL 1. states:

(Site-Specipc) radiation monitor readings indicatingfuel clad degradation greater than Technical Specipcation allonuble limits.

The Dresden EAL MU7 - Fuel Clad Degradation EAL threshold value

1. states:

Ofgas system isolation has occurred on a VALID Ofgas radiation monitor high trip.

COMMENT: It is assumed that the high trip is from the Post-Treatment monitor. The Post-Treatment monitor reading versus coolant activity are

)

dependent on the adsorber bed line up and hold up time. The licensee should l

14

i consider use of other indications such as pre-treatment monitors and main steam line monitors. The licensee selection of the trip setpoint might not be as conservative as suggested by the NUMARC criteria " radiation monitor readings."

The licensee should provide information that the selected threshold value meets the NUMARC conservative criteria.

15.

Subcategory MU8 - RCS leakage.

l The NUMARC SU5 example EAL 1. states:

1hefollowing conditions exist: a. Unidennped orpressure boundary leakage greater than 10 gpm. OR b. Idennped leakage greater than 25 gpm.

The Dresden EAL MU8 - RCS leakage EAL threshold value states:

1. UNIDENTIFIED RCS leakage into the primary containment k 10 gym.

OR 2. Total (IDENTIFIED + UNIDENTIFIED) RCS leakage into the primary containment h 35 gpm.

COMMENT: The licensee use of total leakage is not consistent with the NUMARC criteria.

The licensee should revise this EAL to be consistent with the NUMARC EALs or provide a rationale in the basis for the variations.

16.

Subcategory Mall - Maior Fuel Damace OR Fuel Uncoverv Outside the Reactor Vessel.

The NUMARC AA2 example EAL 1. states:

A (site-specifc set point) alann on one or more of thefollowing radiation monitors:

Refuel Floor Area Radiation Monitor Fuel Handling Building Ventilation Monitor Fuel Bridge Area Radiation Monitor The Dresden EAL Mall - Major Fuel Damage OR Fuel Uncovery Outside the Reactor Vessel EAL threshold value number 1 states:

Valid reading of k 100 R/hr on refuelfloor radiation monitor.

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COMMENT: The licensee selected value 2100 R/hr seems high for this threshold value. The licensee should identify the specific radiation monitor /s.

The licensee should confirm that the selected value is the alarm setpoint or provide a rationale in the basis for use of the 2 100 R/hr value.

17.

Subcategory mal 2 - UNCONTROLLED Loss of Refueling Cavity Volume.

The NUMARC initiating condition states:

Major damage to irradiatedfuel or* loss of water level that has or uill result in uncovering ofirradiatedfuel outside the reactor vessel.

The Dresden mal 2 - UNCONTROLLED Loss of Refueling Cavity Volume initiating condition states:

Damage to spentfuel OR loss of water level such that irradiatedfuel uill become uncovered.

COMMENT: The licensee initiating condition indicates damage to spent fuel.

However, no specific criteria is presented to define what is meant by damage.

Only uncovery is presented as EAL threshold values.

The licensee should consider including a definition of damage to spent fuel in this EAL.

Recoenition Catecorv H - Hazards and Other Conditions.

18.

Subcategory HS1 - Security Event in a Vital Area.

The NUMARC HS1 example EAL #2 states:

Other security events as determinefrom (site-specyic) Safeguards Contingency Plan.

The Dresden basis for HS1 states:

A security event is as defined in the security plan, section 1.

COMMENT: The licensee reference to a separate document, security plan, for the definition of a security event places an unnecessary burden on the Emergency Director. The licensee should include those defined security events that result in emergency classification in the EAL threshold value section.

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19.

Subcategory HA4 - Natural OR destructive phenomena inside Vital Area.

The NUMARC HA1 example EALs state:

2. Tornado or high sinds striking plant vital areas: Tornado or high uinds greater than (site-specific) MPH strike within protected area boundary.

3. Repon of any visible structural damage on any of thefollouing plant structures:

Reactor Building intake Building Ultimate Heat Sink Refueling Water Storage Tark Diesel Generator Building Turbine Building Condensate Storage Tank Control Room Other (site-specyic) Structures.

The Dresden HA4 - Natural OR destructive phenomena inside Vital Area EAL threshold value states:

2. Tornado strike uithin the Protected Area which afects equipment or structures uithin a vital area.

3. Sustained high uinds k 90 mph on A-model report, computer point OR meter reading.

4. Report of risible structural damage to a structure (building, tanks, etc) afecting operations ofsystems required to establish or maintain Cold Shutdown.

COMMENT: The licensee use of the terms "affects" and "affecting" places a qualifying condition on these events that is not present in the NUMARC EALs. The NUMARC criteria only provides for tornado, high winds or report of visible structural damage (structure specific). Affecting operation of equipment is not part of the NUMARC criteria. The NUMARC basis for structure damage states that the EAL should specify a site-specific list of structures containing systems and functions required for safe shutdown of the plant. The licensee does not provide a complete list of specific structures.

The licensee should revise this EAL to be consistent with the NUMARC EALs i

or provide a rationale in the basis for the variations.

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e James E. Dyer October 27, 1993 DISTRIBUTIOfl W/ALL ENCLOSURES CPedersen, Rill SBoynton J0'Brien PEP 8 R/F Central files NRC & Local FDRs DISTRIBUTION W/0 ENCLOSURES FCongel EButcher LJCunningham PMcKee RErickson FKantor JRoe DISTRIBUT10f4 W/BRAIDWOOD REVIEW ONLY RAssa l

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