ML20149G776
| ML20149G776 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 10/27/1994 |
| From: | Mckee P Office of Nuclear Reactor Regulation |
| To: | Opeka J CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| TAC-M89809, TAC-M89810, TAC-M89811, TAC-M89812, NUDOCS 9411070278 | |
| Download: ML20149G776 (81) | |
Text
....,,
October 27, 1994 Mr. John F. Opeka Executive Vice President, Nuclear Connecticut Yankee Atomic Power Company Northeast Nuclear Energy Company Post Office Box 270 Hartford, CT 06141-0270
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION CONCERNING THE EMERGENCY ACTION LEVEL TECHNICAL BASIS DOCUMENT, HADDAM NECK PLANT AND MILLSTONE NUCLEAR POWER STATION, UNIT NOS. 1, 2, AND 3 (TAC NOS. M89809, M89810, M89811, M89812)
Dear Mr. Opeka:
The enclosed Request for Additional Information identifies information that we need to continue review of your submittal dated June 27, 1994, regarding the subject matter.
Please provide a response within 60 days from receipt of this letter.
This request affects one respondent and, therefore, is not subject to Office of Management and Budget review under P.L.96-511.
Sincerely, Original signed by:
Phillip F. McKee, Director Project Directorate I-4 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos.
50-213, 50-245, 50-336, 50-423
Enclosure:
Request for Additional Information cc w/ encl:
See next page DISTRIBUTION:
-Docket File PUBLIC PDI-4 Plant SVarga JZwolinski PMcKee m$fli';J L d ip mroTNYPR(j{pV JAndersen GVissing I
N'9u5 h
VRooney AWang
$"E"'i' 040029 ACRS ( M) q 9411070278 941027 LNicholson, RGI PDR ADOCK 05000213
'y(i
,_ g DOCUMENT NAME:
pr' PDR t
0FFICE LA:PDI-4 l
PM:PDI-4 l,
PM:PDI-4 l ],
PM:PD M l
PM:PDI-4 /J/
NAME SNorris A# AWangfot /,
JAndersen:bf/t GVisftfig VRooney'O'1 '
DATE 10/2L194o 10/LA/94 10/tC/94 lb/2//94 10/W/94 0FFICE D:Pd}6('l l
l l
l l
NAME PMdkse' DATE 10'/] Y94 10/ /94 10/ /94 10/ /94 10/ /94 0FFICIAL RECORD COPY
t t
4 i
1 1
l l
i i
h i
t k
a i
e p
?
. 1
- 3, i s
a Mr. John F. Opeka Haddam Neck Plant & Millstone Power Northeast Nuclear Energy Company Station, Unit Nos. 1, 2 & 3 cc:
Ms. L. M. Cuoco, Senior Nuclear Counsel R. M. Kacich, Director Northeast Utilities Service Nuclear Planning, Licensing & Budgeting Company Northeast Utilities Service Company Post Office Box 270 Post Office Box 128 Hartford, Connecticut 06141-0270 Waterford, Connecticut 06385 Resident Inspector J. J. LaPlatney Haddam Neck Plant Haddam Neck Unit Director c/o U.S. Nuclear Regulatory Commission Connecticut Yankee Atomic Power Company 361 Injun Hollow Road 362 Injun Hollow Road East Hampton, Connecticut 06424-3099 East Hampton, Connecticut 06424-3099 Kevin T. A. McCarthy, Director Regional Administrator Monitoring and Radiation Division Region I Department of Environmental Protection U.S. Nuclear Regulatory Commission 79 Elm Street 475 Allendale Road Hartford, Connecticut 06106-5127 King of Prussia, Pennsylvania 19406 Allan Johanson, Assistant Director First Selectmen Office of Policy and Management Town of Waterford Policy Development and Planning Division Hall of Records i
80 Washington Street 200 Boston Post Road Hartford, Connecticut 06106 Waterford, Connecticut 06385 S. E. Scace, Vice President P. D. Swetland, Resident Inspector Nuclear Operations Services Millstone Nuclear Power Station Northeast Utilities Service Company c/o U.S. Nuclear Regulatory Commission Post Office Box 128 Post Office Box 513 l
Waterford, Connecticut 06385 Niantic, Connecticut 06357 F. R. Dacimo, Nuclear Unit Director M. R. Scully, Executive Director Millstone Unit No. 3 Connecticut Municipal Electric Northeast Nuclear Energy Company Energy Cooperative Post Office Box 128 30 Stott Avenue Waterford, Connecticut 06385 Norwich, Connecticut 06360 Burlington Electric Department David W. Graham c/o Robert E. Fletcher, Esq.
Fuel Supply Planning Manager 271 South Union Street Massachusetts Municipal Wholesale Burlington, Vermont 05402 Electric Company Post Office Box 426 Ludicw, Massachusetts 01056
)
j Mr. John F. 0peka Haddam Neck Plant & Millstone Nuclear Northeast Nuclear Energy Company Power Station, Unit Nos. 1, 2 & 3 l
CC:
H. F. Haynes, Nuclear Unit Director G. H. Bouchard, Nuclear Unit Director Millstone Unit No. 1 Millstone Unit No. 2 Northeast Nuclear Energy Company Northeast Nuclear Energy Company Post Office Box 128 Post Office Box 128 Waterford, Connecticut 06385 Waterford, Connecticut 06385 Charles Brinkman, Manager Board of Selectmen Washington Nuclear Operations Town Office Building ABB Combustion Engineering Haddam, Connecticut 06438 Nuclear Power 12300 Twinbrook Pkwy., Suite 330 Donald B. Miller, Jr.
Rockville, Maryland 20852 Senior Vice President Millstone Station Nicholas S. Reynolds Northeast Nuclear Energy Company Winston & Strawn Post Office Box'128 1400 L Street, NW Waterford, Connecticut 06385 Washington, DC 20005-3502
=
J. M. Solymossy, Director Nuclear Quality and Assessment Services Northeast Utilities Service Company Post Office Box 128 Waterford, Connecticut 06385
l RE0 VEST FOR ADDITIONAL INFORMATION CONCERNING CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT DOCKET NO. 50-213 The NRC has completed its initial review of the proposed emergency action levels (EALs) in the June 1994 Haddam Neck Plant NUMARC EAL submittal. The submittal included Emergency Plan Implementing Procedure (EPIP) 1.5-1, Emeraency Assessment Usina EAL Tables (Revision 26, Jan. 1, 1994), the Connecticut Yankee Emeraency Action Level (EAL) Technical Basis Document (TBD)
(NRC Submittal Version, June 1994), and miscellaneous other supporting documentation. The proposed EALs were reviewed against the guidance in NUMARC/NESP-007, " Methodology for Development of Emergency Action Levels,"
Revision 2.
NUMARC/NESP-007 has been endorsed by the NRC in Regulatory Guide 1.101, " Emergency Planning and Preparedness for Nuclear Power Reactors,"
Revision 3, 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.
Since the staff has previously endorsed 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.
General Comment Several EAls include the criterion for required entry into emergency operating procedures (EOPs) prior to classification. Required is defined by the TBD to mean "that the E0P aust be entered in order to mitigate the accident and that the entry into the E0P was not inadvertent or a precaution." However, if the OSS/DSE0 makes the judgement to enter an E0P, that judgement is based upon an assessment of plant conditions. Thus, if the OSS/DSE0 believes conditions warrant entry into an E0P that is referenced by an EAL, declaration of the emergency class should be made regardless of whether or not specific entry conditions are met.
Provide additional justification for this criterion.
NUMARC Recoanition Cateaory A - Abnormal Rad levels /Radioloaical Effluent 1.
The NUMARC criteria for Initiating Condition (IC) AU1 and EAL AU1-1 state:
AU1 Any Unplanned Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds Two Times the Radiological Technical Specifications for 60 Minutes or Longer.
. 1.
A valid reading on one or more of the following monitors that exceeds the "value shown" (site-specific monitors) indicates that the release may have exceeded the above criterion and indicates the need to assess the release with (site-specific procedure):
(site-specific list)
Note:
If the monitor reading (s) is sustained for 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.
The Haddam Neck equivalent EAL states:
0U1 UNPLANNED RELEASE Unplanned, Unmonitored, or Uncontrolled Offsite Release Within Delta-Two Posture Code limits As Determined from EPIP 1.5-1, Emergency Assessment No valid monitor reading (s) were listed as EAL thresholds in the Haddam Neck tables equivalent to the NUMARC IC. The provisions of NUMARC EAL AU1-1 were not included in the Haddam Neck scheme and their omission was not adequately justified in the Technical Basis Document.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
2.
Haddam Neck EAL RU1-2 states:
Unexpected Area Rad Monitor Reading Offscale High OR > 1000 Times Normal Reading for > 5 Minutes The TBD explains that unexpected is utilized to discriminate against expected increases due to controlled evolutions. Thus, the criterion for readings existing for > 5 minutes is redundant and inconsistent with the NUMARC guidance. The time limit should be deleted or justification for its inclusion provided.
3.
The NUMARC criterion for Initiating Condition (IC) AA1 states:
Any Unplanned Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds 200 Times Radiological Technical Specifications for 15 Minutes or longer.
The NUMARC Basis information goes on to state:
This event escalates from the Unusual Event by escalating the magnitude of the release by a factor of 100. Prorating the 500 mR/yr criterion..., the associated site boundary dose rate would be 10 mR/yr.
The equivalent Haddam Neck IC and EAL 0Al-5 state:
. CA1 0FFSITE DOSE 5.
Rad Assessment Determines Integrated Dose Offsite 2 0.005 Rem TEDE OR k 0.025 Rem CDE Thyroid.
A.
Both the Haddam Neck Initiating Condition and the EAL pertained to off-site consequences, whereas for the Alert classification, the NUMARC criteria refer to site consequences out to the site boundary. This change in affected areas.was not justified in the Technical Basis Document.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
B.
The TBD, which states that the preferred method for evaluating this IC is by use of radiological dose assessment, is inaccurate. The intent of the lower emergency class ICs for radiological effluents (Unusual Event and Alert) is to take actions based upon a loss of control of radioactive material.
Therefore, classification need only be based upon exceeding the associated EAL threshold (s) for greater than 15 minutes, not necessarily a dose assessment of the release. The NUMARC guidance specifically calls for a dose assessment using actual meteorology to determine the consequences of that release and whether or not adverse conditions would escalate the classification or posture code.
The TBD should be revised to reflect the intent of the NUMARC IC.
4.
The NUMARC criteria for AA2-1, 2, 3, and 4 state:
1.
A (site-specific set point) alarm on one or more of the following radiation monitors: (site-specific monitors)
Refuel Floor Area Radiation Monitor Fuel Handling Building Ventilation Monitor Fuel Bridge Area Radiation Monitor 2.
Report of visual observation of irradiated fuel uncovered.
3.
Water Level less than (site-specific) feet for the Reactor Refueling Cavity that will result in irradiated fuel uncovering.
4.
Water level less than (site-specific) feet for the Spent Fuel Pool and Fuel Transfer Canal that will result in irradiated fuel uncovering.
The NUMARC basis guidance goes on to state: Each site should also define its EALs by the specific area where irradiated fuel is located such as Reactor Cavity, Reactor Vessel, or Spent Fuel Pool.
The Haddam Neck In-Plant 9adiation category equivalent Initiating Condition i
and EALs state
.. RA1 SPENT FUEL ASSEMBLY DAMAGE 1.
Spent Fuel is Exposed from Open Vessel, Cavity or SF Pool AND Spent Fuel Has Decayed 2 30 Days 2.
Report of Fuel Handling Accident Causing Visible Damage to Any Spent Fuel Assembly 3.
Fuel Building or Containment Area Rad Monitors Indicate Spent Fuel Damage or Uncovery The Haddam Neck EALs lacked the specificity in regard to which radiation monitors and specific setpoints, and location and water level form the thresholds suggested by the NUMARC guidance. The Technica1 Basis Document was silent on the omitted criteria.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
5.
The NUMARC criteria for AA-3 state:
1.
Valid (site-specific) radiation monitor readings GREATER THAN 15 mR/hr in areas requi~ing continuous occupancy to maintain plant safety functions:
(Site-specific) list 2.
Valid (site-specific) radiation monitor readings GREATER THAN < site-specific > values in areas requiring infrequent access to maintain plant safety functions:
(Site-specific) list The Haddam Neck equivalent Initiating Condition and EAL state:
RA2 PLANT RADIATION Dose Rates Prevent Occupancy Or Access to Areas Needed for Safe Shutdown The Haddam Neck EAL scheme included a table of AREAS OF CONCERN FOR SAFE SHUTDOWN that included locations such as the Control Building, Auxiliary Building, and Containment Building. However, the Haddam Neck EAL lacked the specificity in regard to which radiation monitors, specific setpoints, ar.d the area requiring continuous or infrequent access are EAL thresholds. The TBD justified the Haddam Neck EAL with, Accortling to UFSAR Section 6.4... A11 the ESF and supporting systems can be operated from the control room.
- Thus, continuous occupancy of the areas in which this equipment is located is not required.
Therefore, the CY EAL addresses event sequences that fall outside the design basis resulting in high radiation in areas requiring personnel access to achieve or maintain safe shutdown... The emergency pian shou 1d address the full spectrum of reactor accidents, not just the UFSAR " credible" accidents.
Furthermore, the subject of areas requiring infrequent access was not addressed by this EAL nor the TBD.
. Provide justification for these deviations from the NUMARC/NESP-007 guidance.
6.
The NUMARC criteria for Initiating Condition ASI and EAL ASI-4 state:
Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity that Exceeds 100 mR Whole Body or 500 mR Child Thyroid for the Actual or Projected Duration of the Release.
4.
Field survey results indicate site boundary dose rates exceeding 100 mR/hr expected to continue for more than one hour; or analyses of
?
field survey samples indicate child thyroid dose commitment of 500 mR for one hour of inhalation.
The equivalent Haddam Neck IC and EAL state:
OS1 0FFSITE DOSE 5.
Measured Plume Dose Rate Onsite 150 mR/hr for > 15 Minutes Without Rad (Assessment) 6.
Rad Assessment Determines Integrated Dose Offsite 2 0.05 Rem TEDE OR 2 0.25 Rem CDE Thyroid A.
The specificity of the NUMARC criteria with respect to the location of the measured or assessed doses was not incorporated into the Haddam Neck EALs, i.e., at the site boundary vs. onsite or offsite, nor was the deviation justified in the TBD.
B.
NUMARC criterion regarding field survey results include expected to continue for more than one hour. This criterion was not incorporated into the Haddam Neck EALs nor was the deviation justified in the TBD.
Both of these deviations applied to NUMARC criterion AG1 also, but will not be separately commented on.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
7.
The NUMARC criterion for Initiating Condition AG1 states:
Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity that Exceeds 1000 mR Whole Body or 5000 mR Child Thyroid for the Actual or Projected Duration of the Release Using Actual Meteorology.
The equivalent Haddam Neck IC and EAL state:
OG1 0FFSITE DOSE 6.
Rad Assessment Determines Integrated Dose Offsite 21 Rem TEDE OR 25 Rem CDE Thyroid
l o
a l Absent from the Haddam Neck IC and the supporting EAL was the NUMARC criterion of using Actual Neteorology. The TBD states the declaration would be based upon EPOP 4431, Radiological Dose Assessment, but did not indicate whether the procedure required the use of actual meteorology.
Provide justification for the deviation from the NUMARC/NESP-007 guidance.
NUMARC Recoanition Cateaory F - Fission Product Barrier Dearadation 8.
The NUMARC criterion for loss of fuel clad, based upon coolant activity, states:
Primary Coolant Activity level Coolant activity GREATER THAN (site-specific) value The Haddam Neck equivalent EAL, FCB3-5 states:
Dose Rate at One Foot from Unpressurized RCS Sample 2 23 mR/hr/m1.
A.
Regardless of the licensee's development of a unique EAL for assessing fuel clad integrity, the NUMARC example EAL of " coolant activity greater than 300 pCf/cc dose equivalent I-131" should be included in the EAL scheme or its omission justified.
B.
The TBD on page B-15 incorrectly quotes the NUMARC guidance in stating that 300 Ci/cc dose equivalent I-131 corresponds to 5-10% fuel clad damage.
This level corresponds to 2-5% fuel clad damage and the licensee's EAL i
thresholds should be adjusted accordingly.
C.
The Haddam Neck TBD justified the EAL threshold with The coolant sample i
radiation reading was determined by calculating various coolant I-131 DEQ concentrations postulated to result from 5% fuel clad failure and using core inventory and source term assumptions in NUREG-1465...
The sample reading corresponding to this concentration was then determined using NU Radiological Assessment methodology...
These values are:
23 mR/hr/m1 at 1 foot from sample, using the maximum I-131 DEQ of 832 pCi/cc (minimum coolant volume) 4.9 mR/hr/ml at 1 foot from sample, using the minimum I-131 DEQ of 174 pCf/cc (maximum coolant volume)
The higher value was selected because inadequate core cooling scenarios are the conditions of interest. This means that there is no or minimal ECCS injection, thus assuming minimum coolant volume is appropriate...
The Haddam Neck EAL was based on two non-conservative assumptions in the calculation: 1) the high end of the fuel clad damage band prescribed by NUMARC (5% vs 2%), and 2) assuming the minimum coolant volume, thus maximum
. concentration. Since fuel damage accident scenarios can be postulated that do not occur without the significant loss of coolant assumed in the Millstone 2 calculation, and the resulting 832 pC1/cc concentration is inconsistent with the balance of the industry, the licensee's EAL deviates significantly from the NUMARC guidance without adequate justification.
9.
The NUMARC criterion for the Fuel Clad Barrier Example EAL #1 states:
POTENTIAL LOSS lL Critical Safety Function Status
... Heat Sink-RED The equivalent Haddam Neck EAL states:
FCB1 Status Trees Heat Sink - RED And BOTH of the following:
- Required Feedwater Flow Can NOT Be Established Within 15 Minutes
- RCS Feed and Bleed Can NOT Be Established The licensee has included additional criteria for the potential loss of the fuel clad, based on critical safety function status tree monitoring, that are inconsistent with the NUMARC guidance and are not adequately justified.
Reword the EAL to be consistent with the guidance in NUMARC/NESP-007 or provide additional justification for it as written. This comment holds for RCB1, Status Trees, EAL #2, but will not be commented on separately.
10.
The NUMARC criterion for the RCS Barrier Example EAls #2 and #3 state:
POTENTIAL LOSS
- 2. RCS Leak Rate Unisolable leak exceeding the capacity of one charging pump in the normal charging mode
- 3. SG Tube Ruoture Site-specific indication that a SG is ruptured and the Primary-to-Secondary leak rate exceeds the capacity of one charging pump in the normal charging mode The equivalent Haddam Neck EAls state:
RCB4 Coolant Leakage LOSS
. RCS Leak Rate > Makeup Capacity AND Entry Into E-3, Steam Generator Tube Rupture, Is Required POTENTIAL LOSS 1.
RCS Leak Rate > Makeup Capacity AND Entry Into E-0, Reactor Trip Or Safety Injection, Is Required 2.
RCS Leak Rate $ Makeup Capacity,;*,'D Entry into E-3, Steam Generator Tube Rupture, Is Required The NUMARC thresho3d for leakage is, inability to maintain normal liquid inventory within the Reactor Coolant System (RCS) by normal operation of the Chemical and Volume Control System which is considered as one centrifugal charging pump discharging to the charging header. The Haddam Neck EAL thresholds (Makeup Capacity AND Entry Into...) have deviated in a non-conservative manner from the NUMARC criterion (one charging pump) without adequate justification in the TBD.
Furthermore, it is unclear as to why an RCS leak into a SG is considered a " Loss" of the RCS barrier, while an RCS leak of the same magnitude being released to the containment is only a
" Potential Loss" of the RCS barrier.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
11.
The NUMARC criterion for the RCS Barrier Example EAL #5 states:
POTENTIAL LOSS L Other (Site-Soecific) Indications (Site-Specific) as applicable The equivalent Haddam Neck EAL RCB3 states:
POTENTIAL LOSS Decreasing RCS Pressure With Abnormal Conditions in CTNT The TBD states that The " potential loss" EAL addresses initial symptoms of RCS leakage...
This corresponds to indications of decreasing RCS pressure with abnormally high containment temperature, pressure, or humidity.
A.
All other EALs of similar structure in the Haddam Neck scheme use the terminology Uncontrolled [RCS Cooldown] vs Decreasing, where Uncontrolled was defined as Condition is not the result of planned actions by the plant staff.
B.
Other EALs use the structure AND for coincident conditions rather than With.
_g.
C.
Abnormal Conditions [in CTNT) was not included in the list of definitions, and counding values were not included in the TBD.
D.
The TBD states. Since secondary line L aaks inside CTMT also can result in the indications of concern for this EAL, it is appropriate to consider this as only a " Potential Loss" of the RCS Barrier. Although this TBD admission acknowledged the EAL was potentially not applicable to the RCS barrier, no differentiating criterion was provided to prevent an inadvertent, incorrect emergency declaration based on faulty indicators.
Human engineered, model EAls are user friendly. This Haddam Neck EAL was inconsistent with the desired attributes in that it was not consistent and not objective.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
12.
The NUMARC criteria for the Primary Containment Barrier Example EAL #2 state:
POTENTIAL LOSS L Containment Pressure (Site-Specific) PSIG and increasing OR Explosive mixture exists.
OR Containment pressure greater than containment depressurization system setpoint with less than one full train of depressurization equipment operating.
The equivalent Haddam Neck EAL #CNB3 states:
POTENTIAL LOSS CTNT Pressure 2 45 PSIG AND Increasing CTNT H Concentration k 4%
g The NUMARC criteria of inoperative depressurization equipment appeared to be omitted from the Haddam Neck scheme. The absence of the EAL was not justified in the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
13.
The NUMARC criteria for the Primary Containment Barrier Example EAL #4 state:
LOSS
. L,.
SG Secondary Side Release With Primary-to-Secondary Leakaae Release of secondary side to atmosphere with primary to secondary leakage GREATER THAN tech spec allowable The equivalent Haddam Neck EAL #CNB4 states:
SG Tube Rupture in Progress AND Release to the Environment > 15 Minutes The TBD states Smaller spectrum or uncomplicated SG tube ruptures addressed by the RCB4, Coolant Leakage, above are not expected to result in prolonged releases to the environment as the operations staff perform the actions required by E0P E-3, Steam Generator Tube Rupture.
Of chief concern for this EAL are steam generator tube rupture sequences resulting in prolonged releases to the environment. Prolonged releases could be the result of a large primary-to-secondary flow rapidly increasing ruptured SG water level... The NUMARC EAls are structured to result in a declaration for the full spectrum of steam generator tube ruptures, i.e., a small break resulting in an Unusual Event to large rupture resulting in a Site Area Emergency.
Further, the NUMARC EAL does not include a threshold of time for the bypass condition to exist.
The Haddam Neck EAL did not reflect these attributes, and the TBD justification appeared erroneous in its evaluation of the NUMARC EAL.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
14.
The NUMARC criteria for the Primary Containment Barrier Example EAL #6 state:
POTENTIAL LOSS L Core Exit Thermocouole Readinas 2
Core exit thermocouples in excess of 1200 and restoration procedures not effective within 15 minutes; or, core exit thermocouples in excess of 700' with reactor vessel level below top of active fuel and restoration procedures not effective within 15 minutes The equivalent Haddam Neck EAL states:
j CNB2 POTENTIAL LOSS Entry into FR-C.1, Response to Inadequate Core Cooling, Is Required AND Core Exit T/C Temperatures Do NOT Decrease Within 15 Minutes The Haddam Neck TBD states, Per F-0.2, Core Cooling Status Tree,1200 F corresponds to Core Cooling - RED which requires entry into FR-C.1, Response to Inadequate Cooling. This EAL clearly addresses the first part of the NUMARC criteria, but the second criterion related to thermocouples > 700 F and water level below top of active fuel and restoration procedures not
, effective in 15 minutes was not addressed, nor was its absence from the EAL scheme justified in the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
15.
Haddam Neck EAL #BA2 states:
Unisolable Steam Line Break Outside CTNT.
The TBD states that an "unisolable steam line break outside containment can mask steam generator tube leakage.
This is conservatively treated by Northeast Utilities as a potential substantial degradation in the level of safety of the plant. The TBD also states that this "EAL provides an alternate method indication to Barrier Failure Reference Table EALs RCB1 (RCS Integrity
- RED) and RCB4 (RCS Leak Rate > Makeup Capacity AND Entry Into E-0, Reactor Trip Or Safety injection Is Required). Although these statements are made in the TBD, no technical information was provided to support the assertion that.
the RCS is potentially lost when there is an unisolable steam line break at' Haddam Neck. This EAL is also inconsistent with the guidance in NUMARC/NESP-007, which placed this specific event under HUS, "Other Conditions Existing Which In the Judgement of the Emergency Director Warrant the Declaration of an Unusual Event."
Provide adequate justification for this deviation to the NUMARC guidance.
16.
The NUMARC criteria for RCS Barrier Example EAL #1 state:
POTENTIAL LOSS
- 1. Critical Safety Function Status RCS Integrity - RED OR Heat Sink - RED No example EALs are provided for loss of the RCS based upon critical safety function monitoring.
A site-specific EAL is provided for " Loss" of the RCS barrier which states:
l Core Cooling - Yellow The TBD states that this path exists when RCS subcooling < 32*F (or table value for adverse containment conditions). Thus, the EAL makes the assumption that the RCS integrity is lost when there is reduction or loss in the subcooling margin. However, a loss of subcooling, in and of itself, does not necessarily equate to a loss of the RCS barrier. The NUMARC guidance on loss of the RCS barrier, Le.ed upon subcooling margin, specifically states:
LOSS
l 2. RCS Leak Rate GREATER THAN available makeup capacity as indicated by a loss of RCS subcooling i
Thus, the loss of RCS subcooling is directly linked to a breach of the RCS barrier and is indicative of a condition where the leak rate exceeds the available makeup capacity.
The proposed EAL should be revised or adequate justification provided.
17.
The NUMARC criterion for RCS Barrier EAL #4 states:
LOSS
- 4. Containment Radiation Monitorina Containment rad monitor reading GREATER THAN (site-specific) R/hr The Equivalent Haddam Neck EAL #RCBS states:
CD-1/CD-2 Reading ' SR/hr Without Fuel Clad Barrier loss The guidance in NUMARC/.c,P-007 provides that the site-specific threshold be calculated assuming an instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with normal operating concentrations. No calculations were provided to demonstrate that this site-specific threshold was developed in accordance with the NUMARC guidance.
Provide supporting information for this site-specific threshold.
18.
The licensee has proposed a site-specific EAL for " Loss" of the Containment barrier.
EAL #CNB5 states:
Offsite Dose Plume Rate k 10A Times CD-1/CD-2 Reading if Coolant loss is to CTMT A.
The TBD states that this was previously developed as a thumbrule for indication of loss of the containment barrier. No supporting information on how this thumbrule was developed was provided.
Provide information on the assumptions and calculations for this EAL.
B.
The TBD references the NUMARC example EAL for potential loss of containment based upon significant inventory in containment as being applicable to this site-specific indicator. The basis for the NUMARC example EAL states that "this amount of activity in containment, if released, could have such severe consequences that it is prudent to treat this as a potential loss of containment, such that a General Emergency declaration is warranted".
The licensee's site-specific indicator, however, is insensitive to the
L u
, radioactive inventory in containment and is representative of a loss of the barrier vs. a potential loss as suggested by the NUMARC guidance. Therefore, the' licensee's site-specific EAL does not reflect the irtent of the NUMARC example EAL it references.
Remove the reference to the NUMARC example EAL for sig1ificant radioactive l
inventory in containment.
NUMARC Recoanition Cateoory H - Hazards and Other Conditions Affectina Plant j
Safety 19.
The NUMARC criterion for EAL HU2-1 states:
j 1.
Fire in buildings or areas contiguous to any of the following (site-specific) areas not extinguished within 15 minutes of control room notification or verification of a control room alarm:
(Site-specific) list i
The equivalent Haddam Neck EAL GUI states:
f Fire Within an Area Containing Safe Shutdown Equipment > 15 Minutes The Haddam Neck EAL was written in a less conservative manner than the NUMARC criterion in that the event was described as within vital areas, whereas the NUMARC criterion is more anticipatory with in buildings or areas contiguous to vital areas. This non-conservative deviation was not justified in the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
20.
The NUMARC criterion for EAL HU4-2 states:
2.
Other security events as determined from (site-specific) Safeguards Contingency Plan.
There was no equivalent Haddam Neck EAL and the omission was not justified in the TBD. This also applies to NUMARC EALs HA4-2 and HSI-2 but will not be separately commented on.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
21.
The NUMARC criterion for EAL HAl-3 states:
3.
Report of any visible structural damage on any of the following plant structures:
Reactor Building
=
Intake Building Ultimate Heat Sink Refueling Water Storage Tank
.. Diesel Generator Building Turbine Building Condensate Storage Tank Control Room Other (Site-Specific) Structures The equivalent Haddam Neck 6]1tt EAL #TA2-3 states:
3.
Report to Control Room of Damage Affecting Safe Shutdown Another EAL (#TV2-3) addressed the same subject, but was included in the Unusual Event, Destructive Phenomena category as follows:
3.
Visible damage to Structures or Equipment Required for Safe Shutdown The Haddam Neck Alert EAL was inconsistent with the NUMARC criterion in that the EAL implied assessment by field and/or control room personnel. Thus the anticipatory nature of the NUMARC EAL was lost. The Haddam Neck Unusual Event EAL more closely reflected the intent of the NUMARC Alert criterion.
These deviations from the NUMARC criterion were not justified in the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
22.
The NUMARC criterion for EAL HAl-6 states:
6.
Turbine failure generated missiles result in any visible structural damage to or penetration of any of the following plant areas: (site-specific) list.
The equivalent Haddam Neck EAL #TA2-5 states:
5.
Missiles Affecting Safe Shutdown NUMARC provided additional guidance in the basis information: EAL 6 is intended to address the threat to safety related equipment imposed by missiles generated by main turbine rotating component failures. This (site-specific) list of areas should include all areas containing safety-related equipment, their controls, and their power supplies.
Three concerns were noted with the Haddam Neck EAL:
A.
" Missiles" has a far broader meaning than was intended by this NUMARC EAL that is addressed by HAl-5.
B.
The specificity of contemporaneous damage reflected in the NUMARC Basis Information was not addressed by the Millstone EAL nor its absence justified in the TBD.
C.
The related Unusual Event (TV2-6) states: Turbine Failure Causing Observable Casing Damage.
The use of different terminology, i.e., " turbine" and " missiles" could potentially be confusing in making a classification.
1 l 4
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
l 23.
The NUMARC EAL examples HA3-1 and 2 state-l 1.
Report or detection of toxic gases within a Facility Structure in l
l concentrations that will be life threatening to plant personnel.
l l
2.
Report or detection of flammable gases within a Facility Structure in concentrations that will affect the safe operation of the plant.
The Haddam Neck equivalent EAL #GA3 states:
Toxic or Flammable Gas Making Vital Areas Uninhabitable Or inaccessible l
The licensee did not reference or provide measurable criteria to the emergency director for estab11shing concentrations that affect safe operation of the plant. Without such information, i.e., "When have life threatening and flammable concentration thresholds have been exceeded?", readily available, I
classification would be difficult.
Furthermore, the EAL scheme utilized the concept of Areas of Concern for Safe Shutdown for all other EALs, whereas this EAL used the term Vital Areas which was undefined by the procedure. This inconsistency was not in accordance with NUMARC guidance for model EALs.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
24.
The NUMARC criteria for Initiating Condition (IC) HA5 and EAL HA5-1 state:
Control Room Evacuation Has Been Initiated.
1.
Entry into (site-specific) procedure for control room evacuation.
The equivalent Haddam Neck IC and EAL #GA1 state:
GA1 CONTROL ROOM EVACUATION i
Control Room Evacuated Per Station Procedure or OSS Judgement The NUMARC criteria reflects a declaration when control room evacuation is initiated, whereas the Haddam Neck EAL was stated in the past tense, control room evacuated.
The time difference was not intended with the NUMARC IC, and was not justified in the TBD. This same concern related to time from i
evacuation initiated unt11 control established was applicable to NUMARC criterion HS2 and Haddam Neck EAL GSI, but will not be separately commented on.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
25.
The NUMARC criterion for HS3-1 states:
g i ~
1.
Other conditions exist which in the judgement of the Emergency Director indicate actual or likely major failures of plant functions needed for protection of the public.
r The equivalent Haddam Neck EAL states:
Any condition which in the USS/DSE0's judgement indicates loss or potential loss of two fission product barriers.
This site-specific EAL is already covered under the fission product barrier EALs and, therefore, is redundant. Contrary to the TBD, this EAL is not consistent with the definition of the Site Area Emergency class in NUREG-0654 or NUMARC/NESP-007. The licensee should reword the judgement EAL to be consistent with the NUMARC guidance and the requirements of Appendix E to 10 CFR Part 50.
26.
The NUMARC criteria for HG2-1 sthte:
1.
Other conditions exist which in the judgement of the Emergency Director indicate: (1) actual or imminent substantial core degradation with potential for loss of containment, or (2) potential-for uncontrolled radiological releases.
These releases can reasonably be expected to exceed EPA PAG plume exposure levels outside the site boundary.
The equivalent Haddam Neck EAL states:
JG1 OSS/DSEO JUDGEMENT Any Condition Which in the OSS/DSE0's Judgement Indicates Potential for Radiological Releases Requiring Evacuation or Sheltering Offsite A.
The TBD indicates that the EAL addresses the conditions that fall under the General Emergency classification description in NUREG-0654, Appendix 1 that is retained under the NUMARC methodology, however, the licensee failed to i
include the first argument of the NUMARC example EAL.
B.
The NUMARC guidance calls for declaration of a General Emergency when releases can be expected to exceed the Environmental Protection Agency's (EPA)
Protective Action Guides (PAGs) for the plume exposure pathway. The proposed EAL suggests classification when releases require sheltering offsite.
However, there are no EPA PAGs for sheltering in the plume exposure pathway.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
27.
The NUMARC criteria for HS2 state:
l 1.
The following conditions exist:
r a.
Control room evacuation has been initiated.
=
c
! AND
^
b.
Control of the plant cannot be established per (site-specific) procedure within (site-specific) minutes.
The equivalent Haddam Neck EAL states:
Operations Outside the Control Roon per AOP 3.2-50 Required And EITHER of the Following:
Procedure NOT Initiated Within 15 Minutes of Control Room Evacuation Procedure NOT Completed Within 60 Minutes of Control Room Evacuation The TBD states that the licensee utilizes the'15 minute criterion in the NUMARC guidance for initiation of operations. This is inconsistent with the basis of NUMARC HS2. The intent of including a time criterion for this initiating condition is to allow a sufficient, but not excessive, amount of time for the OSS to determine if control can be readily established outside of the control room..The site-specific time should be developed utilizing analyses that demonstrate how quickly control must be reestablished without core uncovery and/or core damage. This limit should also be limited to 15 minutes unless a longer period can be supported by analyses. The estimated time for completing the actions of A0P 3.2-50 should not be the basis for the time limit in the site-specific EAL.
Provide the site-specific analyses to support this EAL as written.
Provide justification for this deviation from the NUMARC guidance.
NUMARC Recoanition Cateaory S - System Malfunction 28.
The NUMARC criteria for 503-1 state:
1.
The following conditions exist:
a.
Loss of most or all (site-specific) annunciators associated with safety systems for greater than 15 minutes.
AND d.
Annunciator or Indicator loss does not result from planned actfon.
The equivalent Haddam Neck EAL states:
EU3 LOSS OF ANNUNCIATORS Loss of Most (75%) MCB Annunciators > 15 Minutes AND SPDS Or ICC Cabinet Available i
O f The threshold of NUMARC EAL SU3-1.d., i.e., not... planned action, was not included in the Haddam Neck EAls nor was its absence justified in the basis document. This deviation was also applicable to Alert EAL EA3.
The same criterion of unplanned in NUMARC Initiating Condition SU6 (Loss of Communications) was omitted from the Haddam Neck EAL EU4.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
29.
The NUMARC criteria for Initiating Condition SU5 and EAL SU5-1 state:
SUS RCS Leakage OPERATING MODE APPLICABILITY: POWER OPERATION HOT STANDBY HOT SHUTDOWN 1.
The following conditions exist:
a.
Unidentified or pressure boundary leakage greater than 10 gpm.
OR b.
Identified leakage greater than 25 gpm.
The NUMARC Basis criteria states Only operating modes in which there is fuel in the reactor coolant system and the system is pressurized are specified.
The equivalent Haddam Neck EAL BU2 states:
BU2 RCS LEAKAGE MODE: ALL 1.
Pressure Boundary Leakage > 10 GPM 2.
Unidentified Leakage > 10 GPM 3.
Identified Leakage > 25 GPM The TBD states NUREG-1449 raises concerns regarding accident sequences involving leakage through RCS temporary boundaries. RCS leakage EAls apply to all operating modes at CY.
This will assure that leakage is appropriately addressed for cold shutdown and refueling modes and address NRC concerns about 1eakage through temporary RCS boundaries as they apply to EAls.
The j
definition of an Unusual Event (UE) includes the attributes... indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring offsite response or monitoring are expected...
During non-pressurized modes of operations, other NUMARC EAls are designed to address those conditions described by the UE definition. The addition of the Haddam Neck criterion of ALL [#0 DES] was a conservatism that is inconsistent with the UE definition, inconsistent with the industry, and not adequately justified by the TBD.
i l
, Provide justification for this deviation from the NUMARC/NESP-007 guidance.
30.
The NUMARC example SU7-1 states:
1.
Either of the following conditions exist:
a.
Unplanned' loss of vital DC power to required DC busses based on (site-specific) bus voltage indications.
AND b.
Failure to restore power to at least one required DC bus within 15 minutes from the time of loss.
The Haddam Neck equivalent EAL #PU2 states:
Loss of DC On Busses A And B/BX > 15 Minutes The NUMARC criterion specifies that the loss of DC voltage is unplanned..This EAL applies to cold shutdown and refueling, and planned work that de-energizes i
the DC busses should not trigger a declaration.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
31.
The NUMARC criterion for Site Area Emergency.EAL SS3-1 states:
OPERATING MODE APPLICABILITY: Power Operation Hot Standby Hot Shutdown 1.
Loss of All Vital DC Power based on (site-specific) bus voltage indications for greater than 15 minutes.
The equivalent Haddam Neck Alert Initiating Condition and EAL #PA3 state:
1 PA3 LOSS OF DC Mode 2,3,4 Loss of DC On Buses A And B/BX > 15 Minutes The equivalent Haddam Neck Site Area Emeroency Initiating Condition and EAL
- PS2 state:
PS2 LOSS OF DC Mode 1 Loss of DC On Buses A And B/BX > 15 Minutes The Haddam Neck TBD, Alert EAL, justified the deviation from NUMARC criterion with Mode 2 operation, startup, corresponds to power levels up to 5% of rated thermal power (RTP).
This means that the plant would be operating with the low power interlock, P-7, blocking several reactor trip signals related to
r reactor coolant pump operation, core flow, and turbine trip. At power levels up to 5%, temperature and pressure response would be limited.... Similar plant transient response would occur for loss of DC fron modes 3 and 4...
The TBD, Site Area Emergency EAL, went on to state, Complete loss of DC during power operation will result in a complete loss of annunciators and can result in a much more severe transient response (i.e., significant transient) than that associated with operation in lower modes. The NUMARC Basis Information states that loss of all DC power compromises ability to monitor and control plant safety functions. The NUMARC EAL seeks to provide anticipatory declaration of a site area emergency (SAE) that would ultimately occur under other EALs if a plant transient occurred during the power loss. Manual operation of protective functions coupled with loss of valve position indication and annunciation "... involve actual or likely major failures of plant functions needed for protection of the public," the definition of a Site Area Emergency.
Provide additional information concerning the source of control power for engineered safety features.
Provide additional justification for the deviation from the NUMARC/NESP-007 guidance.
32.
The NUMARC criterion for SS4-1 states:
1.
Complete loss of any (site-specific) function required for hot shutdown.
The equivalent Haddam Neck EAL ES2-1 and -2 state:
ES2 INABILITY TO MAINTAIN HOT S/D 1.
Heat Sink - RED And BOTH of the Following:
= Required Feedwater Flow Can NOT Be Established Within 15 Minutes
- RCS Feed and Bleed Can Not Be Established 2.
RCS Boration Capability Unable to Eliminate Inadvertent Criticality The NUMARC basis criterion states, This EAL addresses complete loss of functions, including ultimate heat sink and reactivity control, required for hot shutdown... Although the Haddam Neck EAls are symptomatic of complete i
loss of hot shutdown functions, the EALs did not possess the additional required attributes'of being " anticipatory" (NUREG-0654 refers). The TBD listed 13 different Technical Specification systems that fulfilled several functions such as core cooling and reactivity control. However, the TBD did not justify the omission of some functions nor the substitute Haddam Neck EALs in an adequate manner.
For example, the TBD did not show that RCS Boration Capability Unable to Eliminate Inadvertent criticality would result in a SAE
\\
declaration in the same time as an EAL stating " loss of reactivity control function."
i
l Furthermore, by definition, and in accordance with the NUMARC guidance, the existence of a RED path on CSFST for Heat Sink constitutes a Site Area Emergency.
In the fission product barrier matrix a Heat Sink RED path is indicative of a potential loss of the fuel clad and RCS barriers, again requiring the declaration of a Site Area Emergency.
The additional criteria of the first EAL are inconsistent with the NUMARC guidance.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
33.
The NUMARC criterion for SU4 Fuel Clad Degradation states:
2.
(Site-specific) coolant sample activity value indicating fuel clad degradation greater than Technical Specification aflowable Ilmits.
The Haddam Neck equivalent EALs under 803 state:
RCS Activity > 60 pCi/gm I-131 DEQ.
Or Dose Rate at One foot From Unpressurized RCS Sample 1 2 mR/hr/m1.
However, the TBD states that the Technical Specification limits for Haddam l
Neck related to coolant specific activity are:
- b. Not more than 68/[pCi per gram of gross radioactivity.
Neither of these values were included as EAls in the Haddam Neck scheme, nor was their omission justified in the TBD.
Provide justification for this deviation to the NUMARC guidance I
i i
n i
.c
}
RE0 VEST FOR ADDITIONAL INFORMATION CONCERNING NORTHEAST NUCLEAR ENERGY COMPANY MILLSTONE NUCLEAR POWER STATION. UNIT NO.-l DOCKET NO. 50-245 The NRC has completed its initial review of the proposed emergency action levels (EALs) in the June 1994 Millstone Nuclear Power Station, Unit 1 NUMARC EAL submittal. The submittal included Emergency Plan Implementing Procedure (EPIP) 4400, Event Assessment. Classification. and Reportability (Revision 2, July 31, 1993), the Millstone Unit 1 EALs table (MSI-01, Rev. F, June 1994),
the Millstone Unit 1 Emeraency Action Level (EAL) Technical Basis Document TBD i
(NRC Submittal Version, June 1994), and miscellaneous other supporting documentation. The proposed EALs were reviewed against the guidance in NUMARC/NESP-007, " Methodology for Development of Emergency Action Levels",
Revision 2.
NUMARC/NESP-007 has been endorsed by the NRC in Regulatory Guide 1.101, " Emergency Planning and Preparedness for Nuclear Power Reactors",
Revision 3, 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.
Since the staff has previously endorsed 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.
NUMARC Recoanition Cateaory A - Abnormal Rad Levels /Radioloaical Effluent 1.
The NUMARC criteria for Initiating Condition (IC) AU1 and EAL AU1-1 state:
AU1 Any Unplanned Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds Two Times the Radiological Technical Specifications for 60 Minutes or Longer.
1.
A valid reading on one or more of the following monitors that exceeds the "value shown" (site-specific monitors) indicates that the release may have exceeded the above criterion and indicates the need to assess the release with (site-specific procedure):
(site-specific list)
Note:
If the monitor reading (s) is sustained for 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.
. The NUMARC Basis information goes on to state: The term " Unplanned", as used in this context, includes any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit.
l The Millstone 1 equivalent EAL stated:
0U1 UNPLANNED RELEASE Unplanned, Unmonitored, or Uncontrolled Offsite Release Within Delta-Two Posture Code Limits As Determined from EPIP 4400, Event Assessment, Classification and Reportability A.
EPIP 4400, Paragraph 4.4.3, required, Refer to and REVIEW Attachment 3,
" Unplanned Radioactive Release Reporting Criteria," for the type of release involved. Attachment 3 listed approximately 31 Maintenance Operations that were considered... normal or expected maintenance or operation activities which may increase the release rate of gaseous radioactivity from the plant stack (s).
Paragraph 4.4.4 required that E it is determined that an unplanned release..., then event evaluation was continued in accordance with the procedure. The " planned" list of releases included items such as.
1 D.1. Minor valve packing leaks in any radioactive system.
0.2. Minor pump seal leaks in any radioactive system.
D.3. Increased secondary side activity as indicated by increases in the condenser air ejector monitor...
These " planned" items were clearly inconsistent with the intent of the NUMARC guidance related to planned and unplanned releases. Although the Millstone 1 TBD included the NUMARC Basis staternent in its discussion, no justification was provided for the deviation from the NUMARC guidance.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
B.
The TBD stated, The Stack Gas Monitor - Normal Range, located on the Hillstone 1 stack, provides an alarm if release rates may have exceeded criteria for reporting unplanned releases... This setpoint represents a concentration of stack effluent that will result in a site boundary dose rate of 5 mR/hr, assuming a stack flow of 180,000 CFM and average meteorology.
i Neither this valid monitor reading nor any other were listed as EAL thresholds in the Millstone 1 tables to support the NUMARC IC. Rather, EPIP 4400, paragraph 4.4.4 required, E it is determined that an unplanned release may exceed the 1imits specified in Attachment 3, COMPLETE the calculations as listed in Attachment 3 for the released material. Attachment 3, Sheet 8 of 11,'provided, Unplanned Radioactive Release Reporting Criteria Radionuclide j
Ci). This table listed approximately 50 Reportable Quantities - Rq (and Fe", with the associated RQ in curies, 0.01 radionuclides, such as I" i
. L and 10 respectively.
If an isotope, such as tritium, was not listed, the user was referred to 40CFR302.4 for the RQ.
Based on the above, the reviewer concluded the provisions of NUMARC EAL AU1-1 were not included in the Millstone scheme and were not justified in the TBD.
That is, provide threshold monitor readings, that if exceeded for 160 minutes, and an assessment has not been completed, then make a declaration based upon the valid monitor reading. Only " assessment" was provided for by the Millstone 1 scheme.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
2.
The NUMARC criteria for AU2-1 and -2 states:
1.
(Site-specific) indication of uncontrolled water level decrease in the reactor refueling cavity with all irradiated fuel assemblies remaining covered by water.
2.
Uncontrolled water level decrease in the spent fuel pool and fuel transfer canal with all irradiated fuel assemblies remaining covered by water.
1 The Millstone 1 equivalent EALs EU2-1 and 2 stated:
EU2 Rx CAVITY / FUEL POOL LEVEL 1.
Uncontrolled Spent fuel Pool Water Level Decrease As Indicated by Fuel Pool Level Recorder Reading of 0%
l 2.
Uncontrolled Refuel Pool Water Level Decrease Requiring Containment Evacuation AND All Spent Fuel Assemblies in Safe Storage Locations A.
The TBD indicated that a fuel pool level recorder reading of 0% was equivalent to top of fuel in the spent fuel pit. At that level, the NUMARC criteria of remaining covered by water and the NUREG-0654 criteria of anticipatory would not necessarily be achieved.
This deviation was not justified in the TBD.
B.
It appeared that the fuel pool level recorder was applicable only to the Spent Fuel Pool water level under 111 circumstances, thus the NUMARC guidance of (Site-specific) indication of uncontrolled water level decrease in the reactor refueling cavity... was omitted from the EAL, i.e., what was the site-specific indication to be used as the EAL threshold for the reactor refueling cavity?
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
3.
0A1 Offsite Dose
. The TBD, which states that the preferred method for evaluating this IC is by use of radiological dose assessment, is inaccurate. The intent of the lower emergency class ICs for radiological effluents (Unusual Event and Alert) is to take actions based upon a loss of control of radioactive material. Therefore, classification need only be based upon exceeding the associated EAL threshold (s) for greater than 15 minutes, not necessarily a dose assessment of the release. The NUMARC guidance specifically calls for a dose assessment using actual meteorology to determine the consequences of that release and whether or not adverse conditions would escalate the classification or posture code.
The TBD should be revised to reflect the intent of the NUMARC IC.
4.
The NUMARC criteria for AA2-1, 2, 3, and 4 states:
1.
A (site-specific set point) alarm on one or more of the following radiation monitors: (site-specific monitors) 2.
Report of visual observation of irradiated fuel uncovered.
3.
Water Level less than (site-specific) feet for the Reactor Refueling Cavity that will result in irradiated fuel uncovering.
4.
Water level less than (site-specific) feet for the Spent Fuel Pool and Fuel Transfer Canal that will result in irradiated fuel uncovering.
The NUMARC basis guidance goes on to state: Each site should also define its EAls by the specific area where irradiated fuel is located such as Reactor Cavity, Reactor Vessel, or Spent Fuel Pool.
The Millstone 1 equivalent EAls stated:
1.
Spent Fuel is Exposed from Open Vessel, Cavity or SF Pool AND Spent Fuel Has Decayed 1 30 Days 2.
Report of Fuel Handling Accident Causing Visible Damage to Any Spent Fuel Assembly 3.
Area Rad Monitors Indicate Spent Fuel Damage or Uncovery The Millstone 1 EALs lack the specificity in regard to which radiation monitors and specific setpoints, and location and water level form the thresholds suggested by the NUMARC guidance. The TBD was silent on the omitted criteria.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
5.
The NUMARC criteria for AA3 states:
j
, 1.
Valid (site-specific) radiation monitor readings GREATER THAN 15 mR/hr in areas requiring continuous occupancy to maintain plant safety functions:
(Site-specific) Ifst 2.
Valid (site-specific) radiation monitor readings GREATER THAN < site-specific > values in areas requiring infrequent access to maintain plant safety functions:
(Site-specific) ifst i
The Millstone 1 equivalent EAL stated:
Dose Rates Prevent Occupancy Or Access to Areas Needed for Safe Shutdown The Millstone 1 EAL scheme included a table of AREAS OF CONCERN FOR SAFE SHUTDOWN that included locations such as the Reactor Building, Control Room, and Shutdown Cooling Pump Area. However, the Millstone 1 EAL lacked the specificity in regard to which radiation monitors, specific setpoints, and the area requiring continuous or infrequent access are EAL thresholds.
The TBD justified the Millstone 1 EAL with, According to the UFSAR, the control room is designed to allow control of the plant during all modes of operation, and can be occupied under all credible accidents. All ESF and supporting systems can be operated from the control room.
Thus, continuous occupancy of the areas in which this equipment is located is not required.
Therefore, the Hillstone EAL addresses event sequences that fall outside the design basis resulting in high radiation in areas requiring personnel access to achieve or maintain safe shutdown. The emergency plan should address the full spectrum of reactor accidents, not just the FSAR " credible" accidents.
Furthermore, the subject of areas requiring infrequent access was not addressed by this EAL nor the TBD.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
6.
The NUMARC criteria for IC AG1 states:
Boundarv Doss Resulting from an Actual or Imminent Release of Gaseous Radioactivity that Exceeds 1000 mR Whole Body or 5000 mR Child Thyroid
\\
for the Actua) or Projected Duration of the Release Using Actual Meteorology.
j i
The equivalent Millstone 1 IC and EAL stated
- i i
OG1 0FFSITE DOSE i
3.
Rad Assessment Determines Integrated Dose Offsite 21 Rem TEDE OR >5 Rem CDE Thyroid
1 1 !
+
/
' Absent from the Millstone 1 IC and the supporting EAL was the NUMARC criteria of Using Actual #eteorology. The TBD included the criteria regarding l
meteorology, but would have to be referred.to by a classifier in addition to
.the classification implementing procedure, resulting in potential delay of the classification.
Provide justification for the deviation from the NUMARC/NESP-007 guidance.
I NUMARC Recoanition Cateaory F - Fission Product Barrier Dearadation 1
7.
The NUMARC criteria for the RCS Barrier Example EAL #1 states:
LOSS Lz RCS Leak Rate i
(site-specific) indication of Main Steamline Break The equivalent Millstone 1 EAL stated:
LOSS Primary System Break As Determined from b
Annunciators or Plant Personnel Report The TBD stated that Indicators of Primary System / Main Steam Line Break at Millstone 1 include the following annunciators:
i
. STEAM TUNNEL CHANNEL A/B HI TEMPERATURE...
. MAIN STEAM LINE CHANNEL A/B HI FLOW...
. MAIN STEAM LINE CHANNEL A/B L0 PRESSURE...
Model EALs that are human engineered shou 1d be user friendly. This M111 stone 1 EAL required memorization (i.e., Annunciators = ?) which is inconsistent with the desired attributes.
+
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
8.
The NUMARC criteria for the RCS Barrier Example EAL #1 states:
POTENTIAL LOSS lx RCS leak Rate RCS Leakage CREATER THAN 50 GPM inside the drywell An equivalent Millstone 1 EAL was not provided. The TBD justified the absence with Many BWRs may be unable to measure an RCS leak of this size because the r
i i
1 i 1eak would likely increase drywell pressure above drywell isolation setpoint.
The TBD went on to state Based on 1-OPS 3.07, Technical Basis for the Millstone Unit One Emergency Operating Procedures, the high drywell pressure scram setpoint of 2 psig can be reached due to RCS leakage into the drywell (on the order of about 50 ppm) or...
The drywell pressure EAL of 2 psig appeared to constitute an acceptable symptomatic indicator of RCS leakage, but the leakage condition would have to exist for a long period of time before reaching 2 psig, resulting in a classification delay. The justification did not state that Millstone 1 was unable to measure a 50 gpm leak rate under all circumstances nor make an emergency declaration in a more timely manner.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
9.
The Millstone 1 scheme added a Potential Loss EAL to the RCS Barrier, Primary System Leakage category as follows:
POTENTIAL LOSS Unisolable Primary System Leakage Outside the Drywell as Indicated by Area Rad Monitor Alarms or Radiation Surveys This EAL was replicated in the RCS Barrier and in the Primary Containment Barrier, Radiation category.
Characteristics of model EALs include objective, observable, consistent values. This EAL lacks those characteristics.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
10.
The NUMARC criteria for the Primary Containment Barrier Example EAL #2 states:
LOSS L Containment isolation Valve After Containment Isolation Unisolable primary system leakage outside drywell as indicated by area temp or area rad alarm The equivalent Millstone 1 EAL #CNB4 stated:
LOSS Unisolable Primary System Leakage Outside the Drywell as Indicated by Area Rad Monitor Alarms or Radiation Surveys
. The NUMARC criteria of area temperature alarms appeared to be omitted from the Millstone 1 scheme. The TBD stated The presence of an area radiation or temperature alarms indicating unisolable primary leakage outside the drywell are addressed by the Millstone 1 EALs., but temperature relned EALs could not be located.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
NUMARC Recoanition Cateaory H - Hazatds and Other Conditions Affectina Plant Safety 11.
The NUMARC criteria for EAL HU2-1 states:
1.
Fire in buildings or areas contiguous to any of the following (site-specific) areas not extinguished within 15 minutes of control room notification or verification of a control room alarm:
(Site-specific) list
=
The equivalent Millstone 1 EAL stated:
Fire Within an Area Containing Safe Shutdown Equipment > 15 Minutes The Millstone 1 EAL was written in a less conservative manner than the NUMARC criteria in that the event was described as within vital areas, whereas the NUMARC criteria is more anticipatory with in buildings or areas contiguous to vital areas. This non-conservative deviation was not justified in the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
12.
The NUMARC criteria for EAL HU4-2 states:
2.
Other security events as determined from (site-specific) Safeguards Contingency Plan.
There was no equivalent Millstone 1 EAL and the omission was not justified in the TBD. This also applied to NUMARC EAL HA4-2 and HSI-2 but will not be separately commented on.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
13.
The NUMARC criteria for EAL HAl-2 states:
2.
Tornado or high winds striking plant vital areas: Tornado or high winds greater than (site-specific) mph strike within protected area boundary.
The equivalent Millstone 1 EAL stated:
2.
On-Site Sustained Windspeed > 90 MPH
I,
The NUMARC criteria of a tornado event, which may not be measured by anemometers, was omitted from the Millstone 1 EAL, and not justified in the
~
TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
i 14.
The NUMARC criteria for EAL HAl-3 states-t 3.
Report of any visible structural damage on any of the following plant structures:
Reactor Building Intake Building Ultimate Heat Sink i
Refueling Water Storage Tank Diesel Generator Building Turbine Building
=
Condensate Storage Tank Control Room Other (Site-Specific) Structures The equivalent Millstone 1 Alert EAL #TA2-3 stated:
3.
Report to Control Room of Damage Affecting Safe Shutdown j
Another EAL (#TV2-3) addressed the same subject, but was_ included in the Unusual Event, Destructive Phenomena category as follows:
3.
Visible damage to Structures or Equipment Required for Safe Shutdown The Millstone 1 Alert EAL was non-conservative and inconsistent with the i'
NUMARC criteria in that the EAL implied assessment by field and/or control room personnel. Thus the anticipatory nature of the NUMARC EAL was lost. The Millstone 1 Unusual Event EAL more closely reflected the intent of the NUMARC Alert criteria. These deviations from the NUMARC criteria were not justified in the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
15.
The NUMARC criteria for EAL HAl-6 states:
)
6.
Turbine failure generated missiles result in any visible structural j
damage to or penetration of any of the following plant areas: (site-specific) list.
The equivalent Millstone 1 EAL #TA2-5 stated:
5.
Missiles Affecting Safe Shutdown
. NUMARC provided additional guidance in the basis information: EAL 6 is intended to address the threat to safety related equipment imposed by missiles generated by main turbine rotating component failures. This (site-specific) list of areas should include all areas containing safety-related equipment,
\\
their controls, and their power supplies. Three concerns were noted with this EAL: (1) " Missiles" has a far broader meaning than was intended by this NUMARC EAL that is addressed by HAl-5.
(2) The specificity of contemporaneous damage reflected in the NUMARC Basis Information was not addressed by the Millstone EAL nor its absence justified in the TBD.
(3) The related Unusual Event (TV2-
- 6) stated: Turbine Failure Causing Observable Casing Damage.
The use of different terminology, i.e., " turbine" and " missiles" could potentially be confusing in making a classification.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
16.
The NUMARC examples HA3-1 and 2 state:
1.
Report or detection of toxic gases within a F1cility Structure in concentrations that will be life threatening to plant personnel.
2.
Report or detection of flammable gases within a Facility Structure in concentrations that will affect the safe operation of the plant.
The Hillstone 1 equivalent EAL #GA3 stated:
Toxic or Flammable Gas Making Vital Areas Uninhabitable Or Inaccessible j
The licensee did not reference or provide measurable criteria to the emergency director for establishing concentrations that affect safe operation of the plant. Without such information, i.e., "When have life threatening and flammable concentration thresholds been exceeded?", readily available, classification would be difficult.
Furthermore, the EAL scheme utilized the concept of Areas of Concern for Safe Shutdown for all other EALs, whereas this EAL used the concept of Vital Areas which were undefined by the procedure.
This inconsistency was not in accordance with NUMARC guidance for model EAls.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
17.
The NUMARC criteria for IC HA5 and EAL HA5-1 states:
Control Room Evacuation Has Been Initiated.
1.
Entry into (site-specific) procedure for control room evacuation.
The equivalent Millstone 1 IC and EAL # gal stated:
GA1 CONTROL ROOM EVACUATION Control Room Evacuated Per Unit Procedure Or SS Judgement
. The NUMARC criteria reflects a declaration when control room evacuation is initiated, whereas the Millstone 1 EAL was stated in the past tense, control room evacuated. The time difference was not intended with the NUMARC IC, and was not justified in the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
18.
The NUMARC criteria for IC HS2 and EAL HS2-1 states:
Control Room Evacuation Has Been Initiated and Plant Control Cannot Be Established.
1.
The following conditions exist:
a.
Control room evacuation has been initiated.
AND b.
Control of the plant cannot be established per (site-specific) procedure within (site-specific) minutes.
The equivalent Millstone 1 IC and EAL #GS1 stated:
GS1 CONTROL ROOM EVACUATION Control Room Evacuated AND Required Evolutions Outside the Control Room NOT Completed Within 15 Minutes The TBD explains that required evolutions refers to actions specified by ONP 525A that must be completed to establish control outside the control room.
The licensee's wording in the EAL is ambiguous and non-descript. The licensee should include the specific actions required to establish control in the EAL or reference the procedure that must be utilized at a minimum.
Correct the wording Tf this EAL or provide justification for this deviation from the NUMARC/NESP-007 guidance.
19.
The NUMARC criteria for HS3-1 states:
1.
Other conditions exist which in the judgement of the Emergency Director indicate actual or likely major failures of plant functions needed for protection of the public.
The equivalent Millstone 1 EAL states:
Any condition which in the SS/DSE0's judgement indicates loss or potential loss of two fission product barriers.
This site-specific EAL is already covered under the fission product barrier EAls and, therefore, is redundant. Contrary to the TBD, this EAL is not I
. consistent with the definition of the Site Area Emergency class in NUREG-0654 or NUMARC/NESP-007. The licensee should reword the judgement EAL to be consistent with the NUMARC guidance and the requirements of Appendix E to 10 CFR Part 50.
20.
The NUMARC criteria for HG2-1 states:
1.
Other conditions exist which in the judgement of the Emergency Director indicate: (1) actual or imminent substantial core degradation with potential for loss of containment, or l2) potential for uncontrolled radiological releases. These releases can reasonably be expected to exceed EPA PAG plume exposure levels outside the site boundary.
The equivalent Millstone 1 EAL stated:
JG1 SS/DSEO JUDGEMENT Any Condition Which in the SS/DSE0's Judgement Indicates Potential for Radiological Releases Requiring Evacuation or Sheltering Offsite A.
The TBD indicates that the EAL addresses the conditions that fall under the General Emergency classification description in NUREG-0654, Appendix 1 that is retained under the NUMARC methodology, however, the licensee failed to include the first argument of the NUMARC example EAL.
B.
The NUMARC guidances calls for declaration of a General Emergency wien releases can be expected to exceed the Environmental Protection Agency'. (EPA)
Protective Action Guides (PAGs) for the plume exposure pathway. The prop' sed o
EAL suggests classification when releases require sheltering offsite.
However, there are no EPA PAGs for sheltering in the plume exposure pathsay.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
NUMARC Recoanition Cateaory S - System Malfunction 21.
The NUMARC criteria for SU3-1 states:
1.
The following conditions exist:
a.
Loss of most or all (site-specific) annunciators associated with safety systems for greater than 15 minutes.
AND d.
Annunciator or Indicator loss does not result from planned action.
The equivalent Millstone 1 EAL stated:
i
. EU3 LOSS OF ANNUNCIATORS Loss of Host (75%) MCB Annunciators > 15 Minutes AND SPDS Available The criteria of NUMARC EAL SU3-1.d. was not included in the Hillstone 1 EAls nor was its absence justified in the basis document.
This deviation was also applicable to Alert EAL EA3. The same criteria of unplanned in NUMARC IC SU6 l
(Loss of Communications) was omitted from the Millstone 1 EAL EU4.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
22.
The NUMARC criteria for Initiating Condition SU5 and EAL SUS-1 states:
SUS RCS Leakage OPERATING MODE APPLICABILITY: POWER OPERATION HOT STANDBY HOT SHUTDOWN 1.
The following conditions exist:
a.
Unidentified or pressure boundary leakage greater than 10 gpm.
OR b.
Identified leakage greater than 25 gpm.
The NUMARC Basis criteria states Only operating modes in which there is fuel in the reactor coolant system and the system is pressurized are specified.
The equivalent Hillstone 1 EAL BU2 stated:
BU2 RCS LEAKAGE MODE: ALL 1.
Unidentified Leakage > 10 GPM 2.
Total RCS Leakage > 35 GPM The TBD stated NUREG-1449 raises concerns regarding accident sequences involving leakage through RCS temporary boundaries. RCS leakage EALs apply to all operating modes at Millstone Unit 1.
This will assure that leakage is appropriately addressed for cold shutdown and refueling modes and address NRC l
concerns about leakage through temporary RCS boundaries as they apply to EAls.
The definition of an Unusual Event (UE) includes the attributes... indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring offsite response or monitoring are expected...
During non-pressurized modes of operations, other NUMARC EALs are designed to address those conditions described by the UE definition. The addition of the Millstone 1 criteria of ALL [ NODES] was a conservatism that is inconsistent
. with the UE definition, inconsistent with the industry, and not justified by the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
23.
The NUMARC example SU7-1 states:
1.
The following conditions exist:
a.
Unplanned loss of vital DC power to required DC busses based on (site-specific) bus voltage indications.
AND b.
Failure to restore power to at least one required DC bus within 15 minutes from the time of loss.
The Millstone 1 equivalent EAL #PU2 stated:
Loss of Voltage on DC Busses 101A and 1018 > 15 min.
The NUMARC criteria specifies that the loss of DC voltage is unplanned.
This EAL applies to cold shutdown and refueling, and planned work that de-energizes the DC busses should not trigger a declaration.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
24.
The NUMARC example SA3-1 states:
1.
The following conditions exist:
a.
Loss of (site-specific) Technical Specification required functions to maintain cold shutdown AND b.
Temperature increase that either:
Exceeds Technical Specification cold shutdown temperature limit OR Results in uncontrolled temperature rise approaching cold shutdown technical specification limit.
The Millstone 1 equivalent IC and EAL stated:
EA2 INABILITY TO HAINTAIN COLD S/D
p
. 1.
Uncontrolled RCS Temperature Increase > 102 F That Results in RCS Temperature 1212*F 2.
Inadvertent Criticality A.
The Millstone 1 EAL did not include the required technical :pecification functions to maintain cold shutdown, however, Standby Liquid Control System, Auxiliary Electrical System, and Core Cooling System were listed and their omission discussed in the TBD. The omission of Auxiliary Electrical System was adequately covered by other EALs; the omission of the shutdown cooling function and subcriticality function was not addressed by other EALs and not justified in the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
B.
The EAL threshold temperature of 2 2128F did not include the anticipatory philosophy related to an uncontrolled temperature rise aooroachina cold shutdown technical specification limit.
Provide the technical specification temperature limit ~ for transition between modes.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
25.
The NUMARC criteria for SAS-1 states:
1.
The following conditions exist: (a and b) a.
Loss of Power to < site-specific > Transformers for Greater Than 15 Minutes.
AND b.
Onsite Power Capability has been Degraded to one (Train of)
Emergency Bus (ses) Powered From a Single Onsite Power Source due to the Loss of:
< site-specific list >
The equivalent Millstone 1 EAL stated:
PA2 SINGLE AC POWER SOURCE Only One AC Power Source Available to Supply Busses 14E And/0r 14F The Millstone 1 EAL omitted the NUMARC criteria that the condition existed for 15 minutes, and did not justify the omission in the TBD. Although this was a conservative deviation, it is inconsistent with the guidance, the industry, and does not take into account transient or momentary conditions.
. Provide justification for this deviation from the NUMARC/NESP-007 guidance.
26.
The NUMARC criteria for Site Area Emergency EAL SS3-1 states:
1.
Loss of All Vital DC Power based on (site-specific) bus voltage indications for greater than 15 minutes.
The equivalent Millstone Alert EAL #PA3 stated:
Loss of Voltage on DC Buses 101A And 101B > 15 Minutes The Millstone 1 TBD justified the deviation from NUMARC criteria with Based on the DC system design and procedural requirements at Millstone Unit 1, this IC meets the threshold for an Alert emergency classification (i.e., potential substantial degradation in the level of safety of the plant with the need for
\\
increased monitoring)... Escalation to a Site Area Emergency under ES4, Loss of Annunciators / Transient, may be appropriate based on transient response to reactor scram, other equipment malfunctions requiring operator actions at local panels outside the Control Room, or loss of additional monitoring instrumentation required to determine plant conditions. The NUMARC Basis Information states that Loss of all DC power compromises ability to monitor and control plant safety functions. The NUMARC EAL seeks to provide anticipatory declaration of a SAE that would ultimately occur as described by the licensee TBD under EAL ES4. Manual operation of numerous protective functions coupled with loss of valve position indication and annunciation
... involve actual or likely major failures of plant functions needed for protection of the public," the definition of a Site Area Emergency (SAE).
Provide additional justification for the deviation from the NUMARC/NESP-007 guidance.
27.
The NUMARC criteria for SS4-1 states:
1.
Complete loss of any (site-specific) function required for hot shutdown.
The equivalent Millstone EAL ES2-1 and -2 stated:
ES2 INABILITY TO MAINTAIN HOT SD 1.
Adequate Core Cooling Conditions Can NOT Be Achieved or Maintained j
2.
Entry Into ONP S18, Inadvertent Criticality, Is Required AND Reactor Can NOT Be Brought Subcritical This concern addresses the same concern as for NUMARC EAL SA3-1, loss of cold shutdown functions.
The NUMARC basis criteria states, This EAL addresses complete loss of functions, including ultimate heat sink and reactivity control, required for hot shutdown... Although the Millstone 1 EAls are symptomatic of complete loss of hot shutdown functions, the EAls did not i
.. possess the' additional required attributes of being " anticipatory" (NUREG-0654 refers).
The TBD listed nine different Technical Specification systems that fulfilled several functions such as core cooling and reactivity control.
However, the TBD did not justify the omission of some functions nor the substitute Millstone 1 EALs in an adequate manner.
For example, the TBD did not show that Entry Into ONP 518... AND Reactor Can NOT Be Brought Suberitical would result in a SAE declaration in the same time as an EAL stating " loss of reactivity control function."
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
28.
Millstone 1 EAL RUl-2 states:
Unexpected Area Rad Monitor Reading Offscale High OR > 1000 Times Normal Reading for > 5 Minutes The TBD explains that unexpected is utilized to discriminate against expected increases due to controlled evolutions. Thus, the criteria for readings existing for > 5 minutes is redundant and inconsistent with the NUMARC guidance. The time limit should be deleted or justification for its inclusion provided.
29.
The NUMARC criteria for loss of fuel clad, based upon coolant activity, states:
Primary Coolant Activity level Coolant activity GREATER THAN (site-specific) value The Millstone 1 equivalent EAL, FCB2-5 states:
Dose Rate at One Foot from Unpressurized RCS Sample h 10 mR/hr/mi.
Regardless of the licensee's development of a unique EAL for assessing fuel clad integrity, the NUMARC example EAL of " coolant activity greater than 300 Ci/cc dose equivalent I-131" should be included in the EAL scheme or its omission justified.
The TBD on page B-13 incorrectly quotes the NUMARC guidance in stating that 300 Ci/cc dose equivalent I-131 corresponds to 5-10% ruel clad damage. This level ccrresponds to 2-5% fuel clad damage and the liv.ensee's EAL thresholds should be adjusted accordingly.
1 i
RE00EST FOR ADDITIONAL INFORMATI0ff CONCERNING NORTHEAST NUCLEAR ENERGY COMPANY MILLSTONE NUCLEAR POWER STATION. UNIT NO. 2 DOCKET NO. 50-331 The NRC has completed its initial review of the proposed emergency action levels (EALs) in the June 1994 Millstone Nuclear Power Station, Unit 2 NUMARC EAL submittal. The submittal included Emergency Plan Implementing Procedure (EPIP) 4400, Event Assessment. Classification. and Reportability (Revision 2, July 31, 1993), the Millstone Unit 2 EALs table (MSI-01, Rev. F, June 1994),
the Millstone Unit 2 Emeraency Action level (EAL) Technical Basis Document (TBD).(NRC Submittal Version, June 1994), and miscellaneous other supporting documentation.
The proposed EALs were reviewed against the guidance in NUMARC/NESP-007, " Methodology for Development of Emergency Action Levels,"
Revision 2.
NUMARC/NESP-007 has been endorsed by the NRC in Regulatory Guide 1.101, " Emergency Planning and Preparedness for Nuclear Power Reactors,"
Revision 3, 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.
Since the staff has previously endorsed 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.
NUMARC Recoanition Cateaory A - Abnormal Rad levels /Radioloaical Effluent 1.
The NUMARC criteria for Initiating Condition (IC) AUl and EAL AUl-1 state:
AU1 Any Unplanned Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds Two Times the Radiological Technical Specifications for 60 Minutes or Longer.
1.
A valid reading on one or more of the following monitors that exceeds the "value shown" (site-specific monitors) indicates that the release may have exceeded the above criterion and indicates the need to assess the release with (site-specific procedure):
(site-specific list) l'ote:
If the monitor reading (s) is sustained for longer than 60 minutes and the required assessments cannot be completed within this period, then the declaration must be made based 1
on the valid reading.
l
o The NUMARC Basis information goes on to state: The term " Unplanned", as used in this context, includes any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit.
The Millstone 2 equivalent EAL stated:
0U1 UNPLANNED RELEASE Unplanned, Unmonitored, or Uncontrolled Offsite Release Within Delta-Two Posture Code Limits As Determined from EPIP 4400, Event Assessment, Classification and Reportability A.
EPIP 4400, Paragraph 4.4.3, required, Refer to and REVIEW Attachment 3,
" Unplanned Radioactive Release Reporting Criteria," for the type of release involved. listed approximately 31 Maintenance Operations that were considered... normal or expected maintenance or operation activities which may increase the release rate of gaseous radioactivity from the plant stack (s).
Paragraph 4.4.4 required that LE it is determined that an unplanned release..., then event evaluation was continued in accordance with the procedure. The " planned" list of releases included items such as:
0.1. Minor valve packing leaks in any radioactive system.
D.2. Minor pump seal leaks in any radioactive system.
D.3. Increased secondary side activity as indicated by increases in the condenser air ejector monitor...
These " planned" items were clearly inconsistent with the intent of the NUMARC guidance related to planed and unplanned releases. Although the Millstone 2 TBD included the NUMARC Basis statement in its discussion, no justification was provided for the deviation from the NUMARC guidance.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
B.
The TBD stated, Reportable releases, in accordance with State of Connecticut Public Act 80-351 are as follows:
A.
Releases Exceedina Technical Soecification limits - Any release, ifquid or gaseous, exceeding Technical Specification Instantaneous Release Rate Limits.
These are determined in accordance with Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM).
B.
Unmonitored Gaseous Releases - Exceeding defined radionuclide release amounts.
C.
Unolanned Gaseous Releases - Any increase in noble gas release rates which, when averaged over 10 minutes, is greater than 1500
i microcuries per second above the normal (existing) release rate and this increase is not due to a planned or expected event.
i D.
Unclanned or Unmonitored Liould Release - Any release exceeding Technical Specification Instantaneous Release Rate Limit or unplanned or unmonitored release for which the Total Activity Released (excluding tritium and dissolved gases) exceeded 100 microcuries.
No valid monitor reading (s) were listed as EAL thresholds in the Millstone 2 tables to support the NUMARC IC. Rather, EPIP 4400, paragraph 4.4.4 required, JF lt is determined that an unplanned release may exceed the limits specified in Attachment 3, COMPLETE the calculations as listed in Attachment 3 for the released material. Attachment 3, Sheet 8 of 11, provided, Unplanned Radioactive Release Reporting Criteria Radionuclide Reportable Quant RQgCl).
Thistablelistedapproximately50 radionuclides,suchasI[t,les-and Fe, with the associated RQ in curies, 0.01 and 10 respectively.
If an isotope, such as tritium, was not listed, the user was referred to 40CFR302.4 for the RQ.
Based on the above, the reviewer concluded the provisions of NUMARC EAL AVI-l were not included in the Millstone scheme and were not justified in the TBD.
That is, provide threshold monitor readings, that if exceeded for 2 60 minutes, and an assessment has not been comoleted, then make a declaration based upon the valid monitor reading. Only " assessment" was provided for by the Millstone 2 scheme.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
1 2.
The NUMARC criteria for IC AAI states:
Any Unplanned Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds 200 Times Radiological Technical Specifications for 15 Minutes or Longer.
The NUMARC Basis information goes on to state:
This event escalates from the Unusual Event by escalating the magnitude of the release by a factor of 100. Prorating the 500 mR/yr criterion..., the associated site boundary dose rate would be 10 mR/yr.
The equivalent Millstone 2 IC and EAL 0Al-5. stated:
0A1 0FFSITE DOSE 5.
Rad Assessment Determines Integrated Dose Offsite 1 0.005 Rem TEDE OR 2 0.025 Rem CDE Thyroid.
A.
Both the Millstone 2 IC and the EAL pertained to off-site consequences, whereas for the Alert classification, the NUMARC criteria refer to site consequences out to the site boundary. This change in affected areas was not
i
- l justified in the TBD. This same concern related to affected area (boundary) was noted in other EALs such as NUMARC AS1 and AGl.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
B.
The TBD, which states that the preferred method for evaluating this It is by use of radiological dose assessment, is inaccurate. The intent of the i
lower emergency class ICs for radiological effluents (Unusual Event and Alert) i is to take actions based upon a loss of control of radioactive material.
Therefore, classification need only be based upon exceeding the associated EAL threshold (s) for greater than 15 minutes, not necessarily a dose assessment of the release. The NUMARC guidance specifically calls for a dose assessment using actual meteorology to determine the consequences of that release and whether or not adverse conditions would escalate the classification or posture code.
The TBD should be revised to reflect the intent of the NUMARC IC.
3.
The NUMARC criteria for AA2-1, 2, 3, and 4 states:
1.
A (site-specific set point) alarm on one or more of the following radiation monitors: (site-specific monitors) 2.
Report of visual observation of irradiated fuel uncovered.
3.
Water Level less than (site-specific) feet for the Reactor Refueling Cavity that will result in irradiated fuel uncovering.
4.
Water level less than (site-specific) feet for the Spent Fuel Pool and Fuel Transfer Canal that will result in irradiated fuel uncovering.
The NUMARC basis guidance goes on to state: Each site should also define its EAls by the specific area where irradiated fuel is located such as Reactor Cavity, Reactor Vessel, or Spent Fuel Pool.
The Millstone 2 equivalent EALs stated:
1.
Spent Fuel is Exposed from Open Vessel, Cavity or SF Pool AND Spent Fuel Has Decayed 2 30 Days 2.
Report of Fuel Handling Accident Causing Visible Damage to Any Spent Fuel Assembly 3.
Spent Fuel Pool or Containment Area Rad Monitors Indicate Spent Fuel Damage or Uncovery The Millstone 2 EAls lack the soecificity in regard to which radiation monitors and specific setpoints, and location and water level form the
J-e thresholds suggested by the NUMARC guidance. The TBD was silent on the j
omitted criteria.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
4.
The NUMARC criteria for AA-3 states:
1.
Valid (site-specific) radiation monitor readings GREATER THAN 15 mR/hr in areas requiring continuous occupancy to maintain plant safety functions:
t (Site-specific) Ifst 2.
Valid (site-specific) radiation monitor readings GREATER THAN < site-specific > values in areas requiring infrequent access to maintain plant safety functions:
(Site-specific) list The Millstone 2 equivalent Initiating Condition and EAL stated:
RA2 PLANT RADIATION Dose Rates Prevent Occupancy Or Access to Areas Needed for Safe Shutdown The Millstone 2 EAL scheme included a table of AREAS OF CONCERN FOR SAFE SNUTDOWN that included locations such as the Control Room, Charging Pump l
Cubicles, and Containment. However, the Millstone 2 EAL lacked the specificity in regard to which radiation monitors, specific setpoints, and the area requiring continuous or infrequent access are EAL thresholds.
The TBD justified the Millstone 2 EAL with, According to the UFSAR, the control room is designed to allow control of the plant during all modes of operation, and can be occupied under all credible accidents. All the Engineered Safety Features and supporting systems can be operated from the control room. Thus, continuous occupancy of the areas in which this equipment is located is not required.
Therefore, the Millstone 2 EAL addresses event sequences that are outside the plant design basis resulting in high radiation in areas requiring personnel access to achieve or maintain safe shutdown. The emergency plan should address the full spectrum of reactor accidents, not just the FSAR
" credible" accidents.
Furthermore, the subject of areas requiring infrequent access was not addressed by this EAL nor the TBD.
J Provide justification for these deviations from the NUMARC/NESP-007 guidance.
5.
The NUMARC criteria for Initiating Condition ASI and EAL ASI-4 state:
Boundary Dose Resulting from an Actual or imminent Release of Gaseous Radioactivity that Exceeds 100 mR Whole Body or 500 mR Child Thyroid for the Actual or Projected Durstion of the Release.
I
i 4.
Field survey results indicate site boundary dose rates exceeding 100 mR/hr expected to continue for more than one hour; or analyses of field survey samples indicate child thyroid dose commitment of 500 mR for one hour of inhalation.
The equivalent Millstone 2 IC and EAL stated:
051 0FFSITE DOSE 4.
Measured Plume Dose Rate Onsite 1 50 mR/hr for > 15 Minutes (Without Rad Assessment) 5.
Rad Assessment Determines Integrated Dose Offsite 2 0.05 Rem TEDE OR 2 0.25 Rem CDE Thyroid A.
The specificity of the NUMARC criteria with respect to the location of the measured or assessed doses was not incorporated into the Millstone 2 EAls, i.e., at the site boundary vs. onsite or offsite, nor was the deviation justified in the TBD.
B.
NUMARC criteria regarding field survey results include expected to continue for more than one hour. This criteria was not incorporated into the Millstone 2 Eats nor was the deviation justified in the TBD.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
6.
The NUMARC criteria for Initiating Condition AG1 states:
Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity that Exceeds 1000 mR Whole Body or 5000 mR Child Thyroid for the Actual or Projected Duration of the Release Using Actual Meteorology.
The equivalent Millstone 2 IC and EAL stated:
OG1 0FFSITE DOSE 5.
Rad Assessment Determines Integrated Dose Offsite 21 Rem TEDE OR 25 Rem CDE Thyroid Absent from the Millstone 1 IC and the supporting EAL was the NUMARC criteria of Using Actual Neteorology. The TBD stated the declaration would be based upon EPOP 4431, Radiological Dose Assessment, but did not indicate whether the i
procedure required the use of actual meteorology.
Provide justification for the deviation from the NUMARC/NESP-007 guidance.
NUMARC Recoanition CateaorY F - Fission Product Barrier Dearadation 7.
The NUMARC criteria for the Fuel Clad Barrier Example EAL #2 states.
i
. LOSS L Primary Coolant Activity Level Coolant Activity GREATER THAN
\\
(site-specific) value The NUMARC Basis criteria goes on to state This (site-specific) value corresponds to 300 pCi/cc I, equivalent. Assessment by the NUMARC EAL Task Forceindicatesthatthisa1l$untofcoolantactivityiswellabovethat expected for iodine spikes and corresponds to about 2% to 5% fuel clad damage.
The equivalent Millstone 2 EAL #FCB3 stated:
LOSS Dose Rate at One Foot From Unpressurized RCS Sample 128 mR/hr/ml The Millstone 2 TBD justified the EAL threshold with The site specific value for a RCS sample reading was determined by calculating various coolant I-131^
DEQ concentrations postulated to result from 5% fuel clad failure at Millstone 2.
The calculation... determines the I-131 concentration... using assumptions in NUREG-1465.
The sample reading corresponding to this concentration was then determined using NU Radiological Assessment methodology...
These values are:
= 28 mR/hr/m1 at i foot from an unpressurized sample, using the maximum I-131 DEQ of 1000 pCf/cc (minimum coolant volume)
- 3.6 mR/hr/ml at 1 foot from an unpressurized sample, using the minimum I-131 DEQ of 128 pCl/cc (maximum coolant volume)
The higher value was selected.
It is also reasonable because inadequate core cooling scenarios are the conditions of interest.
This means that there is no or minimal ECCS injection.
Thus assuming minimum coolant volume is appropria te.
The Millstone 2 EAL was based on two non-conservative assumptions in the calculation: 1) the high end of the fuel clad damage band prescribed by NUMARC (5% vs 2%), and 2) assuming the minimum coolant volume, thus maximum concentration.
Since fuel damage accident scenarios can be postulated that do not occur without the significant loss of coolant assumed in the Millstone 2 calculation, and the resulting 1000 pCi/cc concentration is inconsistent with the balance of the industry, the licensee's EAL deviates significantly from the NUMARC guidance without adequate justification. Also, the licensee's development of a unique EAL for assessing the integrity of the fuel clad barrier does not justify the omission of a site-specific EAL corresponding directly to " coolant sample activity greater than 300 pCi/cc dose equivalent I-131."
. Provide justification for the deviation from the NUMARC/NESP-007 guidance and include an EAL that corresponds directly with the NUMARC example.
8.
The NUMARC criteria for the RCS Barrier Example EAL #5 states:
POTENTIAL LOSS L Other (Site-Soecific) Indications (Site-Specific) as applicable The equivalent Millstone 2 EAL RCB3 stated:
POTENTIAL LOSS Decreasing RCS Pressure With Abnormal Conditions in CTMT The TBD stated that The " potential loss" EAL addresses initial symptoms of RCS leakage....This corresponds to indications of decreasing RCS pressure with abnormally high containment temperature, pressure, or humidity.
A.
All other EALs of similar structure in the Milistone 2 scheme use the terminoiogy Uncontrolled [RCS Cooldown] vs Decreasing, where Uncontrolled was defined as Condition is not the result of planned actions by the plant staff.
B.
Other EALs use the structure AND for coincident conditions rather than With.
C.
Abnormal Conditions [in CTNT) was not included in the 11st of definitions, and bounding values were not included in the TBD.
Human engineered, model EALs are user friendly. This M111 stone 2 EAL was inconsistent with the desired attributes in that it was not consistent and not objective.
Provide justification for'this deviation from the NUMARC/NESP-007 guidance.
9.
The NUMARC criteria for the Primary Containment Barrier Example EAL #2 states:
POTENTIAL LOSS L Containment Pressure (Site-Specific) PSIG and increasing OR
.r Explosive mixture exists.
OR i
A Containment pressure greater than containment depressurization system setpoint with less than one full train of depressurization equipment operating.
The equivalent Millstone 2 EAL #CNB2 stated:
POTENTIAL LOSS CTHT Pressure k 54 PSIG AND Increasing CTNT H Concentration 2 4%
g The NUMARC criteria of inoperative depressurizatilon equipment appeared to be omitted from the Millstone 2 scheme. The TBD stated... containment integrity is maintained following the design basis..LOCA.. by utilizing two containment spray subsystems in combination with two containment air recirculation (CAR) and cooling units. Although these equipments would function as depressurization system [s], their loss was not an EAL threshold, nor was the absence of the EAL justified in the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
10.
The NUMARC criteria for the Primary Containment Barrier Example EAL #4 states:
LOSS L SG Secondary Side Release With Primary-to-Secondary Leakace Release of secondary side to atmosphere with primary to secondary leakage GREATER THAN tech spec allowable The equivalent Millstone 2 EAL #CNB3 stated:
SG Tube Rupture in Progress AND Release to the Environment > 15 Minutes The TBD stated Of chief concern for this EAL are steam generator tube rupture sequences resulting in prolonged releases to the environment. Prolonged releases could be the result of a large primary-to-secondary flow rapidly increasing ruptured steam generator water level...
The TBD goes on to state
... larger spectrum tube ruptures.. that require tripping the reactor coolant pumps require twenty minutes to cool down the plant and terminate releases to the atmosphere...
Therefore, a threshold of 15 minutes for release to the atmosphere from the ruptured SG is chosen as the discriminator for this EAL.
The NUMARC EAL is structured to result in a declaration for the full spectrum of steam generator tube ruptures, i.e., a small break resulting in an Unusual Event to large rupture resulting in a Site Area Emergency.
Further, the NUMARC EAL does not include a threshold of time for the bypass condition to exist. The Millstone 2 EAL did not reflect these attributes, and the TBD justification appeared erroneous in its evaluation of the NUMARC EAL.
. Provide justification for this deviation from the NUMARC/NESP-007 guidance.
11.
The NUMARC criteria for the Primary Containment Barrier Example EAL #7 states:
Z, Other (Site-Soecific) Indications (Site-Specific) as applicable The NUMARC Basis information stated This EAL should cover other (site-specific) indications that may unambiguously indicate loss or potential loss of the containment barrier, including indications from area or ventilation monitors...
If site emergency operating procedures provide for venting of the containment during an emergency.., a loss EAL should be included...
No equivalent Millstone 2 EALs were included.
The M111 stone 2 TBD stated A number of indications were considered for the generic "Other Conditions" CTHf EAls at M111stane 2.
In order to provide clear, unambiguous guidance to the Shift Supervisor, the Millstone 2 EALs are written to be consistent with the E0Ps. Notwithstanding this statement, no "Other" EALs appeared to be included. The TBD did not make a statement that no "other" indications were available, nor did the TBD confirm that containment venting under all accident conditions was not applicable.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
NUMARC Recoanition Cateaory H - Hazards and Other Conditions Affectina Plant Safety 12.
The NUMARC criteria for EAL HU2-1 states:
1.
Fire in buildings or areas contiguous to any of the following (site-specific) areas not extinguished within 15 minutes of control room notification or verification of a control room alarm:
(Site-specific) list
=
The equivalent Millstone 2 EAL GUI stated:
~
Fire Within an Area Containing Safe Shutdown Equipment > 15 Minutes The Millstone 2 EAL was written in a less conservative manner than the NUMARC criteria in that the event was described as within vital areas, whereas the NUMARC criteria is more anticipatory with in buildings or areas contiguous to vital areas. This non-conservative deviation was not justified in the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
13.
The NUMARC criteria for EAL HU4-2 states:
- m
. 2.
Other security events as determined from (site-specific) Safeguards Contingency Plan.
There was no equivalent Millstone 2 EAL and the omission was not justified in the TBD. This also applied to NUMARC EAL HA4-2 and HSI-2 but will not be separately commented on.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
14.
The NUMARC criteria for EAL HAl-2 states:
2.
Tornado or high winds striking plant vital areas: Tornado or high winds greater than (site-specific) aph strike within protected area boundary.
The equivalent Millstone 2 EAL stated:
2.
On-Site Sustained Windspeed > 90 MPH The NUMARC criteria of a tornado event, which may not be measured by anemometers, was omitted from the Millstone 2 EAL, and not justified in the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
15.
The NUMARC criteria for EAL HAl-3 states:
3.
Report of any visible structural damage on any of the following plant structures:
Reactor Building Intake Building Ultimate Heat Sink Refueling Water Storage Tank Diesel Generator Building Turbine Building Condensate Storage Tank Control Room Other (Site-Specific) Structures The equivalent Hillstone 2 Alert EAL #TA2-3 stated:
3.
Report to Control Room of Damage Affecting Safe Shutdown Another EAL (#TV2-3) addressed the same subject, but was included in the Unusual Event, Destructive Phenomena category as follows:
3.
Visible damage to Structures or Equipment Required for Safe Shutdown 4
. The Millstone 2 Alert EAL was non-conservative and inconsistent with the j
NUMARC criteria in that the EAL implied assessment by field and/or control room personnel. Thus the anticipatory nature of the NUMARC EAL was lost. The Hillstone 2 Unusual Event EAL more closely reflected the intent of the NUMARC Alert criteria. These deviations from the NUMARC criteria were not justified in the TBD.
1 Provide justification for this deviation from the NUMARC/NESP-007 guidance.
16.
The NUMARC criteria for EAL HAl-6 states:
6.
Turbine failure generated missiles result in any visible structural damage to or penetration of any of the following plant areas: (site-specific) list.
The equivalent Millstone 2 EAL #TA2-5 stated-S.
Missiles Affecting Safe Shutdown NUMARC provided additional guidance in the basis information: EAL 6 is intended to address the threat to safety related equipment imposed by missiles generated by main turbine rotating component failures.
This (site-specific) list of areas should include all areas containing safety-related equipment, their controls, and their power supplies. Three concerns were noted with this EAL:
A.
" Missiles" has a far broader meaning than was intended by this NUMARC EAL that is addressed by HAl-5.
B.
The specificity of contemporaneous damage reflected in the NUMARC Basis Information was not addressed by the Millstone EAL nor its absence justified in the TBD.
C.
The related Unusual Event (TV2-6) stated: Turbine Failure Causing Observable Casing Damage. The use of different terminology, i.e., " turbine" and " missiles" could potentially be confusing in making a classification.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
17.
The NUMARC EAL examples HA3-1 and 2 state:
1.
Report or detection of toxic gases within a Facility Structure in concentrations that will be life threatening to plant personnel.
2.
Report or detection of flammable gases within a Facility Structure in concentrations that will affect the safe operation of the plant.
The Hillstone 2 equivalent EAL #GA3 stated:
Toxic or Flammable Gas Making Vital Areas Uninhabitable Or Inaccessible
.. The licensee did not reference or provide measurable criteria to the emergency director for establishing concentrations that affect safe operation of the plant. Without such information, i.e., "When have life threatening and flammable concentration thresholds been exceeded?", readily available, classification would be difficult.
Furthermore, the EAL scheme utilized the concept of Areas of Concern for Safe Shutdown for all other EALs, whereas this EAL used the concept of Vital Areas which were undefined by the procedure.
This inconsistency was not in accordance with NUMARC guidance for model EALs.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
18.
The NUMARC criteria for IC HAS and EAL HAS-1 states:
Control Room Evacuation Has Been Initiated.
1.
Entry into (site-specific) procedure for control room evacuation.
The equivalent Millstone 2 IC and EAL # gal stated:
GA1 CONTROL ROOM EVACUATION Control Room Evacuated Per Unit Procedure Or SS Judgement D
The NUMARC criteria reflects a declaration when control room evacuation is initiated, whereas the Millstone 2 EAL was stated in the past tense, control room evacuated. The time difference was not intended with the NUMARC IC, and was not justified in the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
19.
The NUMARC criteria for HS3-1 states:
1.
Other conditions exist which in the judgement of the Emergency Director indicate actual or likely major failures of plant functions needed for protection of the public.
The equivalent Millstone 2 EAL states:
Any condition which in the SS/DSE0's judgement indicates loss or potential loss of two fission product barriers.
This site-specific EAL is already covered under the fission product barrier EALs and, therefore, is redundant.
Contrary to the TBD, this EAL is not consistent with the definition of the Site Area Emergency class in NUREG-0654 or NUMARC/NESP-007.
The licensee should reword the judgement EAL to be consistent with the NUMARC guidance and the requirements of Appendix E to 10 CFR Part 50.
20.
The NUMARC criteria for HG2-1 states:
. l 1.
Other conditions exist which in the judgement of the Emergency Director indicate: (1) actual or imminent substantial core degradation with potential for loss of containment, or (2) potential for uncontrolled radiological releases.
These releases can reasonably be expected to exceed EPA PAG plume exposure levels outside the site boundary.
The equivalent Hillstone 2 EAL stated:
JG1 SS/DSE0 JUDGEMENT Any Condition Which in the SS/DSE0's Judgement Indicates Potential for Radiological Releases Requiring Evacuation or Sheltering Offsite A.
The TBD indicates that the EAL addresses the conditions that fall under the General Emergency classification description in NUREG-0654, Appendix 1 that is retained under the NUMARC methodology, however, the licensee failed to include the first argument of the NUMARC example EAL.
B.
The NUMARC guidances calls for declaration of a General Emergency when releases can be expected to exceed EPA's PAGs for the plume exposure pathway.
The proposed EAL suggests classification when releases require sheltering offsite. However, there are no EPA PAGs for sheltering in the plume exposure pathway.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
NUMARC Recoanition Cateaory S - System Malfunction 21.
The NUMARC criteria for SU3-1 states:
1.
The following conditions exist:
a.
Loss of most or all (site-specific) annunciators associated with safety systems for greater than 15 minutes.
AND d.
Annunciator or Indicator loss does not result from planned action.
The equivalent Millstone 2 EAL stated:
EU3 LOSS OF ANNUNCIATORS Loss of Most (75%) MCB Annunciators > 15 Minutes AND SPDS Or ICC Cabinet Available
. The threshold of NUMARC EAL SU3-1.d., i.e., not... planned action, was not included in the Millstone 2 EAls nor was its absence justified in the basis document. This deviation was also applicable to Alert EAL EA3. The same concern of unplanned in NUMARC Initiating Condition SU6 (Loss of Communications) was omitted from the Millstone 2 EAL EU4.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
22.
The NUMARC criteria for Initiating Condition SU5 and EAL SUS-1 states:
SU5 RCS Leakage OPERATING MODE APPLICABILITY: POWER OPERATION HOT STANDBY HOT SHUTDOWN 1.
The following conditions exist:
a.
Unidentified or pressure boundary leakage greater than 10 gPa.
OR b.
Identified leakage greater than 25 gpm.
The NUMARC Basis criteria states Only operating modes in which there is fuel in the reactor coolant system and the system is pressurized are specified.
The equivalent Millstone 2 EAL BU2 stated:
BU2 RCS LEAKAGE MODE: ALL 1.
Pressure Boundary leakage > 10 GPM 2.
Unidentified Leakage > 10 GPM 3.
Identified Leakage > 25 GPM The TBD stated NUREG-1449 raises concerns regarding accident sequences involving leakage through RCS temporary boundaries. RCS leakage EALs apply to all operating modes at Millstone 2.
This will assure that leakage is appropriately addressed for cold shutdown and refueling modes and address NRC concerns about leakage through temporary RCS boundaries as they apply to EALs.
The definition of an Unusual Event (UE) includes the attributes... indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring offsite response or monitoring are expected...
During non-pressurized modes of operations, other NUMARC EALs are designed to address those conditions described by the UE definition. The addition of the Millstone 2 criteria of ALL [ MODES] was a conservatism that is inconsistent with the UE definition, inconsistent with the industry, and not justified by the TBD.
. Provide justification for this deviation from the NUMARC/NESP-007 guidance.
23.
The NUMARC example SU7-1 states:
1.
Either of the following conditions exist:
a.
Unplanned loss of vital DC power to required DC busses based on (site-specific) bus voltage indications.
AND b.
Failure to restore power to at least one required DC bus within 15 minutes from the time of loss.
The Millstone 2 equivalent EAL #PU2 stated:
L Loss of Voltage on DC Busses 201A and 2018 > 15 min.
The NUMARC criteria specifies that the loss of DC voltage is unplanned. This EAL applies to cold shutdown and refueling, and planned work that de-energizes the DC busses should not trigger a declaration.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
24.
The NUMARC criteria for SAS-1 states:
1.
The following conditions exist: (a and b) a.
Loss of Power to < site-specific > Transformers for Greater Than 15 Minutes.
AND b.
Onsite Power Capability has been Degraded to one (Train of)
Emergency Bus (ses) Powered From a Single Onsite Power Source due to the Loss of:
< site-specific list >
The equivalent Millstone 2 EAL stated:
PA2 SINGLE AC POWER SOURCE Cnly One AC Power Source Available to Supply Busses 24C And/0r 24D The Millstone 2 EAL omitted the NUMARC criteria that the condition existed for 15 minutes, and did not justify the omission in the TBD. Although this was a conservative deviation, it is inconsistent with the guidance, the industry, and does not take into account transient or momentary conditions.
3 m
i i Provide justification for this deviation from the NUMARC/NESP-007 guidance.
25.
The NUMARC criteria for Site Area Emergency EAL SS3-1 states:
1.
Loss of All Vital DC Power based on (site-specific) bus voltage
)
indications for greater than 15 minutes.
The equivalent Millstone 2 Alert EAL #PA3 stated:
Loss of Voltage on DC Buses 201A And 2018 > 15 Minutes The Millstone 2.TBD justified the deviation from NUMARC criteria with Reactor
)
protection and vital instrumentation is not directly affected on the loss of DC. At most, the diesel generators would be unable to start, some emergency lighting would be unavailable, and the turbine driven auxiliary feedwater pump (Terry turbine) would be required to be operated by manual operation of the stop valve, feed regulating valves, and governor speed control.
Therefore, for Millstone 2, loss of DC meets the threshold for an Alert emergency classification. The NUMARC Basis Information states that Loss of all DC power i
compromises ability to monitor and control plant safety functions. The NUMARC EAL seeks to provide anticipatory declaration of a SAE that would ultimately occur as described by the licensee TBD under EAL ES4, Loss of Annunciators / Transient or PSI, Station Blackout. Manual operation of.
protective functions coupled with loss of valve position indication and annunciation "... involve actual or likely major failures of plant functions needed for protection of the public", the definition of a Site Area Emergency.
Provide additional information concerning the source of control power for engineered safety features.
Provide additional justification for the deviation from the NUMARC/NESP-007 guidance.
26.
The NUMARC criteria for SS4-1 states:
1.
Complete loss of any (site-specific) function required for hot shutdown.
The equivalent Millstone 2 EAL ES2-1 and -2 stated:
ES2 INABILITY TO MAINTAIN HOT SD 1.
No RCS Heat Removal Method Meets SFSC Criteria AND Shutdown Cooling
^
is NOT in Service i
2.
RCS Boration Capability Unable to Eliminate Inadvertent Criticality The NUMARC basis criteria states, This EAL addresses complete loss of functions, including ultimate heat sink and reactivity control, required for i
hot shutdown... Although the Millstone 2 EALs are symptomatic of complete 1
loss of hot shutdown functions, the EALs did not possess the additional 1
I :
required attributes of being " anticipatory" (NUREG-0654 refers).
The TBD listed 13 different Technical Specification systems that fulfilled several functions such'as core cooling and reactivity control. However, the TBD did not justify the omission of some functions nor the substitute Millstone 2 EALs in an adequate manner.
For example, the TBD did not show that RCS Boration Capability Unable to Eliminate Inadvertent Criticality would resuit in a SAE declaration in the same time as an EAL stating " loss of reactivity control function".
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
27.
Millstone 2 EAL RU1-2 states:
Unexpected Area Rad Monitor Reading Offscale High OR > 1000 Times Normal Reading for > 5 Minutes The TBD explains _that unexpected is utilized to discriminate against expected increases due to controlled evolutions. Thus, the criteria for readings existing for > 5 minutes is redundant and inconsistent with the NUMARC guidance. The time limit should be deleted or justification for its inclusion provided.
1 i
d' 1
l
RE0 VEST FOR ADDITIONAL INFORMATION CONCERNING NORTHEAST NUCLEAR ENERGY COMPANY MILLSTONE NUCLEAR POWER STATION. UNIT NO. 3 DOCKET NO. 50-423 The NRC has completed its initial review of the proposed emergency action levels (EAls) in the June 1994 Millstone Nuclear Power Station, Unit 3 NUMARC.
EAL submittal.
The submittal included Emergency Plan Implementing Procedure (EPIP) 4400, Event Assessment. Classification. and Reoortability (Revision 2, July 31, 1993), the Millstone Unit 3 Emergency Action Levels table (MSI-01, Rev. F, June 1994), the Millstone Unit 3 Emeroency Action Level (EAL)
Technical Basis Document (TBD) (NRC Submittal Version, June 1994), and miscellaneous other supporting documentation. The proposed EALs were reviewed against the guidance in NUMARC/NESP-007, " Methodology for Development of Emergency Action Levels," Revision 2.
NUMARC/NESP-007 has been endorsed by the NRC in Regulatory Guide 1.101, " Emergency Planning and Preparedness for Nuclear Power Reactors," Revision 3, 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.
Since the staff has previously endorsed the guidance in NUMARC/NESP-007, the review focused on those EAls that deviated from the guidance and those EALs i
that required the development of site-specific thresholds. As a result of the j
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.
NUMARC Recoanition Cateaory A - Abnormal Rad Levels /Radioloaical Effluent 1.
The NUMARC criteria for Initiating Condition (IC) AU1 and EAL AU1-1 state:
AU1 Any Unplanned Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds Two Times the Radiological Technical Specifications for 60 Minutes or Longer.
1.
A valid reading on one or more of the following monitors that exceeds the "value shown" (site-specific monitors) indicates that the release may have exceeded the above criterion and indicates the need to assess the release with (site-specific procedure):
(site-specific list)
Note:
If the monitor reading (s) is sustained for 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.
i
d
. The NUMARC Basis information goes on to state: The term " Unplanned", as used in this context, includes any release for which a radioactive discharge permit was not prepared, or a release that exceeds the conditions (e.g., minimum dilution flow, maximum discharge flow, alarm setpoints, etc.) on the applicable permit.
The Millstone 3 equivalent EAL stated:
0U1 UNPLANNED RELEASE Unplanned, Unmonitored, or Uncontrolled Offsite Release Within Delta-Two Posture Code Limits As Determined from EPIP 4400, Event Assessment, Classification and Reportability A.
EPIP 4400, Paragraph 4.4.3, required, Refer to and REVIEW Attachment 3,
" Unplanned Radioactive Release Reporting Criteria," for the type of release involved. Attachment 3 listed approximately 31 Maintenance Operations that were considered... normal or expected maintenance or operation activities which may increase the release rate of gaseous radioactivity from the plant stack (s).
Paragraph 4.4.4 required that JE it is determined that an unplanned release..., then event evaluation was continued in accordance with the procedure. The " planned" list of releases included items such as:
D.1. Minor valve packing leaks in any radioactive system.
D.2. Minor pump seal leaks in any radioactive system.
D.3. Increased secondary side activity as indicated by increases in the condenser air ejector monitor...
These " planned" items were clearly inconsistent with the intent of the NUMARC guidance related to planned and unplanned releases. Although the Millstone 3 TBD included the NUMARC Basis statement in its discussion, no justification was provided for the deviation from the NUMARC guidance.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
B.
The TBD stated, Reportable releases, in accordance with State of Connecticut Public Act 80-351 are as follows:
A.
Releases Exceedina Technical Soecification Limits. - Any release, liquid or gaseous, exceeding Technical Specification Instantaneous Release Rate Limits. These are determined in accordance with Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM).
B.
Unmonitored Gaseous Releases - Exceeding defined radionuclide release amounts.
C.
Unolanned Gaseous Releases - Any increase in noble gas release rates which, when averaged over 10 minutes, is greater than 1500
. microcuries per second above the normal (existing) release rate and this increase is not due to a planned or expected event.
D.
Unolanned or Unmonitored Liould Release - Any release exceeding Technical Specification Instantaneous Release Rate Limit or unplanned or unmonitored release for which the Total Activity Released (excluding tritium and dissolved gases) exceeded 100 microcuries.
No valid monitor reading (s) were listed as EAL thresholds in the Millstone 3 tables equivalent to the NUMARC IC. Rather, EPIP 4400, paragraph 4.4.4 required, JE it is determined that an unplanned release may exceed the limits specified in Attachment 3, COMPLETE the calculations as listed in Attachment 3 for the released material. Attachment 3, Sheet 8 of 11, provided, Unplanned Radioactive Release Reporting Criteria RadionuclideReportableQuantitigs-RQ (Cig.
This table listed approximately fifty radionuclides, such as I '
and Fe, with the associated RQ in curies, 0.01 and 10 respectively.
If an isotope, such as tritium, was not listed, the user was referred to 40 CFR 302.4 for the RQ.
Based on the above, the reviewer concluded the provisions of NUMARC EAL AU1-1 were not included in the Millstone scheme and were not justified in the TBD.
That is, provide threshold monitor readings, that if exceeded for 160 minutes, and an assessment has not been completed, then make a declaration based upon the valid monitor reading. Only " assessment" was provided for by the M111 stone 3 scheme.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
2.
The NUMARC criteria for Initiating Condition (IC) AA1 states:
Any Unplanned Release of Gaseous or Liquid Radioactivity to the Environment that Exceeds 200 Times Radiological Technical Specifications for 15 Minutes or Longer.
The NUMARC Basis information goes on to state:
This event escalates from the Unusual Event by escalating the magnitude of the release by a factor of 100. Prorating the 500 mR/yr criterion..., the associated site boundary dose rate would be 10 mR/yr.
The equivalent Millstone 3 IC and EAL 0Al-5. stated:
OA1 0FFSITE DOSE 5.
Rad Assessment Determines Integrated Dose Offsite h 0.005 Rem TEDE OR 2 0.025 Rem CDE Thyroid.
A.
Both the Millstone 3 IC and the EAL pertained to off-site consequences, whereas for the Alert classification, the NUMARC criteria refer to site
l i
_4_
consequences out to the site boundary. This change in affected areas was not justified in the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
B.
The TBD, which states that the preferred method for evaluating this IC is by use of radiological dose assessment, is inaccurate. The intent of the lower emergency class ICs for radiological effluents (Unusual Event and Alert) is to take actions based upon a loss of control of radioactive material.
Therefore, classification need only be based upon exceeding the associated EAL threshold (s) for greater than 15 minutes, not necessarily a dose assessment of the release. The NUMARC guidance specifically calls for a dose assessment using actual meteorology to determine the consequences of that release and whether or not adverse conditions would escalate the classification or posture code.
The TBD should be revised to reflect the intent of the NUMARC IC.
3.
The NUMARC criteria for AA2-1, 2, 3, and 4 states:
1.
A (site-specific set point) alarm on one or more of the following radiation monitors: (site-specific monitors)
Refuel Floor Area Radiation Monitor Fuel Handling Building Ventilation Monitor Fuel Bridge Area Radiation Monitor 2.
Report of visual observation of irradiated fuel uncovered.
3.
Water Level less than (site-specific) feet for the Reactor Refueling Cavity that will result in irradiated fuel uncovering.
4.
Water level less than (site-specific) feet for the Spent Fuel Pool and Fuel Transfer Canal that will result in irradiated fuel uncovering.
The NUMARC basis guidance goes on to state: Each site should also define its EAls by the specific area where irradiated fuel is located such as Reactor Cavity, Reactor Vessel, or Spent Fuel Pool.
The Millstone 3 In-Plant Radiation category equivalent IC and EAls stated:
RA1 SPENT FUEL ASSEMBLY DAMAGE 1.
Spent Fuel is Exposed from Open Vessel, Cavity or SF Pool AND Spent Fuel Has Decayed 1 30 Days 2.
Report of Fuel Handling Accident Causing Visible Damage to Any Spent Fuel Assembly
. 3.
Fuel Building or Containment Area Rad Monitors Indicate Spent Fuel Damage or Uncovery The Millstone 3 EAls lacked the specificity in regard to which radiation monitors and specific setpoints, and location and water level form the thresholds suggested by the NUMARC guidance.
The TBD was silent on the omitted criteria.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
4.
The NUMARC criteria for AA-3 states:
1.
Valid (site-specific) radiation monitor readings GREATER THAN 15 mR/hr in areas requiring continuous occupancy to maintain plant safety functions:
(Site-specific) list 2.
Valid (site-specific) radiation monitor readings GREATER THAN < site-specific > values in areas requiring infrequent access to maintain plant safety functions:
(Site-specific) list The Millstone 3 equivalent IC and EAL stated:
RA2 PLANT RADIATION Dose Rates Prevent Occupancy Or Access to Areas Needed for Safe Shutdown The Millstone 3 EAL scheme included a table of AREAS OF CONCERN FOR SAFE SHUTDOVN that included locations such as the Control Building, Auxiliary Building, and Containment Building.
However, the Millstone 3 EAL lacked the specificity in regard to which radiation monitors, specific setpoints, and the area requiring continuous or infrequent access are EAL thresholds. The TBD justified the Millstone 3 EAL with, Acccrding to the UFSAR, the control room is designed to allow control of the plant during all modes of operation, and can be occupied under all credible accidents. All the Engineered Safety Features and supporting systems can be operated from the control room.
- Thus, continuous occupancy of the areas in which this equipment is located is not l
required.
Therefore, the Millstone 3 EAL addresses event sequences that fall outside the design basis resulting in high radiation in areas requiring I
personnel access to achieve or maintain safe shutdown. The emergency plan should address the full spectrum of reactor accidents, not just the FSAR
" credible" accidents.
Furthermore, the subject of areas requiring infrequent access was not addressed by this EAL nor the TBD.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
5.
The NUMARC criteria for Initiating Condition AS1 and EAL ASI-4 state:
. Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity that Exceeds 100 mR Whole Body or 500 mR Child Thyroid for the Actual or Projected Duration of the Release.
4.
Field survey results indicate site boundary dose rates exceeding 100 mR/hr expected to continue for more than one hour; or analyses of field survey samples indicate child thyroid dose commitment of 500 mR for one hour of inhalatfon.
The equivalent Millstone 3 IC and EAL stated:
OS1 0FFSITE DOSE 5.
Measured Plume Dose Rate Onsite 2 50 mR/hr for > 15 Minutes Without Rad (Assessment) 6.
Rad Assessment Determines Integrated Dose Offsite k 0.05 Rem TEDE OR k 0.25 Rem CDE Thyroid A.
The specificity of the NUMARC criteria with respect to the location of the measured or assessed doses was not incorporated into the Millstone 3 EALs, i.e., at the site boundary vs. onsite or offsite, nor was the deviation justified in the TBD.
B.
NUMARC criteria regarding field survey results include expected to continue for more than one hour. This criteria was not incorporated into the "iilstene 3 EALs nor was the deviation justified in the TBD.
Both of these deviations applied to NUMARC criteria AGl also, but will not be separately commented on.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
6.
The NUMARC criteria for IC AG1 states:
Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity that Exceeds 1000 mR Whole Body or 5000 mR Child Thyroid for the Actual or Projected Duration of the Release Using Actual Meteorology.
The equivalent Millstone 3 IC and EAL stated:
OG1 0FFSITE DOSE 6.
Rad Assessment Determines Integrated Dose Offsite 21 Rem TEDE OR 15 Rem CDE Thyroid Absent from the Millstone 1 IC and the supporting EAL was the NUMARC criteria of using Actual Neteorology. The TBD stated the declaration would be based
. upon EPOP 4431, Radiological Dose Assessment, but did not indicate whether the procedure required the use of actual meteorology.
Provide justification for the deviation from the NUMARC/NESP-007 guidance.
14UMARC Recocnition Cateaory F - Fission Product Barrier Dearadation 7.
The NUMARC criteria for the Fuel Clad Barrier Example EAL #1 states:
POTENTIAL LOSS L Critical Safety Function Status
... Heat Sink-RED The equivalent Millstone 3 EAL states:
FCB1 Status Trees Heat Sink - RED And BOTH of the following:
= Required Feedwater Flow Can NOT Be Established Within 15 Minutes
- RCS Feed and Bleed Can NOT Be Established The licensee has included additional criteria for the potential loss of the fuel clad, based on CSFST monitoring, that are inconsistent with the NUMARC guidance and are not adequately justified.
Reword the EAL to be consistent with the guidance in NUMARC/NESP-007 or provide additional justification for it as written. This comment holds for RCB1, Status Trees, EAL #2, but will not be commented on separately.
8.
The NUMARC criteria for the RCS Barrier Example EAL #2 states:
POTENTIAL LOSS L RCS leak Rate Unisolable leak exceeding the capacity of one charging pump in the normal charging mode The equivalent Millstone 3 EAL stated:
COOLANT LEAKAGE RCB4 POTENTIAL LOSS Reactor Coolant Leak > Pump Capacity AND Entry Into E-0, Reactor Trip or Safety Injection, is Required
. The Hillstone 3 TBD stated, AOP 3555, Reactor Coolant Leak, requires that, if primary system leakage exceeds the maximum flow provided by two charging pumps such that pressurizer level cannot be maintained, the operators shall trip the reactor and initiate E0P 35 E-0.
The NUMARC threshold for leakage is, inability to maintain normal 11guld inventory within the Reactor Coolant System (RCS) by normal operation of the Chemical and Volume Control System which is considered as one centrifugal charging pump discharging to the charging header. The Mi11 stone 3 EAL threshold (two charging pumps, AND Entry Into E-0) has deviated in a non-conservative manner from the NUMARC criteria (one charging pump) without justification in the TBD. This deviation was also applicable to the NUMARC criteria for SG Tube Rupture, Potential Loss EAL, but will not be separately commented on.
Provide justification for the deviation from the NUMARC/NESP-007 guidance.
9.
The NUMARC criteria for the RCS Barrier Example EAL #5 states:
POTENTIAL LOSS L Other (Site-Soecific) Indications (Site-Specific) as appilcable The equivalent Millstone 3 EAL RCB3 stated:
POTENTIAL LOSS Decreasing RCS Pressure With Abnormal Conditions in CTMT The TBD stated that The " potential loss" EAL addresses initial symptoms of RCS leakage... This corresponds to indications of decreasing RCS pressure with abnormally high containment tempereture, pressure, or humidity.
A.
All other EALs of similar structure in the Millstone 3 scheme use the terminology Uncontrolled [RCS Cooldo%n] vs Decreasing, where Uncontrolled was defined as Condition is not the result of planned actions by the plant staff.
B.
Other EAls use the structure AND.for coincident conditions rather than With.
C.
Abnormal Conditions [in CTNT] was not included in the list of definitions, and bounding values were not included in the TBD.
D.
The TBD stated, Since secondary line breaks inside CTMT also can result in the indications of concern for this EAL, it is appropriate to consider this as only a " Potential loss" of the RCS Barrier. Although this TBD admission acknowledged the EAL was potentially not applicable to the RCS barrier, no
. differentiating criteria was provided to prevent an inadvertent, incorrect emergency declaration based on faulty indicators.
Human engineered, model EAls are user friendly. This M111 stone 3 EAL was inconsistent with the desired attributes in that it was not consistent and not objective.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
10.
The NUMARC criteria for the Primary Containment Barrier Example EAL #2 states:
POTENTIAL LOSS L Containment Pressure (Site-Specific) PSIG and increasing OR Explosive mixture exists.
OR Containment pressure greater than containment depressurization system setpoint with less than one full train of depressurization equipment operating.
The equivalent Millstone 3 EAL #CN83 stated:
POTENTIAL LOSS CTMT Pressure 2 60 PSIA AND Increasing CTMT H Concentration z 4%
g The NUMARC criteria of inoperative depressurization equipment appeared to be omitted from the Millstone 3 scheme. The TBD stated The #111 stone 3 plant design includes a quench spray system, a containment recirculation system and containment recirculation fans... Proper actuation and operation of quench spray, containment recirculation, and the containment air recirculation systems when required maintains CTMT pressure below its design value of 60 psia...
A1though these equipments function as depressurization system [s],
their loss was not an EAL threshold, thus the anticipatory attributes of the NUMARC criteria was absent.
The absence of the EAL was not justified in the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance, 11.
The NUMARC criteria for the Primary Containment Barrier Example EAL #4 states:
LOSS
1 l i L SG Secondary Side Release With Primary-to-Secondary leakaae Release of secondary side to atmosphere with primary to secondary leakage GREATER THAN tech spec allowable The equivalent Millstone 3 EAL #CNB4 stated:
SG Tube Rupture in Progress AND Release to the Environment > 15 Minutes The TBD stated Smaller spectrum or uncomplicated SG tube ruptures addressed by the RCB4, Coolant Leakage, above are not expected to result in prolonged releases to the environment as the operations staff perform the actions required by E0P E-3, Steam Generator Tube Rupture.
Of chief concern for this EAL are steam generator tube rupture sequences resulting in prolonged releases to the environment. Prolonged releases could be the result of a large primary-to-secondary flow rapidly increasing ruptured SG water level... The NUMARC EALs are structured to result in a declaration for the full spectrum of steam generator tube ruptures, i.e., a small break resulting in an Unusual Event to large rupture resulting in a Site Area Emergency.
Further, the NUMARC EAL does not include a threshold of time for the bypass condition to exist. The Millstone 3 EAL did not reflect these attributes, and the TBD justification appeared erroneous in its evaluation of the NUMARC EAL.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
)
12.
The NUMARC criteria for the Primary Containment Barrier Example EAL #6 states:
POTENTIAL LOSS L Core Exit Thermocovole Readinas Core exit thermocouples in excess of 1200 and restoration procedures not effective within 15 minutes; or, core exit thermocouples in excess of 7002 with reactor vessel level below top of active fuel and restoration procedures not effective within 15 minutes i
The equivalent Millstone 3 EAL stated:
CNB2 POTENTIAL LOSS Entry into FR-C.1, Response to Inadequate Core Cooling, Is Required AND Core Exit TC Temperatures Do NOT Decrease Within 15 Minutes The Mil 1 stone 3 TBD stated, Per F-0.2, Core Cooling Status Tree,1200* F corresponds to Core Cooling - RED which requires entry into FR-C.1, Response to Inadequate Cooling. This EAL clearly addresses the first part of the NUMARC criteria, but the second criteria related to thermocouples > 700* F and water level below TAF and restoration procedures not effective in 15 minutes
was not addressed, nor was its absence from the EAL scheme justified in the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
13.
The NUMARC criteria for the Primary Containment Barrier Example EAL #7
[
states:
i Zu Other (Site-Soecific) Indications I
(Site-Specific) as appilcable The NUMARC Basis information stated This EAL thould cover other (site-specific) indications that may unambiguous 1) frifcate loss or potential loss of the containment barrier, including indications from area or ventilation monitors...
If site emergency operating procedures provide for venting of the containment during an emergency.., a Loss EAL should be included...
Two equivalent Millstone 3 EAls related to bypass LOCA conditions were included.
The TBD stated A number of indications were considered for the g:neric "Other Conditions" CTMT EALs at Millstone 3.
In order to provide clear, unambiguous guidance to the Shift Supervisor, the Millstone 3 EALs are written to be consistent with the E0Ps. The TBD did not make a statement that no."other" indications suitable for use as EALs were available, nor did the TBD confirm that containment venting under all accident conditions was not applicable.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
NUMARC Recoanition Cateaory H - Hazards and Other Conditions Affectino Plant Safety 14.
The NUMARC criteria for EAL HU2-1 states:
1.
Fire in buildings or areas contiguous to any of the following (site-specific) areas not extinguished within 15 minutes of control room notification or verification of a control room alarm:
(Site-specific) Ifst
=
The equivalent Millstone 3 EAL GUI stated:
Fire Within an Area Containing Safe Shutdown Equipment > 15 Minutes The Millstone 3 EAL was written in a less conservative manner than the NUMARC l
criteria in that the event was described as within vital areas, whereas the NUMARC criteria is more anticipatory with in buildings or areas contiguous to vital areas. This non-conservative deviation was not justified in the TBD.
v
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
15.
The NUMARC criteria for EAL HU4-2 states:
2.
Other security events as determined from (site-specific) Safeguards Contingency Plan.
There was no equivalent Millstone 3 EAL and the omission was not justified in the TBD. This also applied to NUMARC EALs HA4-2 and HSI-2 but will not be separately commented on.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
16.
The NUMARC criteria for EAL HAl-2 states:
2.
Tornado or high win..ctriking plant vital ~ areas: Tornado or high winds greater than. a.:e-spe'cific) aph strike within protected area boundary.
The equivalent Millstone 3 EAL stated:
2.
On-Site Sustained Windspeed > 20 MPH The NUMARC criteria of a tornado event, which may not be measured by anemometers, was omitted from the Millstone 3 EAL, and not justified in the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
17.
The NUMARC criteria for EAL HAl-3 states:
3.
Report of any visible structural damage on any of the following plant structures:
Reactor Building Intake Buildirig Ultimate Heat Sink Refueling Water Storage Tank Diesel Generator Building 1
Turbine Building
=
Condensate Storage Tank Control Room Other (Site-Specific) Structures The equivalent Millstone 3 Alert EAL #TA2-3 stated:
3.
Report to Control Room of Damage Affecting Safe Shutdown Another EAL (#TV2-3) addressed the same subject, but was included in the Unusual Event, Destructive Phenomena category as follows.
O a 3.
Visible damage to Structures or Equipment Required for Safe Shutdown The Millstone 3 Alert EAL was non-conservative and inconsistent with the 1
NUMARC criteria in that the EAL implied assessment by field and/or control room personnel. Thus the anticipatory nature of the NUMARC EAL was lost. The Millstone 3 Unusual Event EAL more closely reflected'the intent of the NUMARC Alert criteria. These deviations from the NUMARC criteria were not justified i
in the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
18.
The NUMARC criteria for EAL HAl-6 states:
6.
Turbine failure generated alssiles result in any visible structural damage to or penetration of any of the following plant areas: (site-specific) list.
The equivalent Millstone 3 EAL #TA2-5 stated:
5.
Missiles Affecting Safe Shutdown NUMARC provided additional guidance in the basis information: EAL 6 is intended to address the threat to safety related equipment imposed by missiles generated by main turbine rotating component failures.
This (site-specific) list of areas should include all areas containing safety-related equipment, their controls, and their power supplies. Three concerns were noted with the Millstone 3 EAL:
A.
" Missiles" has a far broader meaning than was intended by this NUMARC EAL that is addressed by HAl-5.
B.
The specificity of contemporaneous damage reflected in the NUMARC Basis Information was not addressed by the Millstone EAL nor its absence justified in the TBD.
C.
The related Unusual Event (TU2-6) stated: Turbine Failure Causing Observable Casing Damage. The use of different terminology, i.e., " turbine" and " missiles" could potentially be confusing in making a classification.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
19.
The NUMARC EAL examples HA3-1 and 2 state:
1.
Report or detection of toxic gases within a Facility Structure in concentrations that will be life threatening to plant personnel.
2.
Report or detection of flammable gases within a Facility Structure i
in concentrations that will affect the safe operation of the plant.
The Millstone 3 equivalent EAL #GA3 stated:
4 m
4 Toxic or Flammable Gas Haking Vital Areas Uninhabitable Or Inaccessible The licensee did not reference or provide measurable criteria to the emergency director for establishing concentrations that affect safe operation of the plant. Without such information, i.e., "When have life threatening and flammable concentration thresholds have been exceeded?", readily available, classification would be difficult.
Furthermore, the EAL scheme utilized the concept of Areas of Concern for Safe Shutdown for all other EALs, whereas this EAL used the term Vital Areas which was undefined by the procedure.
This inconsistency was not in accordance with NUMARC guidance for model EALs.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
20.
The NUMARC criteria for Initiating Condition (IC) HAS and EAL HA5-1 states:
Control Room Evacuation Has Been Initiated.
1.
Entry into (site-specific) procedure for control room evacuation.
The equivalent Millstone 3 IC and EAL #GA1 stated:
GA1 CONTROL ROOM EVACUATION Control Room Evacuated Per Unit Procedure Or SS Judgement The NUMARC criteria reflects a declaration when control room evacuation is initiated, whereas the Millstone 3 EAL was stated in the past tense, control room evacuated. The time difference was not intended with the NUMARC IC, and was not justified in the TBD. This came concern related to time from evacuation initiated until control established was applicable to NUMARC criteria HS2 and Millstone 3 EAL CSI, but will not be separately commented on.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
21.
The NUMARC criteria for HS3-1 states:
1.
Other conditions exist which in the judgement of the Emergency Director indicate actual or likely major failures of plant functions
~
needed for protectfon of the public.
i The equivalent Millstone 3 EAL states:
Any condition which in the SS/DSE0's judgement indicates loss or potential loss of two fission product barriers.
This site-specific EAL is already covered under the fission product barrier EALs and, therefore, is redundant. Contrary to the TBD, this EAL is not consistent with the definition of the Site Area Emergency class in NUREG-0654 or NUMARC/NESP-007. The licensee should reword the judgement EAL to be
. t consistent with the NUMARC guidance and the requirements of Appendix E to 10 CFR Part 50.
22.
The NUMARC criteria for HG2-1 states:
1.
Other conditions exist which in the judgement of the Emergency Director indicate: (1) actual or imminent substantial core degradation with potential for loss of containment, or (2) potential.
for uncontrolled radiological releases.
These releases can reasonably be expected to exceed EPA PAG plume exposure levels outside the site boundary.
The equivalent Millstone 3 EAL stated:
JG1 SS/DSE0 JUDGEMENT Any Condition Which in the SS/DSE0's Judgement Indicates Potential for Radiological Releases Requiring Evacuation or Sheltering Offsite A.
The TBD indicates that the EAL addresses the conditions that fall under the General Emergency classification description in NUREG-0654, Appendix 1 that is retained under the NUMARC methodology, however, the licensee failed-to include the first argument of the NUMARC example EAL.
B.
The NUMARC guidances calls for declaration of a General Emergency when releases can be expected to exceed the Environmental Protection Agency's (EPA)
Protective Action Guides (PAGs) for the plume exposure pathway. The proposed EAL suggests classification when releases require sheltering offsite.
However, there are no EPA PAGs for sheltering in the plume exposure pathway.
Provide justification for these deviations from the NUMARC/NESP-007 guidance.
NUMARC Recoanition Cateoory S - System Malfunction 23.
The NUMARC criteria for SU3-1 states:
1.
The following conditions exist:
a.
Loss of most or all (site-specific) annunciators associated with safety systems for greater than 15 minutes.
AND d.
Annunciator or Indicator loss does not result from planned action.
The equivalent Millstone 3 EAL stated:
EU3 LOSS OF ANNUNCIATORS
s,
Loss of Most (75%) MCB Annunciators > 15 Minutes AND SPDS Or ICC Cabinet Available The' threshold of NUMARC EAL SU3-1.d., i.e., not... planned action, was not included in the Millstone 3 EALs nor was its absence justified in the basis document. This deviation was also applicable to Alert EAL EA3. The same criteria of unplanned in NUMARC IC SU6 (Loss of Communications) was omitted from the Millstone 3 EAL EU4.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
24.
The NUMARC criteria for IC SUS and EAL SUS-1 states:
SUS RCS Leakago OPERATING MODE APPLICABILITY: POWER OPERATION HOT STANDBY HOT SHUTDOWN 1.
The following conditions exist:
a.
Unidentified or pressure boundary leakage greater than 10 9Ps.
OR b.
Identified leakage greater than 25 gpm.
The NUMARC Basis criteria states Only operating modes in which there is fuel in the reactor coolant system and the system is pressurized are specified.
The equivalent Millstone 3 EAL BU2 stated:
BU2 RCS LEAKAGE MODE: ALL 1.
Pressure Boundary Leakage > 10 GPM 2.
Unidentified Leakage > 10 GPM 3.
Identified Leakage > 25 GPM The TBD stated NUREG-1449 raises concerns regarding accident sequences involving leakage through RCS temporary boundaries. RCS leakage EAls apply to all operating modes at Millstone 3.
This will assure that leakage is appropriately addressed for cold shutdown and refueling modes and address NRC concerns about leakage through temporary RCS boundaries as they apply to EALs.
The definition of an Unusual Event (UE) includes the attributes... indicate a potential degradation of the level of safety of the plant. No releases of radioactive material requiring offsite response or monitoring are expected...
During non-pressurized modes of operations, other NUMARC EALs are designed to address those conditions described by the UE definition. The addition of the
l :
Millstone 3 criteria of ALL [#0 DES) was a conservatism that is inconsistent with the UE definition, inconsistent with_the industry, and not justified by the TBD.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
25.
The NUMARC example SU7-1 states:
1.
Either of the following conditions exist:
a.
Unplanned loss of vital DC power to required DC busses based on (site-specific) bus voltage indications.
AND b.
Failure to restore power to at least one required DC bus within 15 minutes from the time of loss.
The Millstone 3 equivalent EAL #PU2 stated:
Loss of Voltage on DC Busses 301A-1, 301A-2, 3018-1, And 3018-2 > 15 Minutes The NUMARC criteria specifies that the loss of DC voltage is unplanned. This EAL applies to cold shutdown and refueling, and planned work that de-energizes the DC busses should not trigger a declaration.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
26.
The NUMARC criteria for SAS-1 states:
1.
The following conditions exist: (a and b) a.
Loss of Power to < site-specific > Transformers for Greater Than 15 Minutes.
AND b.
Onsite Power Capability has been Degraded to one (Train of)
Emergency Bus (ses) Powered from a Single Onsite Power Source due to the loss of:
< site-specific list >
The equivalent Millstone 3 EAL stated:
PA2 SINGLE AC POWER SOURCE i
Only One AC Power Source Available to Supply b'usses 34C And 340 kg
a The Millstone 3 EAL omitted the NUMARC criteria that the condition existed for 15 minutes, and did not justify the omission in the TBD. Although this was a conservative deviation, it is inconsistent with the guidance, the industry, and does not take into account transient or momentary conditions.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
27.
The NUMARC criteria for Site Area Emergency EAL SS3-1 states:
OPERATING MODE APPLICABILITY: Power Operatfon Hot Standby Hot Shutdown 1.
Loss of All Vital DC Power based on (site-specific) bus voltage indicatfons for greater than 15 minutes.
The equivalent Millstone 3 Alert Initiating Condition and EAL #PA3 stated:
PA3 LOSS OF DC Mode 2,3,4 Loss of Voltage on DC Buses 301A-1, 301A-2, 3018-1, And 3018-2 > 15 Minutes The equivalent Millstone 3 Site Area Emeraency Initiating Condition and EAL
- PS2 stated:
PS2 LOSS OF DC Mode 1 Loss of Voltage on DC Buses 301A-1, 301A-2, 3018-1, And 3018-2 > 15 Minutes The Millstone 3 TBD, Alert EAL, justified the deviation from NUMARC criteria with Mode 2 operation, startup, corresponds to power levels up to 5% of rated thermal power (RTP).
This means that the plant would be operating with the low power interlock, P-7, blocking several reactor trip signals related to reactor coolant pump operation, core flow, and turbine trip. At power levels up to 5%, temperature and pressure response would be Ilmited.... Similar plant transient response would occur for loss of DC from modes 3 and 4...
The TBD, Site Area Emergency EAL, went on to state, Complete loss of DC during power operation will result in a complete loss of annunciators and can result
\\
in a much more severe transient response (f.e., significant transient) than that associated with operation in lower modes. The NUMARC Basis Information states that Loss of all DC power compromises ability to monitor and control plant safety functions. The NUMARC EAL seeks to provide anticipatory declaration of a SAE that would ultimately occur under other EALs if a plant transient occurred during the power loss. Manual operation of protective functions coupled with loss of valve position indication and annunciation
... involve actual or likely major failures of plant functions needed for protection of the public", the definition of a Site Area Emergency.
l
,. Provide additional information concerning the source of control power for engineered safety features.
Provide additional justification for the deviation from the NUMARC/NESP-007 guidance.
28.
The NUMARC criteria for SS4-1 states:
1.
Complete loss of any (site-specific) function required for hot shutdown.
The equivalent Millstone 3 EAL ES2-1 and -2 stated:
ES2 INABILITY TO MAINTAIN HOT SD 1.
Heat Sink - RED And BOTH of the Following:
- Required Feedwater Flow Can NOT Be Established Within 15 Minutes
- RCS Feed and Bleed Can Not Be Established 2.
RCS Boration Capability Unable to Eliminate Inadvertent Criticality The NUMARC basis criteria states, This EAL addresses complete loss of functions, including ultimate heat sink and reactivity control, required for hot shutdown... Although the Millstone 3 EAls are symptomatic of complete loss of hot shutdown functions, the EAls did not possess the additional required attributes of being " anticipatory" (NUREG-0654 refers).
The TBD listed thirteen different Technical Specification systems that fulfilled several functions such as core cooling and reactivity control. However, the TBD did not justify the omission of some functions nor the substitute Millstone 3 EALs in an adequate manner.
For example, the TBD did not show that RCS Boration Capability Unable to Eliminate Inadvertent Criticality would result in a SAE declaration in the same time as an EAL stating " loss of reactivity control function".
Furthermore, by definition, and in accordance with the NUMARC guidance, the existence of a RED path on CSFST for Heat Sink constitutes a Site Area Emergency.
In the fission product barrier matrix a Heat Sink RED path is indicative of a potential loss of the fuel clad and RCS barriers, again requiring the declaration of a Site Area Emergency. The additional criteria of the first EAL are inconsistent with the NUMARC guidance.
Provide justification for this deviation from the NUMARC/NESP-007 guidance.
29.
Millstone 3 EAL RU1-2 states:
Unexpected Area Rad Monitor Reading Offscale High OR > 1000 Times Normal Reading for > 5 Minutes The TBD explains that unexpected is utilized to discriminate against expected increases due to controlled evolutions. Thus, the criteria for readings existing for > 5 minutes is redundant and inconsistent with the NUMARC i
e...
Y guidance.
The time limit should be deleted or justification for its inclusion provided.
30.
The NUMARC criteria for loss of fuel clad, based upon coolant activity, states:
Primary Coolant Activity Level Coolant activity GREATER THAN (site-specific) value The Millstone 3 equivalent EAL, FCB2-4 states:
Dose Rate at One foot from Unpressurized RCS Sample 130 mR/hr/m1.
A.
Regardless of the licensee's development of a unique EAL for assessing fuel clad integrity, the NUMARC example EAL of " coolant activity greater than 300 Cf/cc dose equivalent I-131" should be included in the EAL scheme or its omission justified.
B.
The TBD on page B-13 incorrectly quotes the NUMARC guidance in stating that 300 Ci/cc dose equivalent I-131 corresponds to 5-10% fuel clad damage.
This level corresponds to 2-5% fuel clad damage and the licensce's EAL thresholds should be adjusted accordingly.
C.
The Millstone 3 TBD justified the EAL threshold with The coolant sample radiation reading was determined by calculating various coolant I-131 DEQ concentrations postulated to result from 5% fuel clad failure and using core inventory and source term assumptions in NUREG-1465... The sample reading corresponding to this concentration was then determined using NU Radiological Assessment methodology...
These values are:
30 mR/hr/ml at 1 foot from an unpressurized sample, using the maximum I-131 DEQ of 1090 pCf/cc (minimum coolant volume) 3.6 mR/hr/ml at 1 foot from an unpressurized sample, using the minimum I-131 DEQ of 72 pCl/cc (maximum coolant volume)
The higher value was selected because inadequate core cooling scenarios are the conditions of interest.
This means that there is no or minimal ECCS injection, thus assuming minimum coolant volume is appropriate...
The Millstone 3 EAL was based on two non-conservative assumptions in the calculation: 1) the high end of the fuel clad damage band prescribed by NUMARC (5% vs 2%), and 2) assumir.3 the minimum coolant volume, thus maximum concentration.
Since fuel damage accident scenarios can be postulated that do not occur without the significant loss of coolant assumed in the Millstone 2 calculation, and the resulting 1090 C1/cc concentration is inconsistent with the balance of the industry, the licensee's EAL deviates significantly from the NUMARC guidance without adequate justification.
i