ML20195J142
| ML20195J142 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 11/16/1998 |
| From: | Geoffrey Edwards PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20195J148 | List: |
| References | |
| NUDOCS 9811240205 | |
| Download: ML20195J142 (48) | |
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t ttstion Support D*partmsnt A
V PECO NUCLEAR reco eme,9x cermoeev 965 Chestabrook Boulevard A Unit of PECO Energy Wayne, PA 19087 5691 November 16,1998 Docket Nos. 50-277 50-278 50-352 50-353 License Nos. DPR-44 DPR-56 NPF-39 NPF-85 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station, Units 2 and 3 Limerick Generating Station, Units 1 and 2 Response to Request for Additional Information Concerning Revised Emergency Action Levels
Dear Sir / Madam:
By letter dated April 16,1998, PECO Energy submitted revised Emergency Action Level (EAL) guidelines for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, and Limerick Generating Station (LGS), Units 1 and 2. These revised EALs were developed based on the guidance provided in NUMARC/NESP-007," Methodology for Development of Emergency Action Levels."
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By letter dated September 24,1998, the NRC identified a number of questions associated with the revised EALs for PBAPS and LGS in which additionalinformation was needed in order for I
the NRC to continue its review. The NRC requested that PECO Energy respond to the request for additional information (RAI) within 30 days of receipt of the NRC letter, which was received on September 30,1998. However, as a result of subsequent discussions with the NRC, the date for responding to this RAI was extended until November 16,1998.
Accordingly, the enclosures to this letter contain the responses to the RAls for PBAPS, Units 2 and 3, and LGS, Units 1 and 2. Enclosure 1 contains the response for PBAPS, and Enclosure 2 ~ /[g M
contains the response for LGS. Each question identified by the NRC has been restated fol' owed by our response. in addition, we are resubmitting complete sets of the EALs for PBAPS and LGS which have been revised, as appropriate, to reflect the changes discussed in this response to the request for additionalinformation. Attachment 1 contains the EALs for PBAPS, and
9811240205'981116 PDR ADOCK 05000277 F
November 16,1998 Page 2 If you have any questions or require additional information, please do not hesitate to contact us.
Very truly yours, Garrett D. Edwards Director-Licensing Enclosures Attachments H. J. Miller, Administrator, USNRC, Region I (w/ enclosures / attachments) cc:
A. C. McMurtray, USNRC Senior Resident inspector, PBAPS (w/ enclosures / attachments)
A. L. Burritt, USNRC Senior Resident inspector, LGS (w/ enclosures / attachments)
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ENCLOSURE 1 Peach Bottom Atomic Power Station Units 2 and 3 Response to Request for Additional Information 1
Revised Emergency Action Level Guidelines
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Docket Nos. 50-277/50 278 November 16,1998 Page1of22 Peach Bottom Atomic Power Station Units 2 and 3 Response to Reauest for AdditionalInformation Concemine Revised EALs The following provides PECO Energy's response to the NRC's request for additional infbrmation regarding the revised Emergency Action Level (EAL) guidelines for Peach Bottom Atomic Power Station, (PBAPS), Units 2 and 3. Each issue identified by the NRC is restated followed by our response.
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 Technical Specificationsfor 60 Minutes or Longer NUMARC/NESP-007 EAL AUl.1 associated with IC AUl is:
1.
A valid reading 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 PBAPS proposed EAL (5.1.1.a) is:
Main or Vent Stack Rad Monitor continuously in HiHi Alarm M known Unmonitored Release or use of Torus Hardened Vent continuously in progress QR Radwaste or Service Water Discharge Rad Monitor continuously in Hi Alarmfor > 60 minutes AND Calculated maximum offsite dose rate using computer dose model exceeds 0.114 mrem /hr IPARD @ 0.342 mrem /hr 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 NUM ARC /NESP-007 guidance.
B.
It is not clear whether the "> 60 minutes" condition applies to all monitors orjust to the i
Service Water Monitor. This may cause misapplication of this EAL. Please describe i
how this EAL is to be applied and how the EAL, as currently written, will not be misapplied.
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Docket Nos. 50-277/50-278 November 16,1998 Page 2 of 22 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) rate may cause confusion in classifying events using this EAL. Please provide additionaljustification for using these setpoints.
D.
The intent of NUMARC/NESP-007 ICs AUl and AAl is to use ODCM methadology to confirm thtt 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.
These issues also apply to PBAPS EAL 5.1.2.a Response to A EALs 5.1.1.a (UE) and 5.1.2.a (Alert) were revised to include monitor readings which indicate a potential to exceed 2 times and 200 times the Technical Specifications using the ODCM methodology. Also, a note was added to classify based on the sustained monitor reading if dose assessment cannot be performed.
Response to B The revision of EALs 5.1.1.a (UE) and 5.1.2.a (Alert) to address part A of this issue clarified that the "> 60 minutes" and "> 15 minutes" applies to all radiation monitors.
Response to C EAL Bases 5.1.1.a and 5.1.2.a were revised to clearly identify that TPARD and CDE are standard PECO Nuclear terminology and are included in the output of the computerized dose model MESOREM Jr.
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Response to D EALs 5.1.1.a,5.1.2.a and their bases were revised to clearly indicate the use of ODCM methodology to determine the appropriate monitor readings for indication of 2 times and 200 times technical specifications respectively. It is not the intent of NUMARC to use ODCM methodology to confirm that the release exceeds technical specification values; but, rather to indicate the need to assesc the release using dose projections. If the dose projections cannot be completed promptly, the event will be classified based on the sustained monitor readings.
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Docket Nos. 50-277/50-278 November 16,1998 Page 3 of 22 Issue No. 2 NUMARC/NESP-007 IC (IC) AS1 states:
Boundary Dose Resultingfrom an Actual or Imminent Release of Gaseous 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-specific list) 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 PBAPS proposed EAL (5.1.3)is:
Main or Vent Stack Rad Monitor continuously in HiHi Alarm Q8 known Unmonitored Release or use of Torus Hardened Vent continuously in progressfor > 15 minutes AND either :
Projected offsite dose using computer dose model exceeds 100 mrem TPARD, QR Projected offsite dose using computer dose model exceeds 500 mrem child thyroid CDE QE Valid dose assessment capability indicates dose consequences > 100 mrem TPARD, QR
> 500 mrem child thyroid CDE QE Analysis ofField Survey results indicates dose consequences > 100 mrem /hr expected to continuefor more than one hour QR Analysis ofField Survey results 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.
Docket Nos. 50-277/50-278 November 16,1998 Page 4 of 22 t
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B.
It is not clear whether the "> 15 minutes" condition applies to all monitors orjust to the l
Toms 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.
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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) rate may cause confusion in classifying events using this EAL. Please provide l
additionaljustification for using these setpoints.
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The intent of NUMARC/NESP-007 ICs AS1 and AG1 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.
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Please provide information regarding the difference between " projected offsite dose" and
" Valid dose assessment capability" as used in this PBAPS EAL.
1 These issues also apply to PBAPS EAL 5.1.4.
I Response to A EALs 5.1.3 and 5.1.4 were revised to include monitor readings which indicate exceeding 100(1000) mR TPARD or 500(5000) mR child thyroid CDE from dose projections using annual average meteorological conditions. Also, the note was added to classify based on the sustained monitor reading if dose assessment cannot be performed.
Response to B l
l The revision of EALs 5.1.3 (SAE) and 5.1.4 (GE) to address part A of this issue clarified that the
"> 60 minutes" and "> 15 minutes" applies to all radiation monitors.
Response to C EAL Bases 5.1.3 and 5.1.4 were revised to clearly identify that TPARD and CDE are standard PECO Nuclear terminology and are included in the output of the computerized dose model MESOREM Jr.
Response to D EALs 5.1.3 and 5.1.4 were revised to classify the event based on sustained monitor readings if the dose projections cannot be completed promptly.
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Docket Nos. 50-277/50-278 Enclosure i November 16,1998 Page 5 of 22 Response to E EALs 5.1.3 and 5.1.4 were revised to delete reference to " Valid dose assessment capability" as this is redundant to the " Projected offsite dose using computer dose model".
l Issue No. 3 NUMARC/NESP-007 IC AA3 states:
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Release ofRadioactive Material or increases in Radiation Levels Within the Facility That Impedes Operation ofSystems Required to Maintain Safe Operations or to Establish or l
Maintain Cold Shutdown l
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 safeorfunctions: (Site-specificlist)
The PBAPS proposed EAL (5.2.2.b) is:
Valid ControlRoom area radiation monitor reading > 15mR/hr A.
Justify limiting the PBAPS EAL to the Control Room when the corresponding NUMARCINESP-007 EAL relates to all " areas requiring continuous occupancy to maintain plant 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 continuously occupied.
Response
EAL 5.2.2.b and its bases were revised to include the Central Alarm Station as an area requiring continuous occupancy and justification that no other area requires continuous occupancy to maintain plant safety functions.
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Issue No. 4 l
NUMARC/NESP-007 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 Cold Shutdown L
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Docket Nos. 50-277/50-278 November 16,1998 Page 6 cf 22 l
NUMARC/NESP-007 EAL AA3.2 associated with IC AA3 is:
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Valid (Site-specific) radiation monitor readings GREATER THAN < site-specific > values in areas requiring infrequent access to maintain plant safety functions.
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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 AND Access is requiredfor safe plant operation, but is impeded, due to radiation dos.' rates A.
This EAL deviates from the NUMARC/NESP-007 guidance by including the condition "AND Access is requircJfor safeplant 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 informationjustifying 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 i
NUMARC/NESP-007 EAL suggests.
Response to A Including the condition "AND Access is required for safe plant operation, but is impeded, due to I
radiation dose rates" is not a deviation from NUMARC guidance. Although it is not included directly in the NUMARC Example EAL, the IC contains the statement: "That Impedes Operation of Systems Required to Maintain Safe Operations or to Establish or Maintain Cold Shutdown."
Additionally, the Basis states: " increased radiation levels that impede necessary access to operating stations,..., in order to maintain safe operation or perform a safe shutdown." By the plant design, safe operation and safe shutdown can be accomplished from the Control Room.
The necessity for entries into the plant to maintain plant safety functions is infrequent and used only as a backup to normal safety system functions in the Control Room. Elimination of the condition could lead to an inappropriate classification. The relative degradation in the level of safety in that circumstance is not commensurate with the definition of an Alert. The impeded access would only become significant if both the need for plant safety systems arises and the normal Control Room functions do not work. There is an extra layer of safety between the impeded access and the inability to perform plant safety functions. Also, the proposed EAL appears to be consistent with EALs proposed by other plants.
Docket Nos. 50-277/50-278 Enclosure i November 16,1998 Page 7 of 22 Response to B The Basis for EAL 5.2.2.a was revised to add additional information on use of a single value since it is based on personnel exposure control.
Issue No. 5 NUMARC/NESP-007 EAL FC2 is:
LOSS:
RPV level less than (site-specific) value The PBAPS proposed EAL (FC.2)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 detennine whether level cannot be restored. Pleasejustify 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
Response
EAL (FC.2) was revised removing the reference to "cannot be restored above."
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 AND Hi Steam Tunnel temperature Annunciator...
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Docket Nos. 50-277/50-278 Enclosure i November 16,1998 Page 8 of 22 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 concerns 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 barrier matrix.
Response
EAL (RC.1) was deleted and Isolable Main Steam Line Break was added as an Alert in EAL i
4.1.2 per the Q&A.
Issue No. 7 NUMARC/NESP-007 EAL PCl is:
LOSS:
Rapid unexplained decreasefollowing initial increase OR Dowellpressure response not consistent with LOCA conditions POTENTIAL L' SS:
O (Site-specific) psig and increasing OR explosive mixture exists The PBAPS proposed EAL (PC.1)is:
LOSS:
Rapid, unexplained decrease in Dowell Pressurefollowing initialincrease QR Dnwell pressure response not consistent with LOCA conditions POTENTIAL LOSS:
Dnwell Pressure > 49psig and increasing OR DrywellHydrogen > 6% AND Drywell Oxygen > 5%
A.
Please provide the deflagration limit curves used to detennine the 6% Hydrogen and 5%
Oxygen figures.
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Docket Nos. 50-277/50-278 Enclosure i November 16,1998 Page 9 of 22
Response
Deflagration limit curves are provided in ERP-C-1410-2, " Hydrogen Concentration Data," page 3 of 3. A copy of this procedure is being provided for your convenience.
Issue No. 8 NUMARC/NESP-007 Initiating Condition (IC) HAl states:
Natural and Destructive Phenomena Affecting the Plant Vital Area NUMARC/NESP-007 EAL HAl.3 is:
Report ofany visible structural damage on any ofthefollowingplant structures:
Reactor Building Intake Building Ultimate Heat Sink Refueling Water Storage Tank
- Diesel Generator Building Turbine Building Condensate Storage Tank ControlRooms Other (Site-specific) Structures The PBAPS proposed EAL (8.4.2.c) is:
Report ofany visible structural damage on any Pl ant 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.
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.
Response
The basis for EAL 8.4.2.c was revised to specifically identify those structures listed in the NUMARC guidance that do not contain equipment required for safe shutdowm.
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1 Docket Nos. 50-277/50-278
. November 16,1998 Page 10 of 22 Issue No. 9 NUMARC/NESP-007 Initiating Condition (IC) HA2 is:
Fire or Explosion Affecting 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-specyic) list a.
AND b.
Affected system parameter indications show degradedperformance orplant personnel report visible damage topermanent structures or equipment within the specified area 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 8-2)
Two orMore Safe Shutdown Systems M
Plant VitalStructures containing Safe Shutdown Equipment AND Safe Shutdown System or Plant Vital Structure 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 perfonnance."
B. The PB APS EAL requires that " Safe Shutdown System or Plant Vital Structure is required for thepresent 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.
C. The PBAPS EAL requires two or more subsystems of a safe shutdown system to be affected by the fire. The corresponding NUMARC/NESP-007 EAL does not include this condition.
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November 16,1998 Page 11 of 22 l
Please provide additional information that justifies these departures from the NUMARC/NESP-l 007 guidance.
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Response
PECO Energy does not believe that the fire EAL deviates from the intent of the NUMARC l
guidance which refers to the use of the safe shutdown analysis to determine system loss that is l
commensurate with appropriately quantifying the size of the fire and subsequently classifying.
No changes have been made at this time.
l 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 NUMARC/NESP-007 EALs HU4.1 and HU4.2 are:
- 1. Bomb device discovered within plant Protected Area and outside theplant 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 Protected Area M
Credible intrusion and attack threat to the Protected Area 2
Attempted intrusion and attack to the Protected Area Attempted sabotage discovered within ?he Protected / Vital Area M
Hostage / Extorsion situation that threatens normalplant operations A. PBAPS EAL basis states that "The Sh:ft Management will declare an Unusual Event subsequent to consulting with the Manager, Nuclear Security to determine the credibility of l
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-
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007 guidance. This comment also applies to SAL 8.1.2.
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DocketNos.50-277/50 278 November 16,1998 Page 12 of 22 '
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.
Response to A l
The basis for EALs 8.1.1 and 8.1.2 were revised to identify that the Shift Manager will consult with the on shift Security representative thereby not delaying the classification.
Response to B EAL 8.1.1 was revised to delete the reference to " Vital Area" which would more appropriately be l
classified as an Alert.
l' Issue No.11 l
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 Sigmpcant 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-specipc) 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 orIndicator loss does not resultfrom planned action.
AND d.
Either ofthefollowing:
1.
A significantplant transient is in progress.
OR 2.
Compensatory non-alarming indications are unavailable
Docket Nos. 50-277/50-278 November 16,1998 Pa;;e 13 of 22 The PBAPS proposed EAL (7.3.2) is:
Unplanned Loss ofmost or all safety system annunciators (Table 7-1) QR indicatorsfor
> 15 minutes requiring increased surveillance to safely operate the unit (s)
AND EITHER A signspcantplant transiert is in progress (Table 7-3) OR theplant monitoring system (PMS)is unavailable A. The PBAPS EAL and basis are not clear as to what constitute safety system indicators.
PBAPS 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 PBAPS EAL 7.3.1.a.
B. PBAPS EAL basis states "Although loss ofALL annunciators is specified. ifa largeportion ofannunciators or signipcant annunciators, as determined by the Shift Supervisor, are lost
.." for the " loss ofALL annunciators." This is inconsistent with the associated PBAPS EAL.
The basis should be corrected. This comment also applies to PBAPS EAL 7.3.1 and 7.3.3.
Response to A EALs 7.3.1.a,7.3.2, and 7.3.3 were revised to add a table for identifying safety function indicators.
Response to B The bases for EALs 7.3.1.a,7.3.2, and 7.3.3 revised to remove the discussion on loss of"All" annunciators.
Issue No.12 NUMARC/NESP-007 Initiating Condition (IC) sal states:
Loss ofAll Offsite Power and Loss ofAll Onsite AC Power to Essential Busses During Cold Shutdown Or Refueling Mode 1
Docket Nos. 50-277/50-278 November 16,1998 Page 14 of 22 NUMARC/NESP-007 EAL SA1.1 is:
- 1. Thefollowing conditions exist:
Loss ofpower to (Site-specylc) transformers.
a.
AND b.
Failure of(Site-specific) emergency generators to supplypower to emergency busses.
AND Failure to restorepower to at least one emergency bus within 15 minutesfrom the c.
time ofloss ofboth offsite and onsite ACpower.
The PBA>S 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 AND Failure to restorepower to at least One emergency bus within 15 minutesfrom the time ofloss ofboth ofsite and onsite 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) emergencygenerators to supplypower to emergency busses." Please provide l
additional information thatjustifies this departure from the NUMARC/NESP-007 guidance.
l This comment also applies to PBAPS EAL 6.1.3.a.
i B. The PBAPS EAL does not define " emergency bus." This may cause confusion in classifying l
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 of onsite AC power EALs.
Response to A i
l "b. Failure of(Site-specific) emergency generators to supply power to emergency busses" is redundant to item c (i.e., "c. Failure to restore power to at least one emergency bus within 15 minutes from the time ofloss of both offsite and onsite AC power.") This is a rewording for clarity and ease in implementing the EAL and is not considered a departure from the NUMARC guidance.
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Docket Nos. 50-277/50-278 November 16,1998 Page 15 of 22 Response to B All loss of onsite AC power EALs were revised to add the term "4 KV" to each reference
" emergency bus." This clearly identifies the emergency busses.
Issue No.13 NUMARC/NESP-007 IC SA3 is:
Inability to Maintain Plant in Cold Shutdown NUMARC/NESP-007 EAL SA3.1 is:
- 1. Thefollowing conditions exist:
Loss of(Site-specific) Technical Specification requiredfunctions to maintain cold a.
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 PBAPS proposed EAL (7.2.2)is:
Loss ofShutdown Cooling AND Uncontrolled Temperature increase that either:
Exceeds 212 *F G
Results in temperature rise approaching 212 F A. The term " Loss ofShutdown Cooling"in the PBAPS EAL is not dermed. The PBAPS 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.
Docket Nos. 50-277/50-278 November 16,1998 Page 16 of 22
Response
EAL 7.2.2 was revised to provide specific procedural guidance in determining the loss of decay heat removal function.
Issue No.14 NUMARC/NESP-007 Initiating Condition (IC) AU2 is:
Fuel CladDegradation NUMARC/NESP-007 EAL AU2.2 is:
Uncontrolled water level decrease in the spentfuelpool andfuel transfer canal with all irradiatedfitel assemblies remaining covered by water The PB APS 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:
... During refueling operations, RPVlevelindication is read on Panel 005..
A. It does not appear to be appropriate to limit the statement "RPVlevelindication is read on Panel 005"in the basis to refueling operations. Please modify the basis or provide additional information for including this statement.
Response
The basis for EAL 1.2.1.a was revised to delete the reference to RPV level indication. It is not appropriate in this EAL.
Issue No.15 NUMARC/NESP-007 Initiating Condition (IC) AA2 states:
Major Damage to Irradiated Fuel or Loss ofIVater Level that Has or TVill Result in the Uncovering offrradiated Fuel Outside the Reactor Vessel
Docket Nos. 50-277/50-278 Enclosure i November 16,1998 Page 17 of 22 NUMARC/NESP-007 EALs AA2.3 and AA2.4 are:
FVater Levelless than (site-specific)feetfor the Reactor Refueling Cavity that will result in Irradiated Fuel Uncovering IVater Levelless than (site-specific)feetfor the Spent Fuel Pool and Fuel Transfer Canal that will result in Irradiated Fuel Uncovering The corresponding PBAPS EALs (1.2.2.c and d) are:
TVater Level < 22 feet above RPVflangefor the Reactor Refueling Cavity that will result in IrradiatedFuel Uncovering IVater Level < 22feetfor the Spent Ft.el Pool that IVill 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.
A
Response
EALs 1.2.2.c and 1.2.2.d were revised to be consistent with the new Peach Bottom Improved Technical Specifications. The "<22 feet" has been changed to 458 inches above instrument zero and 232 ft 3 inches plant elevation respectively for the Reactor Cavity and Fuel Pool. These were chosen since they are already being monitored for compliance. RPV level instrumentation is available for monitoring level in the Reactor cavity and fuel pool level is monitored by visual observation triggered by annunciation of Skimmer Surge Tank low level.
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 ofcooling. The PBAPS basis may be misleading as to the potential significance of a loss of water in the fuel pool event. Please provide additional informationjustifying the PBAPS basis statements.
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Response
The basis for EAL 1.2.2.b has been revised to emphasize the potential significance of a loss of water in the fuel pool event.
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Issue No 17
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NUMARC IC SSS contains the following EALs:
L I-Loss ofreactor vessel water level as indicated by:
- Loss ofalldecay heat removalcooling....
and
- (site-specific) indicators that the core is or will be uncovered.
l 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 i
and
- Inability to maintain RPVlevel over -172" i
In the basis for the PBAPS EALs it is stated that:
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Prior to concluding that RPYlevel cannot be maintained, consideration must be given to injection system m'ailability and status am! trend ofthe rate at which RPVlevel is l
decreasing. Ample time should be allottea to analyze the ability ofinjection sources...
A. Even though the first EAL, i.e., " Loss of all decay heat rernoval 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.
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B. The second EAL, i.e., " Inability to ruaintain RPV level over -172"," appears to deviate from I
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.
i Response to A EAL 2.1.3 was revised and the first condition (i.e.," Loss of all decay heat removal cooling as l
L determined...") was deleted.
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Docket Nos. 50-277/50-278 November 16,1998 Page 19 of 22 l
Response to B l'
' EAL 2.1.3 and basis were revised to specify classification on RPV level < -172" with no delay.
. Issue No.18 l
l-L The NUMARC EAL for IC SA2 is:
(site-specipe indication exists that indicate that reactorprotection system setpoint was exceeded and automatic scram did not occur, and c successful manual scram occurred.
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The corresponding PBAPS EAL is l
Automatic RPS SCRAM should occur due to RPS Setpoint being exceeded l
AND Failure ofAutomatic RPS Scram to reduce reactorpower <4%
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 fu the Site Area Emergency EAL, it was not deemed appropriate for the_ Alert level EAL. P' ease revise this EAL to remove the power level criteria or provide additional information justifying this deviation.
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Response
EAL 2.2.2 was revised to remove the power level criteria and use " shutdown" as the trigger for determining if the automatic scram was successful.
Issue No 19 l-sThe NUMARC EAL for the loss of RCS based upon drywell radiation monitoring is:
Drywell Rad Monitor Reading greater than (site-specipc) R/hr l
The guidance for determining the setpoint for this EAL is "The reading should be calculated L
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 referred to in the Basis for this EAL.
The PBABS reading was established based upon technical specification limit concentrations.
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. Pleasejustify use of these concentrations rather than normal operating concentrations.
l Docket Nos. 50-277/50-278 November 16,1998 Page 20 of 22
Response
A copy of ERP-C-1410 is provided in Exhibit 1. EAL RC.3 was revised based on isotopic concentrations aligned closer to 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 enors in classification will not occur if the specific buses are not included in the EAL itself.
Response
EALs 6.1.1.b and 6.1.3.b were revised with vital DC panel numbers added.
Issue No. 21 The PBAPS EAL 6.1.4 includes the condition,"HPCI and RCIC unavailable for makeup and decay heat removal." Please provHe additional information or, the definition of" unavailable" as used in this EAL and how long the core cooling can be maintained without HPCI and RCIC operating.
Response
EAL 6.1.4 was revised to delete the phrase "HPCI and RCIC unavailable for makeup and decay heat removal," since it is considered redundant to maintaining Reactor Water Level above TAF.
This was removed in order to simplify the EAL so that attention would not be drawn away from the important parameters while evaluating the " availability" of HPCI and RCIC.
Issue No. 22 NUMARC EAL SS4.1 is:
Complete loss ofany (site-specific) function requiredfor hot shutdown
Docket Nos. 50-277/50-278 November 16,1998 Page 21 of 22 The corresponding PBAPS 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:
RPV level cannot be restored above -172"
+
OR 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 requires judgement) rather than a simple setpoint (e.g., RPV level less than -172").
Response
EAL 7.2.3 was revised to delete reference "cannot be restored above."
Issue No 23 NUMARC EAL HU2.1 is:
Fire in building or areas contiguous to any ofthefollowing (site-specific) areas.
The corresponding PBAPS EAL (8.2.1.a) is:
Fire within SE-8 Plant VitalStructures (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.
Response
The basis for EAL 8.2.1.a was revised to address the NUMARC referenced areas / buildings contiguous to plant vital areas. There are no additional areas / buildings that could effect safety I
systems except what is already on the list.
l Docket Nos. 50-277/50-278 November 16,1998 Page 22 of 22 Issue No. 24 i
Vehicle crash into plant structures or systems within protected area boundary l
The corresponding PBAPS EAL is:
Yehicle crash within protected area boundary that maypotentially damage structures l
containingfunctions and systems requiredfor safe shutdown oftheplant L
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 l
plant. This condition more closely correlates with the Alert classification level EAL for a vehicle crash. Please provide additional informationjustifying this deviation.
Response
This EAL does not deviate from the NUMARC bases which states: "EAL 4 is intended to address such items as plane or helicopter crash,... that may potentially damage plant structures containing functions and systems required for safe shutdown of the plant." Use of these words in the EAL is necessary to provide adequate guidance to the shift in making accurate declarations.
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 l
not including these EALs.
Response
The PBAPS EAL scheme includes EALs based on River level which is the proper terminology for the pond and is consistent with Technical Specifications.
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1 ENCLOSURE 2 Limerick Generating Station Units 1 and 2 t
r Response to Request for Additional Information Revised Emergency Action Level Guidelines t
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Docket Nos. 50-352/352 November 16,1998 Page 1 of 22 Limerick Generating Station Units 1 and 2 ~
Resoonse to Reauest for Additional Information Concerning Revised EALs The following provides PECO Energy's response to the NRC's request for additional information regarding the revised Emergency Action Level (EAL) guidelines for Limerick Generating Station (LGS), Units 1 and 2. Each issue identified by the NRC is restated followed by our response.
Issue No.1 NUMARC/NESP-007 Initiating Condition (IC) AUl is:
Any Unplanned Release ofGaseous or Liquid Radioactivity to the Environment that
. &ceeds Two Times the Radiological Technical Specificationsfor 60 Minutes or Longer NUMARC/NESP-007 EAL AUl.1 associated with IC AUl is:
1.
A valid reading 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 LGS proposed EAL (5.1.1.a) is:
North or South Stack Rad Monitor continuously in HiHi Alarm M known Unmonitored Release continuously in progress @ Radwaste or Cooling Tower Blowdown Discharge Rad Monitor continuously in Hi Alarmfor > 60 minutes AND Calculated maximum
. offsite dose rate using computer dose model exceeds 0.114 mrem /hr TPARD M O.342 mrem /hr child thyroid CDE based on a 60 minute average A.
Pleasejustify why readings on site-specific monitors were not included in this EAL as l
called for in the NUMARC/NESP-007 guidance.
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.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 written, will not be misapplied.
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Docket Nos. 50 352/352 November 16,1998 Page 2 of 22 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) rate 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 AUl and AAl 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 guicance.
These issues also apply to LGS EAL 5.1.2.a Response to A EALs 5.1.1.a (UE) and 5.1.2.a (Alert) were revised to include monitor readings which indicate a potential to exceed 2 times and 200 times the Technical Specifications using the ODCM methodology. Also, a note was added to classify based on the sustained monitor reading if dose assessment cannot be performed.
Response to B The revision of EALs 5.1.1.a (UE) and 5.1.2.a (Alert) to address part A of this issue clarified that the "> 60 minutes" and "> 15 minutes" applies to all radiation monitors.
Response to C EAL Bases 5.1.1.a and 5.1.2.a were revised to clearly identify that TPARD and CDE are standard PECO Nuclear terminology and are included in the output of the computerized dose model MESOREM Jr.
Response to D EALs 5.1.1.a,5.1.2.a and their bases were revised to clearly indicate the use of ODCM methodology to determine the appropriate monitor readings for indication of 2 times and 200 times technical specifications respectively. It is not the intent of NUMARC to use ODCM methodology to confirm that the release exceeds technical specification values; but, rather to indicate the need to assess the release using dose projections. If the dose projections cannot be completed promptly, the event will be classified based on the sustained monitor readings.
Docket Nos. 50-352/352 November 16,1998 Page 3 of 22 Issue No. 2 NUMARC/NESP-007 IC ASI is:
Boundary Dose Resultingfrom an Actual orImminent 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 AS1 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-specific list) 3.
Valid dose assessment capability indicates dose consequences greater than 100 mR whole body or500 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 & known Unmonitored Release continuously in progressfor > 15 minutes AND either :
Projected offsite dose using computer dose model exceeds 100 mrem TPARD, M Projected offsite dose using computer dose model exceeds 500 mrem child thyroid CDE 2
Valid dose assessment capability indicates dose consequences > 100 mrem TPARD, M
> 500 mrem child thyroid CDE 2
Analysis ofField Survey results indicates dose consequences > 100 mrem /hr expected to continuefor more than one hour, & Analysis ofField Survey results indicate child thyroid dose commitment of500 mRemfor one hour ofinhalation A.
Pleasejustify 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.
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l Docket Nos. 50-352/352 l
November 16,1998 Page 4 of 22 l
C.
The use of the dose unit "TPARD" in place of a more common dose unit such as Total i
Effective Dose Equivalent (TEDE) and the use of Committed Dose Equivalent (CDE) rate may cause confusion in classifying events using this EAL. Please provide additional justification for using these serpoints.
f D.
The intent of NUMARC/NESP-007 ICs AS1 and AG1 is to confirm that release exceeded
- c. -tair. dose limits using a real-time dose assessment. This confirmation is only used ifit
. n be completed promptly (i.e., within 15 minutes). Otherwise the event is to be 2
classified based upon the monitor reading. Please provide information regarding how 4
i LGS's EAL meets the intent of the NUMARC/NESP-007 guidance.
l E.
Please provide information regarding the difference between " projected offsite dose" and
" Valid dose assessment capability" as used in this LGS EAL.
l These issues also apply to LGS EAL 5.1.4.
Response to A e
EALs 5.1.3 and 5.1.4 were revised to include monitor readings which indicate exceeding 100(1000) mR TPARD or 500(5000) mR child thyroid CDE from dose projections using annual i
average meteorological conditions. Also, a note was added to classify based on the sustained monitor reading if dose assessment cannot be performed.
Response to B The revision of EALs 5.1.3 (SAE) and 5.1.4 (GE) to address part A of this issue clarified that the
"> 60 minutes" and "> 15 minutes" applies to all radiation monitors.
Response to C
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EAL Bases 5.1.3 and 5.1.4 were revised to clearly identify that TPARD and CDE are standard PECO Energy terminology and are included in the output of the computerized dose model MESOREM Jr.
Response to D EALs 5.1.3 and 5.1.4 were revised to classify the event based on sustained monitor readings if the dose projections cannot be completed promptly.
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l Docket Nos. 50-352/352 November 16,1998 Page 5 of 22 i
Response to E l
EALs 5.1.3 and 5.1.4 were revised to delete reference to " Valid dose assessment capability" as this is redundant to the " Projected offsite dose using computer dose model."
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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 Cold Shutdown NUMARC/NESP-007 EAL AA3.1 associated with IC AA3 is:
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.L Valid (Site-specific) radiation monitor readings GREA TER THAN 15 mR/hr in areas requiring continuous occupancy to maintain plant safetyfunctionsi (Site-specificlist)
The LGS proposed EAL (5.2.2.b) is:
j Valid Control Room area radiation monitor reading > 15mR/hr A.
Justify limiting the LGS EAL to the Control Room when the corresponding NUMARC/NESP-007 EAL relates to all " areas requiring continuous occupancy to i
maintain plant 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 L
continuously occupied.
Response
i EAL 5.2.2.b and its bases were revised to include the Central Alarm Station as an area requiring continuous occupancy and justification that no other area requires continuous occupancy to maintain plant safety functions.
l Issue No. 4 l
NUMARC/NESP-007 IC AA3 is:
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Release ofRadioactive Material orincreases in Radiation Levels Within the Facility That
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. Impedes Operation ofSystems Required to Maintain Safe Operations or to Establish or l
Maintain Cold Shutdown
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November 16,1998 Page 6 of 22 I
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-l 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
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maintain plant safetyfunctions as identified in procedure SE-1 or SE-6 ANQ Access is requiredfor safeplant operation, but is impeded, due to radiation dose rates A.
This EAL deviates from the NUMARC/NESP-007 guidance by including the condition "dNQ Access is requiredfor safe plant operation, but is impeded. due to radiation dose l
rates. ". Such a condition could delay the emergency classification in cases where i
immediate access to the areas in question is not required. Please provide additional l
information justifying this deviation.
i 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.
l Response to A Including the condition " A_NQ Access is required for safe plant operation, but is impeded, due to l
radiation dose rates" is not a deviation from NUMARC guidance. Although it is not included' I
directly in the NUMARC Example EAL, the IC contains the statement: "That Impedes Operation l
of Systems Required to Maintain Safe Operations or to Establish or Maintain Cold Shutdown."
l Additionally, the Basis states: " increased radiation levels that impede necessary access to L
. operating stations,..., in order to maintain safe operation or perform a safe shutdown." By the l
plant design, safe operation and safe shutdown can be accomplished from the Control Room.
l The necessity for entries into the plant to maintain plant safety functions is infrequent and used l
' only as a backup to nonnal safety system functions in the Control Room. Elimination of the condition could lead to an inappropriate classification. The relative degradation in the level of safety in that circumstance is not commensurate with the definition of an Alert. The impeded access would only become significant if both the need for plant safety systems arises and the normal Control Room functions do not work. There is an extra layer of safety between the impeded access and the inability to perform plant safety functions. Also, the proposed EAL appears to be consistent with EALs proposed by other plants.-
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Docket Nos. 50-352/352
. November 16,1998 Page 7 of 22
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= Response to B The Basis for EAL 5.2.2.a was revised to add additional information on use of a single value l
since it is based on personnel exposure control.
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Issue No. 5 l
l NUMARC/NESP-007 EAL FC2 for the loss of the fuel clad barrier is:
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l LOSS-
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RPV level le:.s than (site-specific) value i
- The LGS proposed EAL (FC.2)is:
LOSS-
' RPV level cannot be restored above -204"
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' 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.
Response
EAL (FC.2) was revised removing the reference to "cannot be restored above."
l-l Issue No. 6-l.-
NUMARC/NESP-007 EAL RCl for the loss of the reactor coolant system barrier is:
LOSS:
(site-specific) indication ofa Main Steam Line Break L
The LGS proposed EAL (RC.1)is:
j LOSS-Hi Steam Low Annunciator AND Hi Steam Tunnel temperature Annunciator....
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Docket Nos. 50-352/352 November 16,1998 Page 8 of 22 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. Pleasejustify why this EAL is included in the LGS fission product barrier matrix.
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Response
j EAL (RC.1) was deleted and Isolable Main Steam Line Break was added as an Alert in EAL 4.1.2 per the Q&A.
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Issue No. 7 l
NUMARC/NESP-007 EAL PCI for the loss of the containment barrier is:
L LOSS-Rapid unexplained decreasefollowing initial increase OR Drywellpressure response not consistent with LOCA conditions POTENTIAL LOSS:
(Site-specylc) psig and increasing OR explosive mixture exists TL: LGS proposed EAL (PC.1)is:
LOSS-Rapid, unexplained decrease in Drywell Pressurefollowing initial increase DR Drywell pressure response not consistent with LOCA conditions POTENTIAL LOSS:
Drywell Pressure > 44 psig and increasing OR DrywellHydrogen > 6% AND Drywell Oxygen > 5%
A.
Please provide the deflagration limit curves used to determine the 6% Hydrogen and 5%
Oxygen figures.
Response
Deflagration limit curves are provided in ERP-C-1410-2, " Hydrogen Concentration Data," page 3 of 3. A copy of this procedure is provided in Exhibit 1 for your convenience.
i Docket Nos. 50-352/352 November 16,1998 Page 9 of 22 Issue No. 8 NUMARC/NESP-007 IC HA1 is:
Naturaland Destructive Phenomena Affecting the Plant Vital Area NUMARC/NESP-007 EAL HA1.3 is:
i Report ofany visible structural damage on any ofthefollowingplant structures:
Reactor Building Intake Building Ultimate Heat Sink Refueling Water Storage Tank Diesel Generator Building Turbine Building Condensate Storage Tank ControlRooms Other (Site-specific) Structures The LGS proposed EAL (8.4.2.c)is:
Report ofany visible structural damage on any Plant Vital Structure (Table 8-1)
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.
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.
Response
The basis for EAL 8.4.2.c was revised to specifically identify those structures listed in the NUMARC guidance that do not contain equipment required for safe shutdown.
Issue No. 9 j.
NUMARC/NESP-007 IC HA2 is:
4 Fire or Erplosion Affecting the Operability ofPlant Safey Systems Required to Establish i
or Maintain Safe Shutdown l
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Docket Nos. 50-352/352 November 16,1998 Page 10 of 22 NUMARC/NESP-007 EAL HA2.1 is:
- 1. Thefollowing conditions exist:
Fire or explosion in any ofthefollowing (Site-specific) areas: (Site-specific) list a.
AND b.
Affected system parameter indications show degradedperformance orplant personnel report visible damage topermanent structures or equipment within the specified area 1
The LGS proposed EAL (8.2.2.a) is:
Thefollowing conditions exist:
Fire or explosion which makes inoperable:
Two or Afore subsystems or a Safe Shutdown System (Table 8-2)
G Two or Afore Safe Shutdown Systems M
Plant VitalStructures containing Safe Shutdown Equipment AND Safe Shutdown System or Plant Vital Structure is requiredfor thepresent Operational Condition 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 Vital Structure is requiredfor thepresent 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.
C. The LGS EAL requires two or more subsystems of a safe shutdown system to be affected by the fire. The corresponding NUMARC/NESP-007 EAL does not include this condition.
i Please provide additional information thatjustifies these departures from the NUMARC/NESP-t 007 guidance.
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l DocketNos 50-352/352 November 16,1998 Page 11 of 22 Response-i l
PECO Energy does not believe that the fire EAL deviates from the intent of the NUMARC j
guidance which refers to the use of the safe shutdown analysis to determine system loss that is 1
- commensurate with appropriately quantifying the size of the fire and subsequently classifying.
No changes have been made at this time.
Issue No.10 NUMARC/NESP-007 IC HU4 is:
Confirmed Security Event Which Indicates a Potential Degradation in the Level ofSafety ofthePlant NUMARC/NESP-007 EALs HU4.1 and HU4.2 are:
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- i. Bomb device discovered within plant Protected Area and outside theplant Vital Area.
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- 2. Other security events as determinedfrom (Site-specific) Safeguards Contingency Plan.
l The LGS proposed EAL-(8.1.1)is:
j Credible sabotage or bomb threat within the Protected Area DE Credible intrusion and attack threat to the Protected Area DE Attempted intrusion and attack to the Protected Area DE Attempted sabotage discovered within the Protected / Vital 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 NUMARC/NESP-007 guidance.
This comment also applies to EAL 8.1.2.
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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.
Response to.A The basis for EALs 8.1.1 and 8.1.2 were revised to identify that the Shift Manager will consult with the on shift Security representative thereby not delaying the classification.
Response to B EAL 8.1.1 was revised to delete the reference to " Vital Area" which would more appropriately be classified as an Alert.
l Issue No.11 NUMARC/NESP-007 IC SA4 is:
Unplanned Loss ofMost or All Safety System Annunciation or Indication In Control V
Room With Either (1) a Significant Transient in Progress, or (2) Compensatory Non-AlarmingIndicators are Unavailable NUMARC/NESP-007 EAL SA4.1 is:
- 1. Thefollowing conditions exist:
l Loss ofmost or all(Site-specific) annunciators associated with safety systemsfor l
a.
l 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 significant plant transient is in progress.
OR 2.
Compensatory non-alarming indications are unavailable
l Docket Nos. 50-352/352 November 16,1998 Page 13 of 22 The LGS proposed EAL (7.3.2) is:
Unplanned Loss ofmost or all safety system annunciators (Table 7-1) OR indicatorsfor
> 15 minutes requiring increased surveillance to safely operate the unit (s)
AND EITHER A significant plant transient is in progress (Table 7-3) OR theplant 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 specified, ifa largeportion of i
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.
l Response to A EALs 7.3.1.a,7.3.2, and 7.3.3 were revised to add a table for identifying safety function indicators.
Response to B The bases for EALs 7.3.1.a,7.3.2, and 7.3.3 were revised to remove the discussion on loss of "All" annunciators.
Issue No.12 NUMARC/NESP-007 IC sal is:
. Loss ofAll Offsite Power and Loss ofAll Onsite A C Power to Essential Busses During Cold Shutdown Or Refueling Mode l
NUMARC/NESP-007 EAL sal.1 is:
- 1. Thefollowing conditions exist:
Loss ofpower to (Site-specific) transformers.
l a.
l AND b.
Failure of(Site-specific) emergency generators to supply power to emergency busses.
AND a
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- Dceket Nos. 50-352/352
. November 16,1998 Page 14 of 22 Failure to restorepower to at least one emergency bus within 15 minutesfrom the c.
time ofloss ofboth offsite and onsite ACpower.
The LGS proposed EAL (6.1.2.b) is:
Thefollowing conditions exist:
Loss ofPower to 101 and 201 Safeguard Transformers AND Failure to restorepower 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-
- pecific) 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 LGS 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 orjustify not providing this definition. This comment also applies to the other loss ofonsite AC power EALs.
Response to A-
"b. Failure of(Site-specific) emergency generators to supply power to emergency busses" is credundant to item c (i.e., "c. Failure to restore power to at least one emergency bus within 15 minutes from the time ofloss of both offsite and onsite AC power"). This is a rewording for clarity and ease in implementing the EAL and is not considered a departure from the NUMARC guidance.
Response to B
- All loss of onsite AC power EALs were revised to add the term "4 KV" to each reference "emergency bus." This clearly identifies the emergency busses.
Issue No.13 NUMARC/NESP-007 IC SA3 is:
Inability to Maintain Plant in Cold Shutdown
Docket Nos. 50-352/352 November 16,1998 Page 15 of 22 NUMARC/NESP-007 EAL SA3.1 is:
i
- 1. Thefollowing conditions exist:
Loss of(Site-specific) Technical Specification requiredfunctions to maintain cold a.
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 LGS proposed EAL (7.2.2) is:
Loss ofShutdown Cooling l'
AND Uncontrolled Temperature increase that either:
Exceeds 200*F DE Results in temperature rise approaching 200 F i
, A. The term " Loss ofShutdown Cooling'in the LGS EAL is not defined. The LGS EAL should i
l be supplemented to indicate what constitutes " Loss ofShutdown Cooling" or additional information should be provided regarding how this EAL is to be applied.
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Response
l EAL 7.2.2 was revised to provide specific procedural guidance in determining the loss of decay heat removal function.
Issue No.14 i
NUMARC/NESP-007 IC AU2 is:
l Fuel CladDegradation l
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Docket Nos. 50-352/352 November 16,1998 Page 16 of 22 i
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 LOS proposed EAL (1.2.1.a) is:
Uncontrolled water level decrease in the spentfuelpool with all irradiatedfuel assemblies remaining covered by water l
The LGS proposed basis for this EAL is:
... During refueling operations, RPVlevel indication is read on Panel C602...
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A. It does not appear to be appropriate to limit the statement "RPVlevelindication is read on l
Panel C602"in the basis to refueling operations. Please modify the basis or provide l
additional information for including this statement.
Response
L I
The basis for EAL 1.2.1.a was revised to delete the reference to RPV level indication. It is not appropriate in this EAL.
Issue No.15 NUMARC/NESP-007 IC AA2 is:
1-Major Damage to Irradiated Fuel or Loss of Water Level that Has or Will Result in the l-Uncovering ofIrradiated Fuel Outside the Reactor Vessel l
NUMARC/NESP-007 EALs AA2.3 and AA2.4 are:
Water Levelless than (site-specific)feetfor the Reactor Refueling Cavity that will result inIrradiated Fuel Uncovering Water Level less than (site-specific)feetfor the Spent Fuel Pool and Fuel Transfer Canal that will result in Irradiated Fuel Uncovering L.
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 Irradiated Fuel Uncovering.
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l Docket Nos. 50-352/352 November 16,1998 Page 17 of 22 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.
L
Response
EAL 1.2.2.d was revised to be consistent with Technical Specifications. The Technical Specifications limit is "<22 feet." This value was chosen since it is already being monitored.
RPV level instrumentation is available for monitoring level in the Reactor cavity and fuel pool level is monitored by visual observation triggered by annunciation oflow Fuel Pool Storage level.
Issue No.16 l
l The basis of LGS proposed EAL 1.2.2.b discusses events involving the loss of water level that l
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 L
Safety and Regulatory Assessment of Generic BWR and PWR Permanently Shutdown Nuclear l
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
. justifying the LGS basis statements.
l
Response
The basis for EAL 1.2.2.b has been revised to emphasize the potential significance of a loss of water in the fuel pool event.
Issue No 17 NUMARC IC SS5 contains the following EALs:
Loss ofreactor vessel water level as indicated by:
- Loss ofall decay heat removal cooling....
and
- (site-specyic) indicators that the core is or will be uncovered.
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l Docket Nos. 50-352/352 November 16,1998 Page 18 of 22 The corresponding LGS EALs (2.1.3) are:
Loss ofreactor vessel water level as indicated by:
- Loss ofalldecay heat removal cooling as determined byprocedure GP-6.2 and
- Inability to maintain RPYlevelover-161"
.. In the basis for the LGS EALs it is stated that:
Prior to concluding that RPVlevel cannot be maintained, consideration must be given to l.
injection system availability andstatus and trend ofthe rate at which RPVlevelis decreasing. Ample time should be allotted to analpe the ability ofinjection sources...
L L
A. Even though the first condition, 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 condition in thisEAL.
1 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 informationjustifying this deviation.
l Response to A EAL 2.1.3 was revised and first condition (i.e., " Loss of all decay heat removal cooling as determined by procedure...") was deleted.
Response to B L
I EAL 2.1.3 and the basis were revised to specify classification on RPV level < -161" with no delay.
Issue No.18 l
The NUMARC EAL' for IC SA2 is:
(site-specific indication exists that indicate that reactorprotection system setpoint was exceeded and automatic scram did not occur, and a successful manual scram occurred..
l e
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Docket Nos. 50-352/352 November 16,1998 Page 19 of 22 i
l The corresponding LGS EAL (2.2.2)is l
Automatic RPS SCR 4Af should occur due to RPS Setpoint being exceeded
}
l AND i
\\
Failure ofAutomatic RPS Scram 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 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 l
provide additional information justifying this deviation.
Response
l EAL 2.2.2 was revised to remove the power level criteria and use " shutdown" as the trigger for determining if the automatic scram was successful.
f Issue No 19 t
The NUMARC EAL for the loss of RCS based upon drywell radiation monitoring is:
Drywell Rad Afonitor Reading greater than (site-specific) R/hr l
l The guidance for determining the setpoint for this EAL is "The reading should be calculated L
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 l'
Please provide a copy of the document ERP-C-1410 referred to in the Basis for this EAL.
l The LGS reading was established based upon technical specification limit concentrations. Please justify use of these concentrations rather than normal operating concentrations.
Response
A copy of ERP-C-1410 is provided in Exhibit 1. EAL RC.3 was revised based on isotopic j
concentrations aligned closer to normal operating concentrations.
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l Docket Nos. 50-352/352 November 16,1998 Page 20 of 22 i
Issue No. 20 L
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.
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Respense j
EALs 6.1.1.b and 6.1.3.b were revised with vital DC panel numbers added.
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Issue No. 21 L
The LGS EAL 6.1.4 includes the condition, "HPCI and RCIC unavailable for makeup and decay l
heat removal." Please provide additional infonnation on the definition of" unavailable" as used in this EAL and how long the core cooling can be maintained without HPCI and RCIC operating.
Response
EAL 6.1.4 was revised to delete the phrase: "HPCI and RCIC unavailable for makeup and decay heat removal," since it is considered redundant to maintaining Reactor Water Level above TAF.
This was removed in order to simplify the EAL so that attention would not be drawn away from j
the important parameters while evaluating the " availability" of HPCI and RCIC.
Issue No. 22 NUMARC EAL SS4.1 is:
l l
Complete loss ofany (site-specylc) 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 i
AND Either ofthefollowing conditions:
RPV level cannot be restored above -161" OR f
Reactor Power >4%
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i Docket Nos. 50-352/352
. Enclosure 2
' November 16,1998 Page 21 of 22 i
1 Please provide additional information describing the relationship of this EAL to EALs using
~ imilar parameters'(e.g., fission product barrier EALs and failure to scram EALs). In addition s
provide additional information justifying the use of the "RPV level cannot be restored above I
l
. -161" as a setpoint (which requires judgement) rather than a simple setpoint (e.g., RPV level less than -161").
l I
Response.
> EAL 7.2.3 revised to delete reference "cannot be restored above."
Issue No 23 L
Fire in building or areas contiguous to any ofthefollowing (site-specific) areas..
The corresponding LGS EAL (8.2.1.a) is:
Fire within SE-8 Plant Vital Stnictures (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.
Response
The basis for EAL 8.2.1.a was revised to address the NUMARC referenced areas / buildings contiguous to plant vital areas. There are no additional areas / buildings that could effect safety
' systems except what is already on the list.
I Issue No. 24 l
l l.
Vehicle crash intoplant structures or systems within protected area boundary The corresponding LGS EAL (8.3.1.a) is:
l Vehicle crash within protected area boundary that maypotentially damage structures containingfunctions and systems requiredfor safe shutdown oftheplant i'
I I
.-.....a,
. ~.. - - _, - -,,, -
~
.. ~ -. - _.. -
Docket Nos. 50-352/352 November 16,1998 Page 22 of 22 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 information justifying this deviation.
Response
i PECO Energy does not believe that this EAL deviates from the NUMARC bases which states:
"EAL 4 is intended to address such items as plane or helicopter crash.... that may potentially damage plant structures containing functions and systems required for safe shutdown of the plant." Use of these words in the EAL is necessary to provide adequate guidance to the shift in making accurate declarations.
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