ML20153G429
| ML20153G429 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 09/24/1998 |
| From: | Buckley B, Thadani M NRC (Affiliation Not Assigned) |
| To: | Geoffrey Edwards PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| TAC-MA1736, TAC-MA1737, TAC-MA1738, TAC-MA1739, NUDOCS 9809300072 | |
| Download: ML20153G429 (35) | |
Text
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. - I September 24,1998 Mr. GIrrett D. Edwaros Direct:r-Licensing, MC 62A-1 PECO Energy Company Nuclear Group Headquarters Correspondence Control Desk P.O. Box No.195 Wayne, PA 19087-0195
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDitJG EMERGENCY ACTION LEVELS FOR LIMERICK GENERATING STATION (LGS), UNITS 1 AND 2, AND PEACH BOTTOM ATOMIC POWER STATION (PBAPS), UNITS 2 AND 3 (TAC NOS. MA1736, MA1737, MA1738, AND MA1739)
Dear Mr. Edwards:
By letter dated April 16,1998, you submitted revised emergency action level guidelines for LGS, Units 1 and 2, and PBAPS, Units 2 and 3, for NRC review and approval. Based on our evaluation of your submittal, we find that additional information, as delineated in Enclosure 1 for LGS, Units 1 and 2, and Enclosure 2 for PBAPS, Units 2 and 3, is required in order to continue our review. The information being requested was discussed with your staff on August 28,1998, and a response date of 30 days from your receipt of this letter was mutually acceptable.
Sincerely, original signed by:
original signed by:
Bartholomew C. Bucidey, Senior Project Manager Mohan C. Thadani, Senior Project Manager Project Directorate I-2 Project Directorate 1-2 Division of Reactor Projects -l/ll Division of Reactor Projects - t/II Office of Nuclear Reactor Regulation Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353 and 50-277 and 50-278 j
Enclosures:
cc w/encis: See next page DISTRIBUTION l
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DOCUMENT NAME: L11736.RAI 9809300072 980924 PDR ADOCK 05000277 F
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I Mr. Garrett D. Edwards Limerick Generating Station, Units 1 & 2 l
PECO Energy Company 1
cc:
J. W. Durham, Sr., Esquire Chief-Division of Nuclear Safety l
Sr. V.P. & General Counsel PA Dept. of Environmental Resources l
PECO Energy Company P.O. Box 8469 l
2301 Market Street Harrisburg, PA 17105-8469
- Philadelphia, PA 19101 Mcnager-Limerick Licensing,62A-1 Director-Site Engineering PECO Energy Company Limerick Generating Station
)
l 965 Chesterbrook Boulevard P.O. Box A Wayne, PA 19087-5691 Sanatoga, PA 19464 Mr. James D. von Suskil, Vice President Limerick Generating Station Manager Experience Assessment Post Office Box A Limerick Generating Station Sanatoga, PA 19464 P.O. Box A Sanatoga, PA 19464 Plant Manager Limerick Generating Station Library P.O. Box A U.S. Nuclear Regulatory Commission Sanatoga, PA 19464 Region 1 475 Allendale Road Regional Administrator, Region i King of Prussia, PA 19406 U.S. Nuclear Regulatory Commission 475 Allendale Road Senior Manager-Operations King of Prussia, PA 19406 Limerick Generating Station P.O. Box A Senior Resident inspector Sanatoga, PA 19464 U.S. Nuclear Regulatory Commission Limerick Generating Station Dr. Judith Johnsrud P.O. Box 596 National Energy Committee Pottstown, PA 19464 Sierra Club 433 Orlando Avenue Director-Site Support Services State College, PA 16803 Limerick Generating Station P.O. Box A Sanatoga, PA 19464 Chairman Board of Supervisors of Limerick Township 646 West Ridge Pike Linfield, PA 19468 2
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l REOUEST FOR ADDITIONAL INFORMATION REGARDING LIMERICK GENERATING STATION l
EAL REVISION TO NUMARC/NESP-007 METHODOLOGY l
The NRC has completed its initial review of the proposed emergency action levels (EALs) in the April 16,1998, Limerick Generating Station (LOS) submittal. The proposed EALs were reviewed against the guidance in NUMARC/NESP-007, Revision 2," Methodology for Development of Emergency Action Levels." This document has been endorsed by the NRC in Regulatory Guide 1.101, Revision 3," Emergency Planning and Preparedness for Nuclear Power Reactor," 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. Additional information is needed to determine whether a number of the LGS EALs conform to NUMARC/NESP-007 guidance. Please provide this additional information as discussed below.
Issue No. [
NUMARC/NESP-007 Initiating Condition (IC) AUl is:
Any Unplanned Release ofGaseous or Liquid Radioactivity to the Environment that Exceeds Two Times the Radiological TechnicalSpecificationsfor 60 Afinutes or Longer l
NUMARC/NESP-007 EAL AUl.1 associated with IC AUl is:
1.
A validreading on one or more ofthefollowing 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)
The LOS proposed EAL (5.1.1.a)is:
North or South Stack Rad Afonitor continuously in HiHi Alarm M known Unmonitored Release continuously in progress M Radwaste or Cooling Tower Blowdown Discharge Rad Afonitor continuously in Hi Alarmfor > 60 minutes AND Calculated maximum ofsite dose rate using computer dose model exceeds 0.114 mrem /hr TPARD M 0.342 mrem /hr child thyroid CDE based on a 60 minute averege A.
Please justify why readings on site-specific monitors were not included in this EAL as called for in the NUMARC/NESP-007 guidance.
B.
It is not clear whether the "> 60 minutes" condition applies to all monitors or just to the Cooling Tower Blowdown Discharge Rad Monitor. This may cause misapplication of this EAL. Please describe how this EAL is to be applied and how the EAL, as currently l
written, will not be misapplied.
ENCLOSURE 1
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UNITED STATES s
j NUCLEAR REGULATORY COMMISSION 2
WASHINGTON, D.C. 2006H001
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September 24,1998 Mr. Garrett D. Edwards Director-Licensing, MC 62A-1 PECO Energy Company Nuclear Group Headquarters Correspondence Control Desk P.O. Box No.195 Wayne, PA 19087-0195
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAl) REGARDING EMERGENCY ACTION LEVELS FOR LIMERICK GENERATING STATION (LGS), UNITS 1 AND 2, AND PEACH BOTTOM ATOMIC POWER STATION (PBAPS), UNITS 2 AND 3 (TAC NOS MA1736, MA1737, MA1738, AND MA1739)
Dear Mr. Edwards:
By letter dated April 16,1998, you submitted revised emergency action level guidelines for LGS, Units 1 and 2, and PBAPS, Units 2 and 3, for NRC review and approval. Based on our evaluation of your submittal, we find that additional information, as delineated in Enclosure 1 for LGS, Units 1 and 2, and Enclosure 2 for PBAPS, Units 2 and 3, is required in order to continue our review. The information being requested was discussed with your staff on August 28,1998, and a response date of 30 days from your receipt of this letter was mutually acceptable.
Sincerely, 3
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Bartholomew C. Buckley, Senior Project Manager Mohan C. Thadani, Senior Project Manager Project Directorate 1-2 Project Directorate 1-2 Division of Reactor Projects - t/11 Division of Reactor Projects - t/11 Office of Nuclear Reactor Regulation Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353 and 50-277 and 50-278
Enclosures:
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C.
The use of the dose unit "TPARD" in place of a more common dose unit such as Total Effective Dose Equivalent (TEDE) and the use of Committed Dose Equivalent (CDE)
Iale may cause confusion in classifying events using this EAL. Please provide additional justification for using these setpoints.
D.
The intent ofNUMARC/NESP-007 ICs AUl and AA1 is to use ODCM methodology to confirm that the release exceeds technical specification values. This confirmation is only used ifit can be completed promptly (e.g., within 15 minutes in the case of the Alert level EAL). Otherwise the event is to be classified based upon the monitor reading. It is not clear that the ODCM methodology will be used in this manner for this EAL. Please provide information regarding how the LGS's EAL meets the intent of the NUMARC/NESP-007 guidance.
These issues also apply to LGS EAL 5.1.2.a Issue No. 2 NUMARC/NESP-007 IC ASI is:
Boundary Dose Resultingfrom an Actual or Imminent Release ofGaseous Radioactivity Exceeds 100 mR Whole Body or 500 mR Child Thyroidfor the Actual or Projected Duration ofthe Release NUMARC/NESP-007 EALs ASI.1, ASI.3, ASI.4 associated with IC ASI are:
1.
A valid reading on one or more ofthefollowing monitors that exceeds or is expected to exceed the value shown indicates that the release may have exceeded the above criterion and indicates the need to assess the release with (Site-specific procedure): (Site-specificlist) 3.
Valid dose assessment capability indicates dose consequences greater than 100 mR whole body or 500 mR child thyroid 4.
Field survey results indicate site boundary dose rates exceeding 100 mR/hr expected to continuefor more than one hour; or analyses offield survey samples Indicate child thyroid dose commitment of500 mRfor one hour ofinhalation The LGS proposed EAL (5.1.3)is:
North or South Stack Rad Monitor continuously in HiHi Alarm QB known Unmonitored Release continuously inprogressfor > 15 minutes AND either :
Projected ofsite dose using computer dose model exceeds 100 mrem TPARD, QR Projected ofsite dose using computer dose model exceeds 500 mrem child thyroid CDE
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Valid dose assessment capability indicates dose consequences > 100 mrem TPARD, @
> 500 mrem childthyroid CDE G
Analysis ofFieldSurvey results indicates dose consequences > l')0 mrem /hr expected to continuefor more than one hour, M Analysis ofFieldSurvey re:ults indicate child thyroid dose commitment of500 mRemfor one hour ofinhalation A.
Please justify why readings on site-specific monitors were not included in this EAL as called for in the NUMARC/NESP-007 guidance.
B.
It is not clear whether the "> 15 minutes" condition applies to all monitors orjust to the unmonitored release. This may cause misapplication of this EAL. Please describe how this EAL is to be applied and how the EAL, as currently written, will not be misapplied.
C.
The use of the dose unit "TPARD" in place of a more common dose unit such as Total Effective Dose Equivalent (TEDE) and the use of Committed Dose Equivalent (CDE)
Iate may cause confusion in classifying events using this EAL Please provide additional justification for using these setpoints.
D.
The intent of NUMARC/NESP-007 ICs ASI and AGl is to confirm that release exceeded certain dose limits using a real-time dose assessment. This confirmation is only used ifit can be completed promptly (i.e., within 15 minutes). Otherwise the event is to be classified based upon the monitor reading. Please provide information regarding how LGS's EAL meets the intent of the NUMARC/NESP-007 guidance.
E.
Please provide information regarding the difference between " projected offsite dose" and
" Valid dose assessment capability" as used in this LGS EAL.
These issues also apply to LOS EAL 5.1.4.
Issue No. 3 NUMARC/NESP-007 IC AA3 is:
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i Release ofRadioactive Material or Increases in Radiation Levels Within the Facility That Impedes Operation ofSystems Required to Maintain Safe Operations or to Establish or Maintain ColdShutdown NUMARC/NESP-007 EAL AA3.1 associated with IC AA3 is:
1.
Valid (Site-specific) radiation monitor readings GREA TER THAN 15 mR/hr in areas requiring continuous occupancy to maintain plant safetyfunctions: (Site-specific list)
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4 The LGS proposed EAL (5.2.2.b)is:
Valid Control Room area radiation monitor reading > 15mR/hr 4
A.
Justify limiting the LGS EAL to the Control Room when the corresponding l
NUMARC/NESP-007 EAL relates to all " areas requiring continuous occupancy to maintainplant sa6>tyfunctions." Provide information regarding whether the Control I
Room is the only a where continuous occupancy is maintained or if there are other areas, such as the radwaste control room and the central security alarm station, which are continuously occupied.
Issue No. 4 NUMARC/NESP-007 IC AA3 is:
Release ofRadioactive Material or increases in Radiation Levels Within the Facility That Impedes Operation ofSystems Required to Maintain Safe Operations or to Establish or Maintain ColdShutdown i
NUMARC/NESP-007 EAL AA3.2 associated with IC AA3 is:
2.
Valid (Site-specific) radiation monitor readings GREATER THAN < site-specific > values in areas requiring infrequent access to maintain plant safety functions.
The LGS proposed EAL (5.2.2.a) is:
Valid radiation level readings > 5000 mR/hr in areas requiring infrequent access to maintain plant safetyfunctions as identified in procedure SE-1 or SE-6 M Access is requiredfor safe plant operation, but is impeded, due to radiation dose rates A.
This EAL deviates from the NUMARC/NESP-007 guidance by including the condition "M Access is requiredfor safe plant operation, but is impeded, due to radiation dose rates. " Such a condition could delay the emergency classification in cases where immediate access to the areas in question is not required. Please provide additional information justifying this deviation.
B.
Please provide additional information justifying the use of a single value (5000 mR/hr) for level readings, applicable for all areas, instead of a unique value for each area as NUMARC/NESP-007 EAL suggests.
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Issue No. 5 i
NUMARC/NESP-007 EAL FC2 for the loss of the fuel clad barrier is:
LOSS:
RPV level less than (site-specific) value The LGS proposed EAL (FC.2)is:
LOSS:
RPV level cannot be restored above -204" A.
A delay may occur in classifying a loss of RPV level event using the LGS EAL due to the time needed to determine whether level cannot be restored. Pleasejustify why RPV level less than -204" is not, by itself, an indication of the loss of the fuel clad and, ifit is not, what provisions there may be to prevent undue delay in classifying this event using the proposed LGS EAL.
Issue No. 6 NUMARC/NESP-007 EAL RCl for the loss of the reactor coolant system barrier is:
LOSS:
(site-specyle) indication ofa Main Steam Line Break The LGS proposed EAL (RC.1)is:
LOSS:
Hi Steam Low Annunciator AND Hi Steam Tunnel temperature Annunciator....
A.
In a letter dated June 10,1993, the NRC endorsed NUMARC's Questions and Answers (Q&As) on the NUMARC/NESP-007 document. One of the Q&As addressed the use of an isolable main steam line break EAL as a loss of the RCS barrier. The Q&A stated that it was inappropriate to include indication of a main steam line break in the fission product matrix, but that an event-based EAL should be provided for the main steam line break.
Please justify why this EAL is included in the LGS fission product barrier matrix.
Issue No. 7 NUMARC/NESP-007 EAL PCI for the loss of the containment barrier is:
LOSS:
Rapid unexplained decreasefollowing initial increase OR l
Drywellpressure response not consistent with LOCA conditions l
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POTENTIAL LOSS:
l (Site-specific)psig and increasing OR explosive mixture exists The LOS proposed EAL (PC.1)is:
LOSS:
Rapid, unexplained decrease in Drywell Pressurefollowing initial increase OR Drywell pressure response not consistent with LOCA conditions POTENTIAL LOSS:
DrywellPressure > 44psig andincreasing OR Drywell Hydrogen > 6% &YD Drywell Oxygen > 5%
A.
Please provide the deflagration limit curves used to determine the 6% Hydrogen and 5%
i Oxygen figures.
Issue No. &
NUMARC/NESP-007 IC HAl is:
Natural and Destructive Phenomena Affecting the Plant Vital Area NUMARC/NESP-007 EAL HA1.3 is:
Report ofany visible structural damage on any ofthefollowingplant structures:
- Reactor Building
- Intake Building
- Refueling WaterStorage Tank
- DieselGeneratorBuilding
- Turbine Building
- Condensate Storage Tank
- ControlRooms
- Other(Site-specific) Structures The LOS proposed EAL (8.4.2.c)is:
Report ofany visible structural damage on any Plant Vital Structure (Table 81)
Table 8-1 identifies the Plant Vital Structures as the Reactor Enclosure, Control Enclosure, Turbine Enclosure, Diesel Generator Enclosure, and Spray Pond Pump House / Spray Network.
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7 A. It does not appear that Table 8-1 encompasses all the structures and components listed in the NUMARC/NESP-007 Example EAL. Specifically, the tanks listed in NUMARC/NESP-007 1
EAL HA1.3 are not listed in Table 8-1. Please justify this apparent deviation.
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Issue No. 9 j
NUMARC/NESP-007 IC HA2 is:
Fire or Explosion Afecting the Operabiliry ofPlant Safety Systems Required to Establish '
or Maintain Safe Shutdown i
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- 1. Thefollowing conditions exist:
a.
Fire or explosion in any ofthefollowing (Site-specific) areas: (Site-specific) list AND b.
Afected system parameter indications show degradedperformance or plant personnel report visible damage to permanent structures or equipment within the specifiedarea I
The LOS proposed EAL (8.2.2.a) is:
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Fire or explosion which makes inoperable:
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Two or More subsystems or a Safe Shutdown System (Table 8-2)
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Two or More Safe Shutdown Systems l-M l
Plant Vital Structures containing Safe Shutdown Equipment AND Safe Shutdown System or Plant Vital Structure is requiredfor the present Operational j
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A. By including the condition that a fire or explosion makes systems or subsystems inoperable, the LGS EAL does not appear to meet the intent of the corresponding NUMARC/NESP-007 EAL which refers to events leading to " degraded performance."
B. The LGS EAL requires that " Safe Shutdown System or Plant VitalStructure is requiredfor the present Operational Condition," which is not addressed in the NUMARC/NESP-007 EAL and does not appear to meet the intent of the NUMARC/NESP-007 EAL.
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the fire. The corresponding NUMARC/NESP-007 EAL dces not include this condition.
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Please provide additional information that justifies these departures from the NUMARC/NESP-007 guidance.
Issue No.10 NUMARC/NESP-007 IC HU4 is:
Confirmed Security Event Which 1ndicates a Potential Degradation in the Level ofSafety ofthe Plant i
NUMARC/NESP-007 EALs HU4.1 and HU4.2 are:
- 1. Bomb device discovered withinplant ProtectedArea and outside the plant Vital Area.
- 2. Other security events as determinedfrom (Site-specific) Safeguards Contingency Plan.
The LGS proposed EAL (8.1.1)is:
Credible sabotage or bomb threat within the Protected Area M
Credible intrusion and attack threat to the Protected Area M
Attempted intrusion and attack to the Protected Area M
Attemptedsabotage discovered within the Protected /Vitai Area M
Hostage / Extorsion situation that threatens normalplant operations A. ' LGS EAL basis states that "The Shift Management will declare an Unusual Event subsequent to consulting with the Manager, Nuclear Security to determine the credibility ofthe security event." This is inconsistent with the NUMARC/NESP-007 EAL basis which does not include such a statement. This could delay or even impede declaration of the emergency should the Manager, Nuclear Security be unavailable (e.g., during a night shift). Please provide additional information that justifies the departure from the HUMARC/NESP-007 guidance.
This comment also applies to EAL 8.1.2.
B. Please provide additional information regarding how the condition " Attempted sabotage discovered within the Protected / Vital Area" would be detected and why this condition is not more appropriately classified at the Alert or Site Area Emergency classification level.
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Issue No.11 NUMARC/NESP-007 IC SA4 is:
Unplanned Loss ofMost or AllSafety System Annunciation or Indication In Control Room With Either (1) a Significant Transient in Progress, or (2) Compensatory Non.
Alarming Indicators are Unavailable NUMARC/NESP-007 EAL SA4.1 is:
- 1. Thefollowing conditions exist:
Loss ofmost or all (Site-specific) annunciators associated with safety systemsfor a.
greater than 15 minutes.
AND b.
In the opinion ofthe Shift Supervisor, the loss ofthe annunciators or indicators i
requires increased surveillance to safely operate the unit (s).
AND c.
Annunciator or Indicator loss does not resultfrom planned action.
ANI) d.
Either ofthefollowing:
1.
A significantplant transient is inprogress.
OR 2.
Compensatory non-alarming indications are unavailable The LOS proposed EAL (7.3.2)is:
Unplanned Loss ofmost or all safety system annunciators (Table 7-1) QR indicatorsfor
> 15 minutes requiring increasedsurveillance to safely operate the unit (s)
AND EITHER A significantplant transient is in progress (Table 7-3) OR the plant monitoring system (PMS)is unavailable A. The LGS EAL and basis are not clear as to what constitute safety system indicators. LGS EAL and/or basis should be supplemented to indicate what the " safety system indicators" are (e.g., by providing a table like Table 7-1 " Safety System Annunciators"). This comment also applies to LGS EAL 7.3.1.a.
B. LGS EAL basis states "Although loss ofALL annunciators is specifled, ifa large portion of annunciators or significant annunciators, as determined by the Shift Supervisor, are lost..."
for the " loss ofALL annunciators." This is inconsistent with the associated LGS EAL. The basis should be corrected. This comment also applies to LGS EAL 7.3.1.a and 7.3.3.
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Loss ofAll Ofsite Power and Loss ofAll Onsite AC Power to Essential Busses During ColdShutdown Or Refueling Mode NUMARC/NESP-007 EAL SA1.1 is.
- 1. Thefollowing conditions exist:
a.
Loss ofpower to (Site-specifc) transformers.
j AND b.
Failure of(Site-specipc) emergency generators to supplypower to emergency busses.
AND Failure to restore power to at least one emergency bus within 15 minutesfrom the c.
time ofloss ofboth offsite and onsite ACpower.
The LOS proposed EAL (6.1.2.b)is:
Thefol! swing conditions exist:
Loss ofPower to 101 and 201 Safeguard Transformers AND Failure to restore power to at least One emergency bus within 15 minutesfrom the time ofloss ofboth ofsite and onsite ACpower A. LGS EAL is not consistent with the NUMARC/NESP-007 EAL in that it does not include the second condition of the NUMARC/NESP-007 EAL, which is "b. Failure of(Site-specific) emergency generators to supplypower to emergency busses." Please provide additional information that justifies this departure from the NUMARC/NESP-007 guidance.
This comment also applies to LOS EAL 6.1.3.a.
B. The LGS EAL does not defime " emergency bus." This may cause confusion in classifying a loss of power event. Please define " emergency bus" in the EAL or justify not providing this
~ definition. This comment also applies to the other loss of onsite AC power EALs.
Issue No.13 NUMARC/NESP-007 IC SA3 is:
Inability to Maintain Plant in Cold Shutdown i
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- 1. Thefollowing conditions exist:
Loss of(Site-specific) Technical Specification requiredfunctions to maintain cold a.
shutdown.
AND b.
Temperature increase that either:
- Exceeds TechnicalSpecification coldshutdown temperature limit OR Results in uncontrolled temperature rise approaching cold shutdown technical specification limit.
The LOS proposed EAL (7.2.2)is:
Loss ofShutdown Cooling M
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Uncontrolled Temperature increase that either:
. Exceeds 200 #F E
Results in temperature rise approaching 200 *F A. The term " Loss ofShutdown Cooling"in the LOS EAL is not defined. The LOS EAL should be supplemented to indicate what constitutes " Loss ofShutdown Cooling" or additional information should be provided regarding how this EAL is to be applied.
Issue No.14 NUMARC/NESP-007 IC AU2 is:
Fuel CladDegradation NUMARC/NESP-007 EAL AU2.2 is:
Uncontrolled water level decrease in the spentfuelpool andfuel transfer canal with all irradiatedfuel assemblies remaining covered by water The LGS proposed EAL (1.2.1.a)is:
Uncontrolled water level decrease in the spentfuelpool with all irradiatedfuel assemblies remaining covered by water
12 The LGS proposed basis for this EAL is:
... During refueling operations, RP V level indication is read on Panel C602...
A. It does not appear to be appropriate to limit the statement "RPVlevelindication is read on Panel C602"in the basis to refueling operations. Please mo 7fy the basis or provide additional information for including this statement.
Issue No.15 NUMARC/NESP-007 IC AA2 is:
Major Damage to Irradiated Fuel or Loss of Water Level that Has or Will Result in the Uncovering ofIrradiated Fuel Outside the Reactor Vessel NUMARC/NESP-007 EALs AA2.3 and AA2.4 are:
Water Levelless than (site-specific)feetfor the Reactor Refueling Cavity that will result in IrradiatedFuel Uncovering Water Levelless than (site-specific)feetfor the Spent Fuel Pool and Fuel Transfer Canal that will result in Irradiated Fuel Uncovering The corresponding LOS EALs (1.2.2.c and d) are:
Water Level < 22 feet above RPVflangefor the Reactor Refueling Cavity that will result in IrradiatedFuel Uncovering Water Level < 22feetfor the Spent Fuel Pool that Will Result in Irradiated Fuel Uncovering A. Please provide additional information describing the basis for use of the indication of water level "<22 feet" for the fuel pool and reactor cavity. Please provide information regarding how this level will be measured.
Issue No.16 The basis of LGS proposed EAL 1.2.2.b discusses events involving the loss of water level that has or will result in the uncovering ofirradiated fuel outside the reactor vessel. The basis states that offsite doses during these accidents would be well below the EPA Protective Action Guidelines. However, studies of the loss of fuel pool water level, e.g., NUREG/CR-6451, "A Safety and Regulatory Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants," indicate that a significant release may occur if rapid oxidation of the fuel clad occurs due to a prolonged loss of cooling. The LGS basis may be misleading as to the potential significance of a loss of water in the fuel pool event. Please provide additional information
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Issue No 17 NUMARC IC SSS contains the following EALs:
i Loss ofreactor vessel water level as indicated by:
- Loss ofall decay heat removal cooling....
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- (site-specific) indicators that the core is or will be uncovered.
The corresponding LGS EALs (2.1.3) are:
Loss ofreactor vessel water level as indicated by:
- Loss ofall decay heat removal cooling as determined byprocedure GP-6.2 and
- Inability to maintain RPVlevel over -161" i
In the basis for the LGS EALs it is stated that:
i Prior to concluding that RPVlevel cannot be maintained, consideration must be given to injection system availability and status and trend ofthe rate at which RP Vlevel is decreasing. Ample time should be allotted to analyze the ability ofinjection sources...
A. Even though the first condition,i.e.," Loss of all decay heat removal coohng as determined by procedure GP-6.2, " is in accordance with the NUMARC guidance, it is not clear that this condition is necessary to conclude that the plant condition warrants a site area emergency classification. Please provide addition information whichjustifies including this condition in this EAL.,
B. The second EAL, i.e., " Inability to maintain RPV level over -161"," appears to deviate from the NUMARC guidance. This deviation may cause a delay in classification which does not appear to be appropriate. Please provided additional information justifying this deviation.
Issue No.18 l
(site-specific indication exists that indicate that reactorprotection system setpoint was exceeded and automatic scram did not occur, and a successful manual scram occurred
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The corresponding LOS EAL (2.2.2)is Automatic RPS SCRAAf should occur due to RPS Setpoint being exceeded AND Failure ofAutomatic RPSScram to reduce reactorpower <4%
The LGS EAL deviates from the NUMARC guidance by including the "<4%" power condition.
Although including a power level for the failure-to-scram has been determined to be r.cceptable in the Q&A's on the NUMARC EALs for the Site Area Emergency EAL, it was not deemed appropriate for the Alert level EAL Please revise this EAL to remove the power level criteria or provide additional information justifying this deviation.
Issue No 19 The NUMARC EAL for the loss of RCS based upon drywell radiation monitoring is:
Drywell Rad Afonitor Reading greater than (site-specific) R/hr The guidance for determining the setpoint for this EAL is "The reading should be calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with normal operating concentrations...."
The corresponding LGS EAL (RC.3)is:
Drywell Rad Afonitor reading > 100 R/hr Please provide a copy of the document ERP-C-1410 referred to in the Basis for this EAL.
The LGS reading was established based upon technical specification limit concentrations. Please justify use of these concentrations rather than normal operating concentrations.
Issue No. 20 The LGS EAL 6.1.1.b does not identify the specific DC buses for which this EAL is applicable.
This information is included in the basis for this EAL Please provide additional information which describes how the basis document is to be used in the classification process and how errors in classification will not occur if the specific buses are not included in the EAL itself.
Issue No. 21 The LGS EAL 6.1.4 includes the condition,"HPCI and RCIC unavailable for makeup and decay heat removal." Please provide additional information on the definition of" unavailable" as used in this EAL and how long the core cooling can be maintained without HPCI and RCIC operating.
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Issue No. 22 NUMARC EAL SS4.1 is:
Complete loss ofany (site-specific) function requiredfor hot shutdown The corresponding LGS EAL (7.2.3) is:
Loss ofMain Condenser as a heat sink AND Loss ofSuppression Pool heat sink capabilities as evidenced by T-102 legs requiring an Emergency Blowdown AND Either ofthefollowing conditions:
- Reactor Power >4%
Please provide additional information describing the relationship of this EAL to EALs using similar parameters (e.g., fission product barrier EALs and failure to scram EALs). In addition; provide additional information justifying the use of the "RPV level cannot be restored above
-161" as a setpoint (which requires' judgement) rather than a simple setpoint (e.g., RPV level less than -161").
Issue No 23 NUMARC EAL HU2.1 is:
Fire in building or areas contiguous to any ofthefollowing (site-specific) areas..
The corresponding LOS EAL (8.2.1.a) is:
Fire within SE-8 Plant Vital Structures (table 8-1)...
Please provide additional information how the areas listed in Table 8-1 relate to the " buildings or areas contiguous" specified in the NUMARC EAL and justify any deviations.
Issue No. 24 NUMARC EAL HUI.4 is:
Vehicle crash into plant structures or systems within protected area boundary The corresponding LGS EAL (8.3.1.a) is:
Vehicle crash withinprotected area boundary that maypotentially damage structures
16 containingfunctions and systems requiredfor safe shutdown oftheplant The LGS EAL deviates from the NUMARC guidance by including the condition that the crash may damage structures containing functions and systems required for safe shutdown of the plant.
This condition more closely correlates with the Alert classification level EAL for a vehicle crash.
Please provide additional informationjustifying this deviation.
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REOUEST FOR ADDITIONAL INFORMATION REGARDING PEACH BOTTOM ATOMIC POWER STATION EAL REVISION TO NUMARC/NESP-007 METHODOLOGY The NRC has completed its initial review of the proposed emergency action levels (EALs) in the April 16,1998, Peach Bottom Atomic Power Station (PBAPS) submittal. The proposed EALs were reviewed against the guidance in NUMARC/NESP-007, Revision 2," Methodology for Development of Emergency Action Levels." This document has been endorsed by the NRC in Regulatory Guide 1.101, Revision 3," Emergency Planning and Preparedness for Nuclear Power Reactor," 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. Additional information is needed to determine whether a number of the PBAPS EALs conform to NUMARC/NESP-007 guidance. Please provide this additional information as discussed below.
j Issue No.1 NUMARC/NESP-007 Initiating Condition (IC) AUl states:
Any Unplanned Release ofGaseous or Liquid Radioactivity to the Environment that Exceeds Two Times the Radiological TechnicalSpecifcationsfor 60 Minutes or Longer NUMARC/NESP-007 EAL AUl.1 associated with IC AUl is:
1.
A validreading on one or more ofthefollowing monitors that exceeds the "value shown " (site-specific monitors) indicates that the release may have exceeded the above criterion andindicates the needto assess the release with (Site-specifc procedure): (Site-specifclist)
The PBAPS proposed EAL (5.1.1.a)is:
Main or Vent Stack RadMonitor continuouslyin HiHi Alarm M known Unmonitored Release or use ofTorus Hardened Vent continuously inprogress M Radwaste or Service Water Discharge Rad Monitor continuously in Hi Alarmfor > 60 minutes &YD Calculatedmaximum ofsite dose rate using computer dose model exceeds 0.114 mrem /hr TPARD G 0.342 mRemthr child thyroid CDE based on a 60 minute average A.
Please justify why readings on site specific monitors were not included in this EAL as called for in the NUMARC/NESP-007 guidance.
B.
It is not clear whether the "> 60 minutes" condition applies to all monitors orjust to the Service Water Monitor. This may cause misapplication of this EAL. Please describe how this EAL is to be applied and how the EAL, as currently written, will not be misapplied.
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The use of the dose unit "TPARD" in place of a more common dose unit such as Total Effective Dose Equivalent (TEDE) and the use of Committed Dose Equivalent (CDE) raic may cause confusion in classifying events using this EAL. Please provide additional justification for using these se,tpoints.
D.
The intent of NUMARC/NESP-007 ICs AUl and AA1 is to use ODCM methodology to confirm that the release exceeds technical specification values. This confirmation is only used ifit can be completed promptly (e.g., within 15 minutes in the case of the Alert level EAL). Otherwise the event is to be classified based upon the monitor reading. It is not clear that the ODCM methodology will be used in this manner for this EAL. Please provide information regarding how the PBAPS's EAL meets the intent of the NUMARC/NESP-007 guidance.
l These issues also apply to PBAPS EAL 5.1.2.a Issue No. 2 NUMARC/NESP-007 Initiating Condition (IC) AS1 states:
Boundary Dose Resultingfrom an Actual or Imminent Release ofGaseous Radioactivity Exceeds 100 mR Whole Body or 300 mR Child Thyroidfor the Actual or Projected Duration ofthe Release NUMARC/NESP-007 EALs ASI.1, ASI.3, ASI.4 associated with IC ASI are:
1.
A valid reading on one or more ofthefollowing monitors that exceeds or is expected to exceed the value shown indicates that the release may have exceeded l
the above criterion andindicates the need to assess the release with (Site-specific procedure):(Site-specifclist) l 3.
Valid dose assessment capability indicates dose consequences greater than 100 mR whole body or 300 mR childthyroid 4.
Fieldsurvey results indicate site boundary dose rates exceeding 100 mR/hr expected to continuefor more than one hour; or analyses offeld survey samples l
indicate child thyroid dose commitment of500 mRfor one hour ofinhalation l
l The PBAPS proposed EAL (5.1.3)is:
Main or Vent Stack Rad Monitor continuously in HIHi Alarm M known Unmonitored Release or use of Torus Hardened Vent continuously inprogressfor > 13 minutes Ab22 either :
Projected ofsite dose using computer dose model exceeds 100 mrem TPARD, M
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3 Projected ofsite dose using computer dose model exceeds 500 mrem child thyroid CDE i
E Valid dose assessment capability indicates dose consequences > 100 mrem TPARD, M
> $00 mrem childthyroid CDE G
Analysis ofField Survey results indicates dose consequences > 100 mrem /hr expected to continuefor more than one hour, & Analysis ofFieldSurvey results indicate child thyroiddose commitment of500 mRemfor one hour ofinhalation A.
Please justify why readings on site-specific monitors were not included in this EAL as called for in the NUMARC/NESP-007 guidance.
1 B.
It is not clear whether the "> 15 minutes" condition applies to all monitors orjust to the Torus Vent. This may cause misapplication of this EAL. Please describe how this EAL is to be applied and how the EAL, as currently written, will not be misapplied.
C.
The use of the dose unit "TPARD" in place of a more common dose unit such as Total Effective Dose Equivalent (TEDE) and the use of Committed Dose Equivalent (CDE)
Ialt may cause confusion in classifying events using this EAL. Please provide additional justification for using these setpoints.
D.
The intent ofNUMARC/NESP-007 ICs AS1 and AGl is to confirm that release exceeded certain dose limits using a real time dose assessment. This confirmation is only used ifit can be completed promptly (i.e., within 15 minutes). Otherwise the event is to be classified based upon the monitor reading. Please provide information regarding how PBAPS's EAL meets the intent of the NUMARC/NESP-007 guidance.
E.
Please provide information regarding the difference between " projected offsite dose" and
" Valid dose assessment capability" as used in this PBAPS EAL.
These issues also apply to PBAPS EAL 5.1.4.
Issue No. 3 NUMARC/NESP-007 Initiating Condition (IC) AA3 states:
l Release ofRadioactive Material or increases in Radiation Levels Within the Facility That Impedes Operation ofSystems Required to Maintain Safe Operations or to Establish or Maintain ColdShutdown NUMARC/NESP-007 EAL AA3.1 associated with IC AA3 is:
1.
Valid (Site-specifc) radiation monitor readings GREA TER THAN 15 mR/hr in areas requiring continuous occupancy to maintainplant safetyfunctions: (Site-
1 4
specificlist)
The PBAPS proposed EAL (5.2.2.b)is:
Valid ControlRoom area radiation monitor reading > 15mR/hr l
1 A.
Justify limiting the PBAPS EAL to the Control Room when the corresponding NUMARCINESP-007 EAL relates to all " areas requiring continuous occupancy to maintainplant safetyfunctions." Provide information regarding whether the Control Room is the only area where continuous occupancy is maintained or if there are other areas, such as the radwaste control room and the central security alarm station, which are i
continuously occupied.
Issue No. 4 NUMARC/NESP-007 Initiating Condition (IC) AA3 states:
Release ofRadioactive Material or increases in Radiation Levels Within the Facility That Impedes Operation ofSystems Required to Maintain Safe Operations or to Establish or Maintain ColdShutdown NUMARC/NESP-007 EAL AA3.2 associated with IC AA3 is:
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2.
Valid (Site specific) radiation monitor readings GREATER THAN < site-specific > values in areas requiring infrequent access to maintain plant safety functions.
l The PBAPS proposed EAL (5.2.2.a)is:
Valid radiation level readings > 5000 mR/hr in areas requiring infrequent access to maintain plant safetyfunctions as identified in procedure SE-1 or SE-10 M Access is l
requiredfor safe plant operation, but is impeded, due to radiation dose rates A.
This EAL deviates from the NUMARC/NESP-007 guidance by including the condition "M Access is requiredfor safe plant operation, but is impeded, due to radiation dose rates. " Such a condition could delay the emergency classification in cases where immediate access to the areas in question is not required. Please provide additional information justifying this deviation.
B.
Please provide additional information justifying the use of a single value (5000 mR/hr) for level readings, applicable for all areas, instead of a unique value for each area as NUMARC/NESP-007 EAL suggests.
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Issue No. 5 NUMARC/NESP-007 EAL FC2 is:
LOSS:
RPV level less than (site-specific) value.
The PBAPS proposed EAL (RC.1)is:
LOSS:
RPV level cannot be restored above -226" A.
A delay may occur in classifying a loss of RPV level event using the PBAPS EAL due to the time needed to determine whether level cannot be restored. Please justify why RPV level less than -226" is not, by itself, an indication of the loss of the fuel clad and, ifit is not, what provisions there may be to prevent undue delay in classifying this event using the proposed PBAPS EAL.
Issue No. 6 NUMARC/NESP-007 EAL RCl is:
LOSS:
(site-specific) indication ofa Main Steam Line Break The PBAPS proposed EAL (RC.1)is:
LQSS:
Hi Steam Low Annunciator 4HL) Hi Steam Tunnel temperature Annunciator....
A.
In a letter dated June 10,1993, the NRC endorsed NUMARC's Question and Answers (Q&As) on the NUMARC/NESP-007 document. One of the Q&As addressed concems on included an EAL for an isolable main steam line break as a loss of the RCS barrier.
The Q&A stated that it was inappropriate to include indication of a main steam line break in the fission product matrix, but that an event-based EAL should be provided for the main steam line break. Pleasejustify why this EAL is included in the PBAPS fission product matrix.
Issue No. 7 NUMARC/NESP-007 EAL PC1 is:
LQSS:
Rapid unexplained decreasefollowing initial increase OR Drywellpressure response not consistent with LOCA conditions
POTENTIAL LOSS:
(Site-specifc)psig andincreasing OR explosive mixture exists The PBAPS proposed EAL (PC.1)is:
LOSS:
Rapid, unexplained decrease in Drywell Pressurefollowing initial increase DE Drywell pressure response not consistent with LOCA conditions POTENTIAL LOSS:
Drywell Pressure > 49psig andincreasing OR Drywell Hydrogen > 6% 2D Drywell Oxygen > 5%
A.
Please provide the deflagration limit curves used to determine the 6% Hydrogen and 5%
Oxygen figures.
Issue No. 8 NUMARC/NESP-007 Initiating Condition (IC) HAl states:
Natural and Destructive Phenomena Afecting the Plant Vital Area NUMARC/NESP-007 EAL HA1.3 is:
Report ofany visible structural damage on any ofthefollowingplant structures:
- ReactorBuilding
- Intake Building
- UltimateHeatSink
- Refueling Water Storage Tank
- DieselGeneratorBuilding
- Turbine Building
- Condensate Storage Tank
- ControlRooms
Report ofany visible structural damage on any Plant Vital Structure (Table 8-1)
Table 8-1 identifies the Plant Vital Structures as the Power Block, Diesel Generator Building, Emergency Pump Structure, Inner Screen Structure, Emergency Cooling Tower.
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A. It does not appear that Table 8-1 encompasses all the structures and components listed in the NUMARC/NESP-007 Example EAL. Specifically, the tanks listed in NUMARC/NESP-007 EAL HA1.3 are not listed in Table 8-1. Pleasejustify this apparent deviation.
Issue No. 9 NUMARC/NESP-007 Initiating Condition (IC) HA2 states:
Fire or Explosion Afecting the Operability ofPlant Safety Systems Required to Establish or Maintain Safe Shutdown NUMARC/NESP-007 EAL HA2.1 Is:
- 1. Thefollowing conditions exist:
Fire or explosion in any ofthefollowing (Site-specific) areas: (Site-specifc) list a
AND b.
Afectedsystemparameter indications show degradedperformance orplant personnelreport visible damage topermanent structures or equipment within the specifedarea The PBAPS proposed EAL (8. 2.2.a)is:
Thefollowing conditions exist:
Fire or explosion which makes inoperable:
Two or More subsystems or a Safe Shutdown System (Table B-2)
M Two or More Safe Shutdown Systems Plant Vital Structures containing Safe Shutdown Equipment AND Safe Shutdown System or Plant VitalStructure is requiredfor thepresent Operational Condition A. By including the condition that a fire or explosion makes systems or subsystems inoperable, the PBAPS EAL does not appear to meet the intent of the corresponding NUMARC/NESP-007 EAL which refers to events leading to " degraded performance."
B. The PBAPS EAL requires that "Sofe Shutdown System or Plant VitalStructure is required for the present Operational Condition," which is not addressed in the NUMARC/NESP-007 EAL and does not appear to meet the intent of the NUMARC/NESP-007 EAL.
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l C. The PBAPS EAL requires two or more subsystems of a safe shutdown system to be affected by the fire. The corresporiding NUMARC/NESP-007 EAL does not include this condition.
Please provide additional information that justifics these departures from the NUMARC/NESP-007 guidance.
Issue No.10 NUMARC/NESP-007 Initiating Condition (IC) HU4 is:
Confirmed Security Event Which Indicates a Potential Degradation in the Level ofSafety ofthe Plant j
NUMARC/NESP-007 EALs HU4.1 and HU4.2 are:
- 1. Bomb device discovered withinplant ProtectedArea and outside the plant Vital Area.
- 2. Other security events as determinedfrom (Site-specific) Safeguards Contingency Plan.
The PBAPS proposed EAL (8.1.1)is:
Credible sabotage or bomb threat within the ProtectedArea
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2 Credible intrusion and attack threat to the Protected Area M
Attempted intrusion and attack to the Protected Area S
Attemptedsabotage discovered within the Protected / Vital Area M
Hostage / Extorsion situation that threatens normalplant operations A. PBAPS EAL basis states that "The Shift Management willdeclare an UnusualEvent subsequent to consulting with the Manager, Nuclear Security to determine the credibility of the security event." This is inconsistent with the NUMARC/NESP-007 EAL basis which does not include such a statement. This could delay or even impede declaration of the emergency should the Manager, Nuclear Security be unavailable (e.g., during a night shift).
Please provide additional information that justifies the departure from the NUMARC/NESP-007 guidance. This comment also applies to EAL 8.1.2.
4 B. Please provide additional information regarding how the condition " Attempted sabotage discovered within the Protected / Vital Area" would be detected and why this condition is not more appropriately classified at the Alert or Site Area Emergency classification level.
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Issue No.11 NUMARC/NESP-007 Initiating Condition (IC) SA4 states:
Unplanned Loss ofMost or All Safety System Annunciation or Indication in Control Room With Either (1) a Signifcant Transient in Progress, or (2) Compensatory Non-AlarmingIndicators are Unavailable NUMARC/NESP-007 EAL SA4.1 is:
- 1. Thefollowing conditions exist:
Loss ofmost or all (Site specifc) annunciators associated with safety systemsfor a.
greater than 15 minutes.
AND b.
In the opinion ofthe Shift Supervisor, the loss ofthe annunciators or indicators requires increased surveillance to safely operate the unit (s).
AND c.
Annunciator or Indicator loss does not resultfrom planned action.
AND d.
Either ofthefollowing:
1.
A significantplant transient is inprogress.
OR 2.
Compensatory non-alarming indications are unavailable The PBAPS proposed EAL (7.3.2)is:
UnplannedLoss ofmost or allsafety system annunciators (Table 7-1) QB indicatorsfor
> 15 minutes requiring increasedsurveillance to safely operate the unit (s)
AND EITHER A sigmfcantplant transient is inprogress (Table 7-3) OR theplant monitoring system (PMS)is unavailable A. The PBAPS EAL and basis are not clear Es to what constitute safety system indicators.
PBAPS EAL and/or basis should be supplernented to indicate what the " safety system indicators" are (e.g., by providing a table like Table 7-1 " Safety System Annunciators").
This comment also appiies to PBAPS EAL 7.3.1.
B. PBAPS EAL basis states "Although loss ofALL annunciators is speciped, ifa largeportion ofannunciators or significant annunciators, as determined by the Shift Supervisor, are lost
..." for the " loss ofALL annunciators". His is inconsistent with the associated PBAPS EAL. The basis should be corrected. His comment also applies to PBAPS EAL 7.3.1 and 7.3.3.
Issue No.12 NUMARC/NESP-007 Initiating Condition (IC) SA1 states:
Loss ofAll Ofsite Power andLoss ofAll Onsite AC Power to Essential Busses During ColdShutdown Or RefuelingMode NUMARC/NESP-007 EAL SA1.1 is:
'1. Thefollowing conditions exist:
Loss ofpower to (Site-specifc) transformers.
a.
AND b.
Failure of(Site-specipc) emergency generators to supplypower to emergency busses.
AND Failure to restore power to at least one emergency bus within 15 minutesfrom the c.
time ofloss ofboth ofsite and onsite ACpower.
The PBAPS proposed EAL (6.1.2.b)is:
Thefollowing conditions exist:
Loss ofPower to 2 and 3 Startup and Emergency Aux. Transformers and 343 Startup Transformer MD Failure to restore pcser to at least One emergency bus within 15 minutesfrom the time ofloss ofboth ofsite andonsite ACpower A. PBAPS EAL is not consistent with the NUMARC/NESP-007 EAL in that it does not include the second condition of the NUMARC/NESP-007 EAL, which is "b. Failure of(Site-specific) emergency generators to supplypower to emergency busses." Please provide additional information thatjustifies this departure from the NUMARC/NESP-007 guidance.
This comment also applies to PBAPS EAL 6.1.7.a.
B. The PBAPS EAL does not define " emergency bus." This may cause confusion in classifying a loss of power event. Please define " emergency bus"in the EAL orjustify not providing this definition. This comment also applies to the other loss ofonsite AC power EALs.
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Issue No.13 NUMARC/NESP-007 Initiating Condition (IC) SA3 states:
l Inability to Maintain Plant in ColdShutdown
11 NUMARC/NESP-007 EAL SA3.1 is:
- 1. Thefollowing conditions exist:
a.
Loss of(Site-specifc) Technical Specifcation requiredfunctions to maintain cold shutdown.
AND b.
Temperature increase that either:
Exceeds Technical Specifcation cold shutdown temperature limit OR Results in uncontrolled temperature rise approaching coldshutdown technicalspecifcation limit.
The PBAPS proposed EAL (7.2.2)is:
Loss ofShutdown Cooling MD Uncontrolled Temperature increase that either:
. Exceeds 212 F DB
. Results in temperature rise approaching 212 F A. The term " Loss ofShutdown Cooling"in the PBAPS EAL is not defined. The PBAPS EAL should be supp'.mented to indicate what constitutes " Loss ofShutdown Cooling" or additional information should be provided regarding how this EAL is to be applied.
]ssue No.14 NUMARC/NESP-007 Initiating Condition (1C) AU2 is:
Fuel CladDegradation NUMARC/NESP-007 EAL AU2.2 is:
Uncontrolled water level decrease in the spentfuelpool andfuel transfer canal with all irradiatedfuel assemblies remaining covered by water The PBAPS proposed EAL (1.2.1.a)is:
Uncontrolled water level decrease in the spentfuelpool with all irradiatedfuel assemblies remaining covered by water The PBAPS proposed basis for this EAL is:
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... During refueling operations, RPVlevel indication is read on Panel 005...
A. It does not appear to be appropriate to limit the statement "RPVlevelindication is readon Panel 00.5"in the basis to refueling operations. Please modify the basis or provide additional information for including this statement.
Issue No.15 NUMARC/NESP-007 Initiating Condition (IC) AA2.4 states:
Major Damage to Irradiated Fuel or Loss of Water Level that Has or Will Result in the Uncovering offrradiatedFuel Outside the Reactor Vessel NUMARC/NESP-007 EALs AA2.3 and AA2.4 are:
Water Levelless than (site-specifc)feetfor the Reactor Refueling Cavity that will result inirradiatedFuel Uncovering Water Level less than (site-specific)feetfor the Spent Fuel Pool and Fuel Transfer Canal that will result in irradi.:tedFuel Uncovering The corresponding PBAPS EALs (1.2.2.c and d) are:
Water Level < 22 feet above RPVflangefor the Reactor Refueling Cavity that will result inirradiatedFuel Uncovering Water Level < 22feetfor the Spent Fuel Pool that Will Result in irradiated Fuel Uncovering A. Please provide additional information describing the basis for use of the indication of water level "<22 feet" for the fuel pool and reactor cavity. Please provide information regarding how this level will be measured.
Issue No.16 The basis of PBAPS proposed EAL 1.2.2.b discusses events involving the loss of water level that has or will result in the uncovering ofirradiated fuel outside the reactor vessel. The basis states that offsite doses during these accidents would be well below the EPA Protective Action Guidelines. However, studies of the loss of fuel pool water level, e.g., NUREG/CR-6451, "A Safety and Regulatory Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants," indicate that a significant release may occur if rapid oxidation of the fuel clad occurs due to a prolonged loss of cooling. The PBAPS basis may be misleading as to the potenti.d significance of a loss of water in the fuel pool event. Please provide additional informationjustifying the PBAPS basis statements.
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o 13 Issue No 17 NUMARC IC SSS contains the following EALs:
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Loss ofreactor vessel water level as indicated by:
- Loss ofall decay heat removal cooling....
and
- (site-specific) indicators that the core is or will be uncovered The corresponding PBABS EALs are:
Loss ofreactor vessel water level as indicated by:
- Loss ofall decay heat removal cooling as determined byprocedure GP-6.2 and
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- Inability to maintain RPVlevel over -172" In the basis for the PBAPS EALs it is stated that:
Prior to concluding that RPVlevel cannot be maintained, consideration must be given to injection system availability and status and trend ofthe rate at which RPVlevel is decreasing. Ample time should be allotted to analyze the ability ofinjection sources...
A. Even though the first EAL, i.e.," Loss of all decay heat removal cooling as determined by procedure GP-6.2, "is in accordance with the NUMARC guidance, it is not clear that this condition is necessary to conclude that the. plant condition warrants a site area emergency classification. Please provide addition information which justifies including this EAL.
B. The second EAL, i.e., " Inability to maintain RPV level over -172," appears to deviate from the NUMARC guidance. This deviation may cause a delay in classification which does not appear to be appropriate. Please provided additional information justifying this deviation.
Issue No.18 The NUMARC EAL forIC SA2 is:
(site-specifc indication exists that indicate that reactorprotection system setpoint was exceeded and automatic scram did not occur, and a successful manual scram occurred.
The corresponding PBAPS EALis Automatic RPS SCRAMshould occur due to RPS Serpoint being exceeded AND Failure ofAutomatic RPS Scram to reduce reactorpower <4%
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The PBAPS EAL deviates from the NUMARC guidance by including the "<4%" power condition. Although including a power level for the failure-to-scram has been determined to be acceptable in the Q&A's on the NUMARC EALs for the Site Area Emergency EAL, it was not deemed appropriate for the Alert level EAL. Please revise this EAL to remove the power level criteria or provide additional information justifying this deviation.
Issue No 19 The NUMARC EAL for the loss of RCS based upon drywell radiation monitoring is:
Drywell Rad Monitor Reading greater than (site-specifc) R/hr The guidance for determining the setpoint for this EAL is "The reading should be calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine
)
inventory associated with normal operating concentrations...."
Please provide a copy of the document ERP-C-1410 refered to in the Basis for this EAL.
The PBABS reading was established based upon technical specification limit concentrations.
Please justify use of these concentrations rather than normal operating concentrations.
Issue No. 20 The PBAPS EAL 6.1.1.b does not identify the specific DC buses for which this EAL is applicable. This information is included in the basis for this EAL. Please provide additional information which describes how the basis document is to be used in the classification process and how errors in classification will not occur if the specific buses are not included in the EAL itself.
Issue No. 21 The PBAPS EAL 6.1.4 includes the condition,"HPCI and RCIC unavailable for makeup and decay heat removal." Please provide additional information on the definition of" unavailable" as used in this EAL and how long the core cooling can be maintained without HPCI and RCIC operating.
Issue No. 22 NUMARC EAL SS4-1 is:
Complete loss ofany (site-specific) function requiredfor hot shutdown The corresponding PBAPS EAL (7.2.3) is:
l Loss ofMain Condenser as a heatsink
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Loss ofSuppression Pool heat sink capabilities as evidenced by T-102 legs requiring an
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15 Emergency Blowdown AND Either ofthefollowing conditions:
- Reactor Power >4%
Please provide additional information describing the relationship of this EAL to EALs using similar parameters (e.g., fission product barrier EALs and failure to scram EALs). In addition provide additional information justifying the use of the "RPV level cannot be restored above
-172" as a setpoint (which requiresjudgement) rather than a simple setpoint (e.g., RPV level less than -172").
IssueNo 23 NUMARC EAL HU2-1 is:
Fire in building or areas contiguous to any ofthefollowing (site-specipc) areas..
The corresponding PBAPS EAL (8.2.1.a) is:
Fire within SE-8 Plant Vital Structures (table 8-1)...
Please provide additional information how the areas listed in Table 8 1 relate to the " buildings or areas contiguous" specified in the NUMARC EAL and justify any deviations.
Issue No. 24 NUMARC EAL HU4-1 is:
"Alcle crash into plant structures or systems withinprotected area boundary The corresponding PBAPS EAL is:
Vehicle crash withinprotected area boundary that maypotentially damage structures containingfunctions andsystems requiredfor safe shutdown oftheplant The PBAPS EAL deviates from the NUMARC guidance by including the condition that the crash may damage structures containing functions and systems required for safe shutdown of the plant. This condition more closely correlates with the Alert classification level EAL for a vehicle crash Please provide additional informationjustifying this deviation.
Issue No. 25 Revision 20 of the PBAPS EAL scheme included EALs based upon Conowingo Pond level. The PBAPS EAL scheme based upon the NUMARC scheme did not include this EAL. Pleasejustify
.o 16 not including these EALs.
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