ML20128G166
| ML20128G166 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 10/03/1996 |
| From: | Norris J NRC (Affiliation Not Assigned) |
| To: | NRC |
| References | |
| NUDOCS 9610080360 | |
| Download: ML20128G166 (26) | |
Text
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October 3, 1996 l
LICENSEE: GPU Nuclear Corporation i
FACILITY: Three Mile Island, Unit 1 (TMI-1) l
SUBJECT:
SUMMARY
OF SEPTEMBER 24, 1996, MEETING REGARDING RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION (RAI) RELATING TO PROPOSED CHANGES TO EMERGENCY ACTION LEVELS (EALs)
On Tuesday, September 24, 1996, a meeting was held at NRC headquarters, One White Flint North, Rockville, Maryland, between GPU Nuclear Corporation (GPU/ licensee) and the NRC staff. The purpose of the meeting was to discuss preliminary responses to the staff's.RAI relating to the request to change the ,
EALs for TMI-1. Enclosure 1 is a list of Participants, and Enclosure 2 .
contains a copy of the preliminary response to the RAI. Based on the meeting, GPU will prepare the final responses to the RAI and will submit the to the staff. t (Original Signed By)
Jan A. Norris, Senior Project Manager Project Directorate I-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket No. 50-289
Enclosures:
- 1. List of Participants
- 2. Preliminary Response to RAI cc w/encls: Licensee and service list e
Distribution l
HARD CO,J E-MAIL Docket File
- RZimmerman PTressler g PUBLIC* SVarga EJordan \ l PDI-3 Plant
- JZwolinski EFox OGC JStolz SMaingi ACRS JNorris WDean J0'Brien k l 07,UMENT NAM E : G: \NORRIS\MEETSUM5.TMI r- . .... . c . c.,y oi .n.a, .... c . co.. .n.a., . . ,e . u .,
OFFICE PM:P0h-l l LA:PDIV-2 l/V D:PDI-g l l l l NAME JN6eriA9 PTresslefQX.i JStolz %
DATE 10) O 796 10/3/9'6> 10/';/96' 10/ /96 10/ /96 0FFICIAL RECORD COPY l
9610000360 961003
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MEETING BETWEEN NRC STAFF AND GPUN RELATIVE TO TMI-1 REQUEST TO CHANGE EALs SEPTEMBER 24,1996 LIST OF ATTENDEES NRC fdgi J. Norris A. Miller E. Fox J. Grisewood S. Maingi N. Brown J. O'Brien ENCLOSURE 1 1
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- September 20,1996 l l .
!, TMI response to the Request for Additional Information from the NRC.
I. GENERAL
- 1. It is unclear as to whichportion of the EALs apply to Unit I andwhich apply to Unit 2 or both. Provide additionalinformation as to the applicability of the EALs to each of the units andhow the EAL scheme is to be used to classify events at either unit.
RESPONSE
ThD-2 is defueled and is in Post Defueling Monitored Storage (PDMS), which has been approved by the NRC. Chapter 8 of the TMI-2 PDMS SAR, Section 8.2, analyzes the off I
site dose consequences of credible, postulated, unanticipated release events at TMI-2 during j PDMS. The maxunum value for any event was less than the annual dose limits in the ThH I ODCM and 10CFR50 Appendix I (15 MREM / year). Based on this analysis TMI-2 is not i included in the radiological EALs. !
Because the unit is defueled, there are not any requirements for EALs dealing with Fission Products or Systems. Additionally, natural phenomena affects the site in general and not just ThD-1 or TMI-2.
The remaining item that could affect TMI-2 is a fire. However, because the ThH fire EAL addresses a fire inside the Protected Area, this includes TMI-2 without making a specific reference to TMI-2. Follow-up reporting per licensing dockets will still differentiate TMI-1 and TMI-2, but the EALs will not differentiate the units.
- 2. NUMARC/NESP-007 provides guidance concerning emergency class downgrading.
RESPONSE
ThH has had criteria to evaluate the EALs to escalate or de-escalate (downgrade) event classification for several years. The information is included in EPIP-TMI .02, Emergency Direction, and EPIP-COM .45, Classified Emergency Termination / Recovery.
The decision to escalate or de-escalate (downgrade) is performed by re-evaluating the existing EALs. Therefore it is prudent to provide directions'to re-evaluate in a procedure where actions are required. The EAL procedure is a listing and no action other than evaluation are expected from that procedure.
- 3. A definition is notprovidedan the word " Imminent" is usedin EAL G7.1
RESPONSE
. The following definition is included in the EAL procedure:
IMhENENT: This is when the loss condition will occur in an hour or less.
Additionally it is when equipment needed to prevent the loss is not
! available and it is unknown when the equipment will be available. It is also applicable if necessary equipment is not expected to be returned before the loss condition occurs.
ENCLOSURE 2 arsr Nac. ooc )
September 20,1996
.' II. SPECIFIC
- 1. NUMARCInitiating Condision (IC) A U1 includes example EALs based on efluent monitor readings, sample results, perimeter radiation monitoring results and dose assessment.
PROBLEM A. The TMI EAL scheme did include an EAL corresponding to NUMARC Example EALs AUl. An EAL based upon a radiation monitor indication is needed in case a dose assessment cannot be performed within I hour (for the Unusual Event classification level EAL) or 15 minutes (for the Alen or higher emergency r, classification level).
Add an EAL corresponding to NUMARC EAL AUI.1 or provide additional justification for this deviation. This comment also applies to TMI's EAL A1.1, S1.1
- and G1.1.
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RESPONSE
The program in place at TMI meets the intent of the NUMARC EAL for radiation monitor indication because the automated dose assessment system obtains the monitor reading every 15 minutes and uses real- time meteorology and effluent flow rates to determine the Offsite dose. With such a system, there is no need to have a pre-established "value shown" radiation monitor reading to be used to declare an event. Such pre-established values must ,
be based on meteorological and flow rate assumptions that make such an event declaration valid only in limited instances. The result is that the use of such values will result in both conservative and non-conservative decisions. It is far more accurate the have the automated dose assessment system evaluate monitor readings continuously to determine if an event should be declared.
The inability to perform a dose projection within the required I hour or 15 minute period is not a credible event. In the rare instances when the automated system is not available, local manual computer codes are available to perfonn the assessment of monitor readings in the required time frame.
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l AMLEsP,,NRC. Doc 2
September 20,1996 j t
, B. The TMI EAL scheme did not address NUMARC Example EALs AUI.2 and !
L AU1.3 or AA1.2 and AA.3, even though the TMI has an installed perimeter :
l monitoring system. Please providejusti6 cation for not including EALs based on l efDuent sample analysis results and perimeter radiation monitor readings or add such EALs. This comment also applies to TMI's EAL A1.1.
I RESPONSE: !
Much like monitor readings, pre-established sample results rely on meteorology and flow !
l rate assumptions that can result on non-conservative decisions. Sample results above the ' !
l values listed in the RMS setpoint procedure are input into the TMI dose assessment model :
where they are evaluated with real-time meteorology and efBuent flow rates to determine if I Offsite dose EALs have been met. This process is triggered by the sampling procedure l (1301-4.7 for RMA8/9, or 1301-5.9 for RMAS/15, or 6610-ADM-4250.10 for Actions l When RMS Malfunctions) and the high radiation procedure (1202-12). Our capability to !
quickly evaluate efBuent sample results with current plant and environmental conditions, !
rather than use pre-established values, provides a more accurate means of event declaration !
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which will minimize non-conservative decisions.
While TMI does have an Offsite monitoring system, it not a perimeter system. The Reuter i
Stokes monitors are located at varying distance from the site, some inside the exclusion area 1
- boundary and others up to several miles away. As a result, this EAL would not be ;
I ap'p licable for TMI.
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!. September 20,1996
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. 2. NUMARCIC A U2 includes :.canples that reference Spent FuelPoollevel.
PROBLEM !
l No EALs corresponding to Examples 1-3 were included in the TMI EAL scheme
- which was identified as a deviation from the NUMARC guidance. Thejustification given for the deviation is that such event based EALs are not consistent with TMI's ;
symptomatic approach to emergency classification. ;
l l A. The TMI EAL for this IC is based only on increasing radiation levels in the plant and ,
l does not address the " loss of water level" aspect ofNUMARC Examples AU2.1 and AU2.2. By not addressing the loss ofwater level, the TMI EAL for this IC lacks the redundancy and anticipatory. quality of the NUMARC Example EALs. Please
, provide additional information regarding this deviation from the NUMARC ,
! guidance. ,
j RESPONSE: ,
Adding a NEW Unusual Event EAL (UI.4)
Low level alarm on the Spent Fuel Pool and confirmed decreasirgg level due to Spent Fuel Poolleakage, as determined by the Shift Supervisor.
BASIS: L G Early indication of a problem with cooling the Spent Fuel and potential for increased doses to the t
plant staff.
i G Event classification is warranted as a precursor to a more serious event l
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September 20,1996
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. B. TMI EAL UI.2 is stated in terms of radiation monitor readings 500 mR/hr, and the basis states that plant area radiation monitor readings " typically range as high as 0.5 mR/hr " The EAL is followed by a parenthetical note that could either be a separate EAL statement or a modifier to the Erst statement. This EAL could be ambiguous in some circumstances, such as if a radiation monitor were observed to read 600 mR/hr but the highest reading in the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was 0.7 mR/hr. Please provide additional information or clarification regarding the intent and expected interpretation of the parenthetical statement.
RESPONSE
The EAL has been modified and the parenthetical statement has been included in the basis. The intent of the statement was to provide clarification to the 500 mR/hr I number which is accomplished by the statement being in the basis.
. UI.2 _ (In Plant)(UNUSUAL EVENT)
VALID UNEXPECTED IN-PLANT AREA RADIATION MONITOR (RM-G monitors)
READINGS OF h 500 mR/hr APPLICABILITY: All Plant Conditions BASIS:
S Normal levels are the highest reading in the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, excluding the current peak, which typically range as high as 0.5 mR/hr.
8 This value of 500 mR/hr identifies that an abnonnal condition exists (This is an approximate increase by a factor of 1000 over normal readings, background.)
9 Unexpected radiation levels of this magnitude represent a degradation in the control of radioactive material and potential degradation in the level of safety of the plant.
9 This EAL does not include the Control Room. (Refer to EALI.2 for Control Room habitability.)
S This EAL, satisfies NESP-007 Unusual Event AU2.
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1 A:\ RESP NRC. doc 5 i
September 20,1996
. 3. NUMARCIC AA.2 lists examples concerning additionalloss ofwater in the Spent Fuel Pools.
l PROBLEM The TMI EAL for this IC is based only on projected dose and does not address the
" loss ofwater level" aspect ofNUMARC IC AA2. By not addressing the loss of water level, the TMI EAL for this IC lacks the redundancy and anticipatory quality of the NUMARC Example EALs. Please provide additional information justifying TMIs departure from the NUMARC guidance with respect to redundant and anticipatory EALs.
RESPONSE
NEW Alert EAL (A1.4) 1 Decreasing level in the Spent Fuel Pool and RM-G-9 reading bl000 mR/ hour.
BASIS:
S Calculation RAF 6612-96-022 provides guidance for radiation monitor response to uncovedng of irradiated fuel.
l 8 Potential for increased doses to plant personnel.
8 Potential for doses to the public, but the doses are below the Environmental Protection Agency (EPA) Protective Action Guides (PAGs).
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l AARESP,,NRC. DOC 6
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September 20,1996 7
- 4. NUMARCExample EAL AA3.2 states: l VALID (Site) radiation monitor readings GREA TER THAN (Site) values in areas requiring i infrequad access to maintain plant safetyfunctions. (Site ) list ;
I PROBLEM A. The basis for the licensee's proposed EAL does not identify the areas covered by the j i
radiation monitors listed, nor does it describe why those areas meet the example EAL description of" requiring infrequent access to maintain plant safety functions."
Please provide additional information on the basis for selection of the 1000 mR/hr ,
criteria and identification of these particular radiation monitors in EAL A1.2 i
RESPONSE
- 1. This is a listing of the location of the monitors: ;
LOCATIONS of Radiation monitors listed in EAL A1.2 basis. !
RM-G-2 , Radio Chem Lab.
RM-G-3 Sampling Room (Primary)
RM-G-4 Hot Machine Shop Aux. Building Entrance, 305' Elevation :
RM-G-10 RM-G-11 Aux. Building near Waste Tank, 305' Elevation RM-G-12 Aux. Building near Drumming area,.305' Elevation .>
RM-G-13 Aux. Building Entrance,281' Elevation ;
RM-G-14 Aux. Building near Waste Tank,281' Elevation l RM-G-15 Aux. Building Heat Exchanger Vault, 271" Elevation
- 2. These area monitors are located in various areas of the Auxiliary Building i and the Chemistry Labs where plant personnel may have to responii to take ;
amitigating actions or collect needed data during an accident.
- 3. The basis for the 1000 mR/hr criteria is that such areas would require locked ;
- high radiation controls by Technical Specifications. Such controls would dew down personnel response to these areas. !
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B. Basis statement #7 for this EAL states "This EAL satisfies NESP-007 Alert AA.2." !
Kany of the radiation monitors listed cover the fuel pool / refueling floor area, it :
would appear that EAL A1.2 actually meets the intent NUMARC Example AA2.1. l Flease provide additional information on whether "AA.2" should read "AA.3" or if i EAL 1.2 should actually be cited in the cross reference section as meeting the intent i ofNUMARC Example AA2.1.
RESPONSE: l The reference is changed to AA.3 instead of AA.2.
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September 20,1996
PROBLEM I TMI's EAL S t.1 is based on projected integrated dose, per NUMARC Example EAL ASI.3, and does not directly make use of effluent release rate, as in NUMARC Example EALs ASI.1, ASI.2, and ASI.4 or AGl.1, AGl.2 and AGl.4, even though the TMI has an installed perimeter monitoring system. Please providejustification for not including EALs based on radiation effluent monitor readings, field survey results or perimeter radiation monitor res(ngs or add such EALs.
RESPONSE
The program in place at TMI meets the intent of the NUMARC EAL for radiation monitor I
indication because the automated dose assessment system' obtains the monitor reading every
. 15 minutes and uses real- time meteorology and effluent flow rates to determine the Off' site j dose. With such a system, there is no need to have a pre-established "value shown" )
radiation monitor reading to be used to declare an event. Such pre-established values must j be based on meteorological and flow rate assumptions that make such an event declaration l valid only in limited instances. The result is that the use of such values will result in both conservative and non-conservative decisions. It is far more accurate the have the automated dose assessment system evaluate monitor readings continuously to determine if an event should be declared. The inability to perform a dose projection within the required 1 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or 15 minute period is not a credible event. In the rare instances when the automated system is not available, local manual computer codes are available to perform the !
assessment of monitor readirigs in the required time frame.
CONTINUED ON THE NEXT PAGE! [
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s September 201996 3 i RESPONSE (CONTINUED)
Much like monitor readings, pre-established sample results rely on meteorology and Sow l rate assumptions that can result on non-conservative decisions. Sample results above the ;
values listed in the RMS setpoint procedure are input into the TMI dose assessment model !
where they are evaluated with real-time meteorology and efBuent flow rates to determine if j Offsite dose EALs have been met. This process is tdggered by the sampling procedure '
(1301-4.7 for RMA8/9, or 1301-5,9 for RMAS/15, or 6610-ADM-4250.10 for Actions
.When RMS Malfunctions) and the high radiation procedure (1202-12). Our capability to l quickly evaluate efBuent sample results with current plant and environmental conditions, l
rather than use pre-established values, provides'a more accurate means of event declaration which will minimize non-conservative decisions.
While TMI does have an Offsite monitoring system, it not a perimeter system. The Reuter Stokes monitors are located at varying distance from the site, some imide the exclusion area boundary and others up to several miles away. As a result, this EAL would not be j applicable for TMI l Additions are made to the Site Area Emergency and General Emergency I
dealing with offsite field team results. The changes are as follows:
L ADD to Sl.1 !
j OR VALID off site Field Monitoring Team results indicate an integrated dose of
- 1) d 100 mrem (Whole Body) TEDE and <1000 mrem OR l 2) h 500 mrem (Child Thyroid) CDE and <5000 mReni Add to Gl.1 OR
, VAlm off site Field Monitoring Team results indicate an integrated dose of !
- 1) h 1000 mrem (Whole Body)TEDE :
OR l 2) h 5000 mrem (Child Thyroid) CDE 1
I AnaESP NRC. Doc 9
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B NUMARC Recognition Category F Fission Product Barrier Degradation
This (Site) value correspomis to 300 pCi/cc1131 equivalent. Assessment by the NUMARC \
EAL Task Force indicates that this amount ofcoolant activity is well above that expected }
for iodine spikes andcorre. ponds to about 2% to 5% fuel clad damage. This amount of j clad damage indkates sigmpcant clad heating and thus the Fuel Clad Barrier is l consideredlost.
There is no equivalent "PotentialLoss EALfor this item.
PROBLEM ,
A. The TMI Fission Product Barrier table identifies 5000 pCi/cc as the " loss" criteria l for fuel clad. The basis states that this coolant activity level indicates ". 10% of the !
core has experienced cladding damage ...". It is not stated whether these are 1131 equivalent values. Please provide additional information regarding the reasons for selecting a clad damage criterion 2-5 times higher than suggested by the NUMARC guidance.
RESPONSE: I Modified to Alert Alarm on RM-G-22 and RM-G-23 _,,,
BASIS:
O 2500 pCi/cc total RCS activity corresponds to approximately 300 pCi/cc DEI per the EDCM. This is approximately 5% fuel clad damage.
i B. The TMI Fission Product Barrier table identifies 360 Ci/cc (corresponding to about 1 % clad damage) as the " potential loss" c.iterion for fuel clad whereas the NUMARC guidance specifies no " potential loss" criterion. Please provide additional informationjustifying the addition of this site-specific EAL.
RESPONSE: ;
The condition has been removed from the evaluation scheme.
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MRESP NRC. DOC }Q j
Sept aber20,1996
, 2. NUMARC Example FAL FC4 (Reactor Vessel Water Level) basis states ;
There is no " Loss" FAL corre.sponding to this item because it is better covered by the other FuelCladBarrier " Loss"E4Ls l
The (Site) valuefor the "PotentialLoss"FAL corre.sponds to the top of'the activefuel. ;
For sites using CSFSTs, the "PotentialLoss"FAL is depned by the Core Cooling -
ORANGEpath. The (Site) value in this FAL should be consistent with the CSFSTvalue.
PROBLEM !
The TMI Fission Product Barrier table does not include a reactor vessel water level
" potential loss" criterion for the fuel clad barrier. The basis document does not identify this ,
as a deviation or address vessel level and the means to monitor it. Please provide additional !
information regarding this deviation from the NUMARC guidance. l l
RESPONSE: I At TMI the potential loss of the Fuel Clad Barrier is determined by calculating a superheat value using the incore thermocouples and RCS pressure. If this value is greater than 25*F, then we would declare a potential loss of the Fuel Clad Barrier. The only way for the incore thermocouples to indicate superheat is for the top of the core to be uncovered. Thus this is an indirect measurement ofReactor Coolant Inventory. This method is better than using the Reactor Coolant Inventory Trending system which is not qualified and only trends level to the bottom of the hot leg piping. The TMI FSAR states "The Control Room operators take no action during or following any accident based on RCITS [ Reactor Coolant Inventory Trending System] indication. The RCITS system improves the ability of the operators to diagnose the approach ofinadequate core cooling and to assess the adequacy of responses taken to restore core cooling, i.e. additional confirmatory information." This method of determining the potential loss of the Fuel Clad Barrier meets j the guidance provided in the NUMARC document and is not a deviation from this l guidance. Examples are given in the document which provide other methods of I accomplishing the same determination.
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fuelwith claddamage.
There is no "PotentialLoss"EAL associatedwith this item.
PROBLEM A. The TMI Fission Product Barrier Table identiSes "RM-G 22 or RM-G-23 > HIGH ALARM" as the Fuel Clad " Loss" criterion. The basis statement indicates that this alarm setpoint is based on a LOCA with about 10% clad damage (5000 Ci/cc). Please provide additional information regarding the validity of radiation monitor readings as indication of fuel clad loss under other than LOCA conditions and the reasons for selecting a clad damage criteria 2-5 times higher than suggested by the NUMARC guidance.
RESPONSE
Revised RM-G-22 and RM-G-23 to be > 1 R/ hour BASIS:
- Readings on RM-G-22 and RM-G-23 for an activity of about 2500 pCi/cc [DEIl31 about 300 Ci/cc) result in readings ofless than 1 R/ hour. IR/ hour is the mihimum sensitivity for the high range monitors.
9 Do not have an instrument that can provide reliable information at the stated level. ,
- The 1 R/ hour is based on about 6 % fuel clad damage about 3000 Ci/cc total activity and about l 390 Ci/cc for Dell 31. j B. The TMI Fission Product Barrier table identifies "RM-G-22 or RM-G-23 > ALERT ALARM" (for which the setpoint is 50% of the HIGH ALARM setpoint) as the Fuel Clad " Potential Loss" criterion whereas the NUMARC guidance specifies no
" potential loss" criterion. Please provide additional ir. formation justifying the ,
addition of this site-specific EAL.
RESPONSE
The cor.dition has been removed from the evaluation scheme.
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- t. 4. NUMARCExampleEALsFC7andRC6(EmergencyDirectorJudgment) areprovidedfor redundancy.
PROBLEM l The TMI Fission Product Barrier table does not include an " Emergency Director i
Judgment" criterion for the loss ofFuel Clad and RCS barrier. A certain degree of redundancy, a desirable quality in an EAL set, is clearly intended by the NUMARC guidance. It is not clear why the fission product and RCS barrier " Judgment" EALs are considered particularly redundant and unacceptable for TMI. Please provide additional l information regarding these deviations from the NUM/AC guidance.
l RESPONSE:
l We wish to have the Emergency Director (ED) apply appropriate judgment in ALL situations. Therefore, the Emergency Direction procedure requires that the ED always evaluate the situation, apply appropriatejudgment, and escalate the EAL, if appropriate.
l Since this will be done in ALL cases, there is no need to add a judgment section in certain EALs. However, there were two (2) additional bullets added to the JUDGMENT EALs to insure the concerns the NUMARC/NESP-007 raised in the Fission Product Barrier EAL concerning the use of appropriate judgment are addressed:
- 1) The inability to monitor the parameters to make a proper EAL classification l 2) EAL criteria is not presently met, but there are no foreseen possible actions that
- would prevent meeting or exceeding the criteria.
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PROBLEM The TMI basis states: "A leak of this magnitude is hwnd that of a single make up pump and feed through the normal make up line."
A. Elsewhere in the TMI basis,120 gpm is identified as the capacity of a single make up pump.
Please provide additional information regarding this deviation from the NUMARC guidance and inconsistency between the EAL and the basis statements.
RESPONSE
RCS leakane / Total OTSG leakage > 120 enm This value exceeds the capacity of a single make up pump feeding the Reactor Coolant System through the normal make up valve (MU-V-17). This is consistent with the NUMARC guidance.
RCS leakage / Total OTSG leakage > 350.gsn
, A leak of this magnitude exceeds the capacity of a single make up pump feeding the Reactor Coolant System (RCS) through the normal make up valve (MU-V-17) and the additional capacity obtained by going through the make up line bypass valve (MU-V-217, an abnormal lineup). In these instances the leakage from the RCS is greater than available inventory control and would lead to a loss of subcooling.
This leak size anticipates the loss of subcooling.
Please note, at TMI (a B&W type plant) the" charging pump" is also the HPI pump and therefore has greater capacity than a typical " charging pump.". .
B. Loss of subcooling is not addressed in the TMI EAL Please provide additional information regarding this deviation from the NUMARC guidance l 1
RESPONSE- I The loss of subcooling as addressed by the NUMARC guidance is based on the !
CORE COOLING CSF for a Westinghouse plant. The ORANGE path for j challenge to the CORE COOLING is > 700* F on the Incore thermocouples. This approach does not consider the impact of RCS pressure. At 2500 psig the saturation temperature is about 670*; therefore with the Incore temperature at 700 there is at least 30 of Super Heat. However, wham the RCS is at 50 psig the amount of Super Heat is greatly increase and is at 250* The 250 Superheat condition is approaching the point where clad damage can occur. The approach taken at TMI is always 25* Super Heat and is always evaluating a Potential Loss.
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. 6. NUMARC Example EAL RC3 basis states (inpart): i The " Loss" EAL addresses ruptured SG(s) with an unisolable Secondary Line Break i corresponding to then loss of 2 of 3pssion product barriers (RCS Barrier and l l Containment Barrier - this EAL will absqvs result in a Containment Barrier " Loss" i l EAL 4). l l
PROBLEM:
The TMI Fission Product Barrier table identi6es "OTSG leak > 350 gpm as the Steam Generator Tube Rupture criterion for the loss of the RCS barrier. There is no mention of ,
an unisolable secondary line break or the release ofRCS activity to the environment. Please !
provide additional information regarding this deviation from the NUMARC guidance. [
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RESPONSE: {
Change Containment loss (RB) to OTSG leak h 1 gpm (Tech Spec) and steam to l
ATMOSPHERE :
BASIS: !
G The leak and path to the environment have the potential to impact the public with small doses. [
9 This is anticipatory because dose assessment will validate the event classification l 9 Paths are Steam Line Break , Main Steam Relief stuck open or steaming via the Atmosphene i Dump Valves.
9 The direct to atmosphere means that the condenser function has been lost. l Also change the UE for standard leak to be 10 gpm OTSG to the condenser.
i l 7. NUMARC Example EAL RC4 hasis states (inpart): '
The (Site) reading is a value which indicates the release ofreactor coolant to the containment. The reading should be calculatedassuming the instantaneous release and i dispersal of the reactor coolant noble gas and iodine inventory associated with normal :
operating concentrations (i.e., within T/S) into the containment atmosphere....
There is no "PotentialLoss"EAL associatedwith this item. l i
PROBLEM j A. The TMI Fission Product Barrier table identifies "RM-G-22 or RM-G-23 > ALERT i ALARM" as the containment radiation criterion for loss of the RCS barrier. The TMI basis states that this alarm setpoint is 50% of the HIGH ALARM setpoint, which is based on a LOCA with 10% fuel damage instead of the normal operating actisity concentration specified in the NUMARC basis. Please provide additional information regarding this deviation from the NUMARC guidance.
RESPONSE
Revise: RM-G-22 or RM-G-23 reading h 22 R/ hour.
BASIS:
G Calculation RAF 6612-96-023 documents RM-G-22/23 readings under LOCA conditions
! with Tech Spec RCS activity.
l 9 This should be considered a loss ofRCS.
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B. The TMI Fission Product Barrier table identifies "RM-G 22 or RM-G-23 > 13 R/hr" as the
~ i containment radiation criterion for potential loss of the RCS barrier whereas the NUMARC '
guidance specifies no "potentialloss" criterion. The TMI basis is confusing and does not ;
! substantiate the choice of 13 R/hr as the criterion. Please provide additional information i
regarding this deviation from the NUMARC guidance and the choice of the containment i radiation criterion.
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RESPONSE- - !
l No potentialloss should be specified i
! Deleted item. !
L !
- 8. NUMARC Etainple EAL PC2 (Containment Pressure) includes an' " unexplained loss of l pressure " criterion. The basis states (Inpart): }
Rapid unexplainedloss ofpressure (i.e., not attributable to containment . spray or \
condensation ejfects)following an initialpressure increase indicates a itss ofcontainment l integrity.
PROBLEM A. The TMI Fission Product Barrier table does not include an " unexplained loss of pressure" i l criterion. Please provide additional information regarding this deviation from the NUMARC guidance. i l RESPONSE: !
Rapid unexplained loss of RB pressure, following an initial pressure increase above 4 psig.
BASIS:
9 The rapid decrease in pressure is not attributable to containment spray or condensation effects.
9 The pressure drop is to normal or near normal RB pressure (i.e. Less than 2 psig, typically 0 psig).
B. The TMI Fission Product Barrier table specifies "RB Press. > 100 psig" as a criterion for !
loss of the containment barrier, even though the basis states "... calculation showed that j cracking could be expected at 120 psig" Please provide additional m ' formation regardmg !
selection of this pressure as a criterion for " containment loss".
l i
I RESPONSE: '
While the calculations show that 120 psig is acceptable based on the strain in the building before the RB would be breached, this pressures can not be read in the Control Room.
The 100 psig value was chosen because it is the maximum value that be read on the Control Room console.
, 9. (Ihis number was not in the document.)
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' September 20,1996
Containmentpressure greater than containment depressurization system sepoint with less than onefull train ofdepressurization equipment operating.
Additionally the basis states (in part):
The secondpotentialloss EAL represents apotentiallass ofcontaimnent in that the containment heat removal /depressurization system ... are either lost orperforming in a degraded manner.
PROBLEM The TMI Fission Product Barrier Table does not include a " degraded heat removal /depressurization system" criterion. Please provide additionalinfonnation regarding
. this deviation from the NUMARC guidance. -
RESPONSE
ADDED CONTAINMENT JEOPARDY condition The Reactor Building Pressure is 2: 30 psig and the Reactor Building Emergency Cooling is less than the minimum assumed in the FSAR.
BASIS
- 1. This condition ofless than minimum is exceeded if the followmg exist:
SPRAY COOLERS 1 0, 0 1
- 2. This is consistent with the Level 2 Proability Risk Assessment (PRA) assumptions of no Coolers and no Spray where the pressure could increase to 4 times the value with a combustion or similar event to cause a pressure spike. Four times the setpoint (30 psig) equals the failure value from the PRA of120 psig. Therefore, above 30 psig, with no cooling, the RB is in jeopardy.
8 N8P NRC. DOC
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September 20,1996 i
- 11. NUMARC Example EAL PC4 (SG Secondary Side Release With Primary-to-Secondary l Leakage) includes thefollowing criterionfor containment loss: 1
- Release ofsecondary side to atmosphere withprimary to secondary leakage GREA TER l THANtech spec allowable.' l De basisstates
- l Dis EAL ad& esses SG tube rsptures. Secondary side releases to atmosphere include i thosefrom the condenser air ejector, atmosphen*c dump valves, andmain steam safety ;
valves. For smaller breaks, not exceeding the normal charging cqpacity thresholdin RCS l Barrier "PotentialLoss" EAL 2 (RCSLeak Rate) or EAL 3 (SG Tube Rupture), this EAL l results in an UnusualEvent. For large breaks, RCSBarrier " Loss or "PotentialLoss" ;
EAL 2 wouldresult in an Alert. For SG tube ruptures which may involve multiple steam !
, generators or unisolable secondary line breaks, this EAL would result in a Site Area l
. Emergency. Fwalation to GeneralEmergency would be based on "PotentialLoss" of the FuelCladBarrier. !
PROBLEM !
A. The TMI EAL addresses primary-secondary leak rates exceeding the capacity of a single :
' makeup pump, not just leakage in excess of tech spec limits, as specified in the NUMARC l example. Please provide additional information regarding this deviation from the '
NUMARC guidance. ;
RESPONSE
Change Containment loss (RB) to OTSG leak h I gpm (Tech Spec) and steam to ATMOSPHERE
! BASIS:
9 . The leak and path to the environment have the potential to impact the public with small doses.
9 This is anticipatory because dose assessment will validate the event classification j 9 Paths are Steam Line Break , Main Steam Relief stuck open or steaming via the Atmospheric Dump Valves.
9 The direct to atmosphere means that the condenser function has been lost.
Also change the UE for standard leak to be 10 gpm OTSG to the condenser.
I f 4 l
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. September 20,1996 .
, ' B. Because TMI has selected the same OTSG leakage critedon (>120 gpm) for " containment '
loss" and for "RCA potential loss", OTSG leakage of >120 gpm will net 7 point, requiting classi6 cation as Site Area Emergency. This is contrary to the above-cited NUMARC basis, which suggests that Alert is the appropriate classification unless the tube ruptures involve i "muhiple steam generators or unisolable secondary line breaks." Please provide additional i information regarding this deviation from the NUMARC guidance.
RESPONSE: l l Based on further review the OTSG leak to atmosphere has reconsidered and added to be a l l loss of Containment if the leak is El gpm. The standard OTSG leak of 10 gpm has been I
clarified to be when the condenser is available. The RCS barrier criteria remains the same at l l 120 gpm for JEOPARDY and 350 gpm for LOSS.. j i- This meets the NUMARC criteria, the examples stated in the Request for information are :
I not achievable. !
- 12. NUMARC Example EAL PC5 (Sigmfcant Radioactive Inventory in Containment) includes thefollowing criterionforpotential containment loss
- l
- Containment rad monitor reading GREA TER THAN (Site) R/hr.
l The NUMARC basis states (inpart): ,
The (Site) reading is a value which indicates sigmpcantfuel damage well in excess of the EALs associatedwith both loss ofFuel Clad andRCS barriers. Regardless ofwhether containment is challenged, this amount ofactivity in containment, ifreleased, could have such severe consequences that it isprudent to treat this as apotentialloss ofcontainment, such that a GeneralEmergency declaration is warranted PROBLEM The TMI Fission Product Barrier table does not include a "high comainment radiation" criterion, and thus, would not meet the classi6 cation goal stated in the NUMARC basis.
Please provide additional information regarding this deviation from the NUMARC guidance.
RESPONSE
Newjeopardy EAL RM-G-22 or RM-G- 23 reading h 12000 R/hr BASIS:
9 Based on calculation RAF 9140-89-002, RM-G-22 or RM-G-23 readings would correspond to a LOCA with 20% release of fuel gap activity.
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September 20,1996 j
- , 13. NUMARC Example EAL PC6 (Core Exit Thermocouple Readings) include criterionfor l containmentpotentialloss. ,
PROBLEM -
The TMI Fission Product Barrier table includes an incore temperature Criterion for I
(
potential loss of containment of"Tclad > 1800 F". The proposed TMI EAL is significantly l greater than the NUMARC - -- A and no temperature / vessel level criterion is stated.
Please provide additional information regarding the deviation from the NUMARC guidance ,
RESPONSE: .
l At TMI the temperature is based on projected CLAD temperature and not just indica:ed .
Thermocouple indication. The projected condition is a function of thennocouple indications and system pressure. This is a good correlation to expected degradation of l tb fuel. Additionally the 1800* F limit for clad is more conservative than the 1200* F l
thermocouple temperature. ;
l At TMI the potential loss of the Fuel Clad Barrier is determined by calculating a superheat value i I
using the incore thermocouples and RCS pressure. If this value is greater than 25*F, then we would declare a potential loss of the Fuel Clad Barrier. The only way for the incore thermocouples to indicate superheat is for the top of the core to be uncovered. Thus this is an indirect -
measuremint of Reactor Coolant Inventory. This method is better than using the Reactor Coolant Inventory Trending system which is not quahfied and only trends level to the bottom of the hot leg piping. The TMI FSAR states "The Control Room operators take no action during or following any accident based on RCITS [ Reactor Coolant Inventory Trending System] indication. The RCITS system improves the ability of the operators to diagnose the approach ofinadequate core
- cooling and to assess the adequacy of responses taken to restore core cooling, i.e. additional co'nfirmatory infonnation." This method of detennining the potential loss of the Fuel Clad Barrier meets the guidance provided in the NUMARC document and is not a deviation from this guidance.
Examples are given in the document which pmvide other methods of accomplishing the same determination. _
r Y
i AnRr.SP,,NRC. doc 20 i
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. . September 20,1996 -
- 14. NUMARC Example PC8 (Emergency Director Judgment) is stated.specipcallyfor barriers. & 7MIFission Product Barrier table does not include an " Emergency .
DirectorJudgment" criterion. . _
l
& "Justipcation Reference Document" states. ,
i The Juggment item listed under Fission Product Barriersfor each barrier is not included in the IMIEAL because it is consideredredundant. Section 7 cowrs the' Judgment EALs. l i
PROBLEM :
A certain degree of redundancy, a desirable quahty in an EAL set, is clearly intended by l the NUMARC guidance. It is not clear why the fission product barrier " judgment" EALs are considered particularly redundant and unacceptable for TMI.' Please provide additional ;
information regarding this deviation form the NUMARC guidance.- !
RESPONSE- 1 We wish to have the Emergency Director (ED) apply appropriatejudgment in ALL ' j situations. Therefore, the Emergency Direction procedure requires that the ED always i evaluate the situation, apply appropriate judgment, and escalate the EAL, if appropriate. !
Since this will be done in ALL cases, there is no need to add ajudgment section in cenain i EALs. However, there were two (2) additional bullets added to the JUDGMENT EALs to l insure the concerns the NUMARC/NESP-007 raised in the. Fission Product Barrier EAL l concerning the use of appropriatejudgment are addressed: l
- 1) The inability to monitor the parameters to make a proper EAL classification .
- 2) EAL criteria is not presently met, but there are no foreseen possible actions that would prevent meeting or exceeding the criteria.
C. NUMARC Recognition Category Hazards and Other Conditions Affecting Plant Safety
- 1. NUMARC Example EAL HAL3 recommends listing structures that are damaged PROBLEM The proposed TMI EALs do not contain a counterpart to this NUMARC example even though the " Justification Reference Document" suggests that it is addressed. Please provide additional information regarding this deviation from the NUMARC guidance.
RESPONSE: I Added a listing of buildings to be considered in appropriate EALS. )
A4.2 (High Winds), A4.3 (Tornado) and A4.4 (Earthquake) !
(Reactor Building, Intake Building, Intermediate Building, Control Tower, Aux & Fuel !
Handling Building and Diesel Generator Building) l l
i MREsPJRC. DOC 21
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September 20,1996 l l
. 2. NUMARC Example EAL HA2.1 provides criterionforpres and TM1 EAL A5.1 is stated to j meet the intent. t PROBLEM i
- The proposed TMI EAL does not address explosions as a source ofdamage, nor does it ,
specify the areas containing functions and systems for safe shutdown of the plant, as stated ;
in the NUMARC basis. Please provide additional information regarding the deviation from i the NUMARC guidance. l Y
RESPONSE: l Added a list of buildings to evaluate in the BASIS for Fire and Explosion i (Reactor Building, Intake Building, Intermediate Building, Control Tower, Aux & Fuel '
Handling Building and Diesel Generator Building)
Explosion is an EAL but was not referenced in the submittal. The EAL is AS A !
D. NUMARC Recognition Category S System Malfunction i l, NUMARCICSU7 states: l Unplanned loss ofrequired DCpower During Cold Shutdown or Refueling Shutdownfor l
( Greater than 15 minutes. \
PROBLEM The proposed TMI EALs do not address IC SU7 directly. The " Justification Reference )
Document" states that the TMI EALs will rely on "... impact to the public (Integrated Dose) to capture the Unusual Event condition." The licensee is effectively declaring that no Unusual Event declaration will ever be made for this Initiating Condition, because exceeding any Unusual Event projected dose EAL implies that conditions are degraded to the point where one or more other Alert (or higher) EALs have been exceeded. Please provide additional information regarding this deviation from the NUMARC guidance.
l
RESPONSE
New EAL at UE for loss ofDC at Cold Shutdown (CSD) and Refueling Shutdown (RSD) l Modify exining Site Area Emergency EAL to be applicable for everything except CSD and RSD.
The ALERT EAL is no longer valid and is deleted.
i ;
)
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September 20,1996
- 2. NUMARCICSA3 states:
Inability to Maintain Plant in Cold Shutdown
, PROBLEM .
l The TMI " Justification Reference Document" indicates that the rationale for this devidon is provided in " Deviation / Justification Appendix 1". However, no discussion of this NUMARC IC was found in the Appendix. Please provide additionalinformation regarding this deviation from the NUMARC guidance.
i
RESPONSE
Reference in the Justification document (Page 32) was to APPENDIX 4.
REVISED EAL:
! ALERT l Loss of ALL means of Decay Heat' Removal (Core Heat Removal as allowed by Tech Specs) and temperature is b 212"F with predicted coolant level to be below the top of the fuel in less than one l hour. >
BASIS: l 9 The 212 F, at atmospheric pressure, coridition has been reviewed and is an approved state to allow l actions to prevent damage to the core S The time to uncover the fuel is based on level before the loss of Decay Heat Removal and the time since reactor shutdown. The loss of Decay Heat Removal Emergency Procedure (1202-35) contains the information to predict core uncovery.
SITE AREA EMERGENCY Loss of ALL means of Decay Heat Removal (Core Heat Removal as allowed by Tech Specs) and core exit temperature indications of h 237' F.
BASIS:
S A core exit temperature of 237 F, at atmospheric pressure, is superheated by 25 and is therefore theindication of fuel uncovery.
i l
l I
i A: RESP _NRCEOC 23
September 20,1996
[SG1] Prolongedloss ofAll Offsitepower andprolongedloss ofACpower.
and
[SG2] Failure of the Reactor Protection System to complete an Automatic Scram arul Manual Scram was NOTsuccessful and there is indication ofextreme challenge to the ability to coolthe core.
The proposed TMI EALs do not address these ICs.
PROBLEM The NUMARC Example EALs are more " anticipatory" than the fission product barrier EALs. It is not clear why these EALs are considered particularly redundant for TMI. No speci6cjustificationis provided for the omissions. Please provide additional" m formation regarding these deviation from the NUMARC guidance.
RESPONSE
NEW EAL
[SGI } An EAL is added to the Electrical Section:
Prolonged Station Blackout exists as indicated by:
- 1. LOOP h 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> AND ,,,
- 2. No emergency 4 KV Bus (ID or IE) energized for b 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> AND
- 3. NO on-site power source available.
BASIS:
- TMIis a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> coping plant.
O Beyond the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> the potential exists to breach the RCS and CLAD. The CONTAINMENT is stillintact. This is an anticipatory declaration.
NEW EAL
[SG2]
Failure ofthe Reactor Protection System (RPS trip string) to; automatically INITIATE AND COMPLETE a reactor trip when any RPS trip set point has been exceeded AND The manual reactor trip from the control room was NOT successful AND A. All Make up to the RCS has been lost with Tclad > 1800'.
OR B. All means of RCS heat removal (Main and Emergency Feedwater) have been lost for h 30 minutes.
BASIS:
l 9 This meets the anticipatory criteria for a General Emergency because of the loss of coolant and l failure of the CLAD.
> # No core damage is expected under these conditions unless all RCS heat removal is lost for at least 30 minutes f
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