ML20198G139
| ML20198G139 | |
| Person / Time | |
|---|---|
| Issue date: | 12/22/1998 |
| From: | Stewart Magruder NRC (Affiliation Not Assigned) |
| To: | Essig T NRC (Affiliation Not Assigned) |
| References | |
| PROJECT-689 NUDOCS 9812280302 | |
| Download: ML20198G139 (22) | |
Text
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December 22, 1998 MEMORANDUM TO: Thomas H. Essig, Acting Chief Generic Issues and Environmental Projects Branch Division of Reactor Program Management Offics of Nuclear Reactor Regulation FROM:
Stewart L. Magruder, Project Manager Original Signed By:
Generic Issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF DECEMBER 11,1998, MEETING WITH THE NUCLEAR i
l ENERGY INSTITUTE (NEI) REGARDING PROPOSED REVISION TO EMERGENCY ACTION LEVEL GUIDANCE l
On December 11,1998, repcesentatives of the Nuclear Energy Institute (NEI) met with representatives of the Nuclear Regulatory Commission (NRC) at the NEl offices in Washington, DC. The purpose of the meeting was to discuss NRC comments on an industry-proposed r6 vision to emergency action level (EAL) guidance. Attachment 1 provides a list of meeting attendees.
in a letter dated November 2,1998, NEl submitted its revised EAL guidance (NEl 97-03 dated October 1998) for NRC review and comment. In a letter dated December 3,1998, NRC provided its comments to NEl. The purpose of this meeting was to discuss these comments and NEl's proposed resolution. Attachment 2 contains NEl's proposed resolution of the NRC comments. Attachment 3 contains a summary of discussions held on the proposed resolutions.
In addition to discussing comments on the NEl document, NEl discussed its plans for j
development of EAL guidance applicable to cold shutdown and refueling conditions, defueled i
plants and dry-cask fuel storage users. NEl stated that the schedule for completing i
development of this guidance had not changed but that NEi now plans to combine this guidance with the EAL guidance in NEl 97-03 to create a cingle EAL guidance document for power reactors. NRC staff members stated that this appeared to be an appropriate plan.
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Project No. 689 Attachments: As stated cc w/att: See next page Project No. 689 Attachments: As stated l
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\\ * *,, *,8 December 22, 1998 MEMORANDUM TO: Themas H. Ecsig. Acting Chief Generic issues cod Environmental Projects Branch Division of Reactor Program Maaagemorit Office of Nuclear Reactor Regulation FROM:
Stewart L. Magruder, Project l'.ianager hM L%d Generic issues and Environmen'al Projects Eranch V
Divisien of Reactor Program Management OUico of Nuclear Peactor Regulation
SUBJECT:
SUMMARY
OF DECEMBER 11,1998, MEETING WITH THE NUCLEAR ENERbY INSTITUTE (NEI) REGARDING PROPOSED REVISION TO EMERGENCY ACTION LEVEL GUIDANCE On December 11,1998, representatives of the Nuclear Energy Institute (NEI) met with representatives of the Nuclear Regulatory Commission (NRC) at the NEl offices in Washington, DC. The curpose of the meeting was to discuss NRC comments on an industry-proposed revision to emergency action level (EAL) guidance. Attachment 1 provides a list of meeting attendees.
in a letter dated November 2,1998, NEl submitted its revised EAL guidance (NEl 97-03 dated October 1998) for NRC review and comment. In a letter dated December 3,1998, NRC provided its comments to NEl. The purpose of this meeting was to discuss these comments und NEl's proposed resolution. Attachment 2 contains NEl's proposed resolution of the NRC comments. Attachment 3 contains a summary of discussions held on the proposed resolutions.
In addition to discussing comments on the NEl document, NEl dlscussed its plans for development of EAL guidance applicable to cold shutdown and refueling conditions, defueled plants and dry-cask fuel storage users. NEl stated that the schedule for completing development of this guidance had not changed but that NEl new plans to combine this gu! dance with the Et' guidance in NEl 07-03 to create a single EAL guidance document for power reactors. Nh.itaff members stated that this appeared to be an appropriate plan.
Project No. 689 Attachments: As stated cc w/att: See next page
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NRC/NEl MEETING ON NEl's PROPOSED REVISION TO EAL GUIDANCE LIST OF ATTENDEES December 11,1998 l
NAME
- ORGANIZATION Alan Nelson NEl
' Dave Stobough Commonwealth Edison Walter Lee Southern Nuclear John Costello Virginia Power Mark Luksie Tennessee Valley Authority Jim O'Brien NRC/NRR Rando!ph Sullivan NRC/NRR Patricia Milligan NRC/NRR s
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l Distribution: Mtg. Summ ry w/ NEl R3 Ravilion to EAL guidanca Dited Dicember 22, 1998 Hard Cooy Docket File PUBLIC PGEB R/F OGC ACRS SMagruder -
JO'Brien EMail SCollins/RZimmerman BSheron BBoger JRoe DMatthews TEssig CMiller FAkstulewicz BZalcman JO'Brien EFox FKantor DBarss
.LCohen TMilligan RSullivan SRoudier GTracy, EDO t
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RESPONSE
TO NRC STAFF COMMENTS IN LETTER DATED 12/03/98 ON NEl 97-03 Revision 3 (Dated 10/98)
Forward This document is a preliminary response to NRC staff comments providedin a letter from C. Miller to A. Nelson did 12/3/98. This document provides the staff comment and a preliminary response and/or action statement.
This document was prepared by the NEl staff andindustry representatives. We have provided a response to each comment. Thus, our response should not be taken as firm commitments.
NEI Response to NRC 120398 LTR ATTI. doc 12/10/98 i
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NRC COMMENTS ON THE OCTOBER 1998 DRAFT OF NEl 97-03 Tha following comments are numbered to correlate with the NRC's initial assessment of the revisions made to NUMARC/NESP-007 in NEl 97-03 (see Attachment 2).
1.1 Section 3.12 Classfication of Transient Events NEl 97-03 describes two approaches for classifying transient events.
Comment:
The guidance in this section needs to be consistent with 10 CFR 50.72 notification guidance.
NEl ITF Response - 12/10/98:
The ITF agrees that 10CFR 50.72 requirements are applicable. To clarify this requirement in Section 3.12 the ITF has revised page 3.14 line 17 frorn " Normal reporting requirements (eg.,10 CFR 50.72) are applicable in these cases." to read " Reporting requirements of 10 CFR 50.72 are applicable and guidance of NUREG-1022, Rev.1 section 3 should be applied." This sentence has also been elevated to standalone paragraph status.
2.2.2 Steam Generator Emergency Action Levels (EALs)
A comparison of the NESP-007 and the NEl 97-03 steam generator fission product barrier EALs is provided in the following table:
Bamer NEsP 007 NEl 97 03 Res Loss (sne-specshc)indcabon that a SG is ruptured and has a sGTR that results in an Eccs (si) noruselsble seccxmdary line break <OR> (site-specific)
Actua00n indcaton that a 3G is ruptured and a prolonged release of contaminated secondry coolant is s Ocumng from me affected sG to me enwronment RCs Potental (site specife) indcanon that a sG is ruptured and the na Loss pnrnary to-semndary leak rate exceem the capacity of one charging pump in the normal charging mode, Containment Loss Release of simndary sade t) atmosphere mth RUPTUREo s/Gis also FAULTEo pnmary t> secondary uakage GREATER THAN toch spec outside of contanment akwabie or Pnmefy t> secondary leaktate greater than 10 gpm wth nontsolable steam release from affected s/G The differences in the classification schemes are described belcw.
Containment loss NESP 007.specified that "primaryto-secondary leakage GREATER THAN tech spec allowable" NEI Response to NRC 120398 LTR ATTI. doc 12/10/98 2
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was indication of a loss of containment, in NEl 97-03, the magnitude of the leak was raised to 10 l
gpm from 1 gpm (as specified in the Westinghouse standard technical specifications).
Comment:
No justification was provided for raising this limit.
NEl ITF Response - 12/10/98:
The ITF believes that justification was provided in the bases section lines 37 thru 48 on page 5-l F-19. The setpoint of 10 gpm is consistent with the SU5 setpoint for unidentified or pressure boundary leakage. This is believed to be conservative in that SG tube leakage is normally considered to be identified leakage which has a setpoint per SUS of 25 gpm.
l In addition, the condition " RUPTURED S/G is also FAULTED outside of containment" was added to this EAL.
Comment:
This condition would be encompassed by the 10 gpm leak rate condition and, therefore, would not ta necessary for this EAL.
NEl ITF Response - 12/10/98:
The ITF agrees that the EAL " RUPTURED S/G is also FAULTED outside of containment"is redundant. However, the ITF believes the EAL was added for human factor considerations in I
that the terms Ruptured and Faulted are easily recognized terms. The redundancy is believed to add to the ease of classification and should be left as is.
In reviewing this comment the ITF believes that the EAL " Primary-to-Secondary leak rate greater than 10 gpm with nonisolable steam release from affected SG" should be rewritten as " Primary-to Secondary leak rate greater than 10 gpm with nonisolable steam release from affected SG to the environment". This change is necessary to ensure that the loss of the containment boundar l
has occurred and therefore a threat to the public exists bofore the loss of Containment Barrier is declared.
RCS l.oss The loss of RCS criteria specified in NEl-97-03 is "SGTR that results in an ECCS (SI) Actuation."
Comment:
It is not clear how this condition relates to the condition " GREATER THAN available makeup capacity as indicated by a loss of RCS subcooling," which is used in a related loss of RCS EAL. Justification was not provided for utilizing the condition "SGTR that results in an ECCS (SI) Actuation"in this EAL NEl ITF Response - 12/10/98:
For a SGTR event, the need to actuate Si will primarily be a result of loss of RCS inventory vice loss of subcooling due to pressure reduction. This is due to the delta pressure difference of releasing RCS inventory to a pressurized SG vice a depressurized containment. Although the loss of RCS inventory due to a SGTR will result in lowering subcooling values, Abnormal Operating procedures will most likely direct Si actuation when pressurizer level cannot be maintained using normal charging capabilities prior to any subcooling lower limit being exceedec.
Therefore the ITF believes that the EAL is written appropriately.
NEI Response to NRC 120398 LTR ATTI. doc 12/10/98 3
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2.2.3 FB-RCS-L1 Main Steam Line Break EAL NESP-007 EAL FB-RCS-L1 is:
(site-specific) Indication of kain Steamline Break This EAL was changed to:
1 (Site-specific) Indication of an unisolable Ma'n Steamline Break The term unisolable was added because an isolated main steam line break does not constitute a loss of the RCS barrier.
Comment:
In the June 1993 Q&A, it was determined that inclusion of an isolated main steam line break as an EAL (outside of the fission product barrier matrix) was appropriate because of the puff release associated with this event. An EAL of this type was not included in NEl 97-03.
NEl ITF Response - 12/10/98:
The June 1993 O&A (item 4 on page 17) indicated that the probable offsite dose from the puff release resulting from an isolable steam line break must be classified. The Q&A indicated that the appropriate place to classify this puff release was under system failures. The ITF believes l
that the threat to the public due to the puff release will be evaluated and appropriately classified under the ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT section because no example of unmonitored release can be determined. Specifically AU1, AU2, or AA1 would lead to appropriate classification of the isolable steam line break.
2.2.4 FB RCS-PL3 Primary Containment Flooding NESP-007 EAL FB-CONT PL3 is:
Reactor vessel water level LESS THAN (sitaspecific) value and the maximum core uncovery time limit is in the UNSAFE region This EAL'was changed to:
Primary containment flooding required Comment: The basis section for this EAL has conflicting statements. One sentence states that b
this condition indicates that a core melt is in progress. A second sentence states that this condition represents imminent core melt sequences.
NEl ITF Response - 12/10/98:
L ITF agrees that the basis section contains conflicting statements. The sentence (line 14 and 15 l
on page 5 F-8) which states that " core melt is imminent" should be changed to "a core melt sequence is in progress" for consistency...
F NEl Response to NRC 120398 LTR ATTI. doc 12/10/98 4
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n 2.3.6 HU3 NESP-007 IC HUS contains the following EALs:
1.
Report or detection of toxic or flammable gases that has or could enter the site area boundary in amounts that can affect NORMAL PLANT OPERATIONS.
2.
Report by Local, County or State Officials for evacuation or sheltering of site personnel based on an offsite event.
The bases for these EALs were modified to provide guidance on releases that may affect normal plant operations, in addition, the bases were modified to remove guidance on the relationship of
" DOT Evacuation Tables" to " evacuation areas."
Comment:
The justification was not provided for the removal of information regarding the DOT Evacuation Tables.
NEl ITF Response - 12/10/98:
DOT Evacuation Tables are not used to evaluate classification criteria for hazardous materials and were removed for this reason. Material Safety Data Sheets (MSDS) are required to be maintained for all hazardous material s and /or gases that are maintained onsite in quantities large enough to be a threat to plant personnel or that could result in an offsite hazard. The MSDS provides guidance for actions to be taken in the event of a release or spill. Reference to the MSDS was not added to the bases because they do not provide value to the classification process.
2.3.8 HU4-2 NESP-007 example EAL HU4-2 is:
Other security events as determined from (sitespecific) Safeguards Contingency Plan.
The corresponding NEl 97-03 EAL is:
Security events as determined from (sitespecific) Safeguards Contingency Plan and reported by the (site' specific) security shift supervision The NESP-007 EAL was rnodified to add the condition "and reported by the (sitspecific) security shift supervision."
Comment: The justification was not provided for this change.
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NElITF Response 12/10/98:
Reference is made to (site-specific) security shift supervision because these individuals are the designated personnel on-site qualified and trained to confirm that a security event is occurring ol has occurred. Training on sacurity event classification confirmation is closely controlled due to the strict secrecy controls placed on the plant Security Plan.
2.3.9 HU4 Basis NEl Response to NRC 120398 LTR ATTI. doc 12/10/98 5
The basis for IC HU4 states the following:
Examples of security events that indicate Potential Degradation in the Level of Safety of the Plant are provided below for consideration.
Consideration should be given to the following events:
1.
SABOTAGE has or is occurring affecting Safety Related Quipment 2.
HOSTAGE / EXTOR TION situation that threatens to interrupt NORMAL PLANT OPERATIONS 3.
CIVIL DISTURBANCE ongoing between the site perimeter (or other site specific nomenclature) and PROTECTED AREA 4.
Hostile STRIKE ACTION at the facility which threatens to interrupt NORMAL PLANT OPERATIONS Comment:
Event 1, above, is not justified as an Unusual Event, but rather appears more j
closely aligned with the Site Area Emergency IC (HS1), " Confirmed Security Event in a Plant VITAL AREA" or the Alert IC (HA4)," Confirmed Security Event in a Plant PROTECTED AREA."
NElITF Response 12/10/98:
ITF agrees that the basis explanation is not cl6ar. The intent of the list was to provide a generic list of events that should be considered when evaluating the event against the site-specific Safegaurds Contingency Plan. The ITF recommends changing the following:
Consideration should be given to the following events:
1.
SABOTAGE has or is occurring affecting Safety Related Equipment 2.
HOSTAGE / EXTORTION situa6n that threatens to interrupt NORMAL PLANT OPERATIONS 3.
CIVIL DISTURBANCE ongoing between the site perimeter (or other site specific nomenclature) and PROTECTED AREA 4.
Hostile STRIKE ACTION at the facility which threatens to interrupt NORMAL PLANT OPERATIONS to Consideration shouldbe given to the following types of events when evaluating an event against the criteria of the site-specific Security Contingency Plan: SABOTAGE, HOSTAGEiEXTORTION, CIVIL DISTURBANCE,'and STRIKE ACTION.
Comment:
Event 2 appears to be more closely aligned with the Alert IC (HA4),if the event was to occur within the Protected Area, and more closely aligned with the Site Area Emergency IC,if the event was to occur within the Vital Area.
NElITF Response 12/10/98:
See above comment.
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NEl Response to NRC 120398 LTR ATTI. doc 12/10/98 6
2.3.12 HA1-4 NESP-007 example EAL HA1-4 is:
(Site-specific) indications in the control room This EAL was deleted.
Comment:
The justification was not provided for deleting this EAL.
NEl ITF Response - 12/10/98:
EAL 4 was subsumed in the changes made to the NESP-007, Rev 2 EAL 7. EAL 7 became EAl.
6 in NEl 97-03 due to this subsumption of EAL 4. This combining of EALs was intended to simplify the EAL classification scheme.
2.3.17 HA4-1 NESP-007 EAL HA4-1 is:
Intrusion into plant protected area by a hostile force.
This EAL was modified to specify that the intrusion is " ongoing."
Comment:
The justification was not provided for modifying this EAL.
NEl ITF Response - 12/10/98:
ITF recommends the removal of " ongoing" from the EAL example and the basis.
2.3.18 New EAL under HA4 A " bomb discovered" EAL was added to IC HA4, i.e.:
BOMB discovered within the PROTECTED AREA potentially affecting (site specific)
Safety Related Equipment.
Comment:
Although the condition of a bomb discovered in the protected area is consistent with the IC for this EAL (HA4), i.e.," Confirmed Security Event in a Plant PROTECTED AREA"it is not appropriate to include the need to assess whether the bomb must "potentially" affect safety-related equipment for EAL to meet the threshold for an Alert declaration.
NEl ITF Response - 12/10/98:
ITF believes that the qualifier "potentially affecting (site specific) Safety Related Equipment"is desirable to ensure that unnecessary classifications do not occur for bombs in the protected are. 1 that have no potential for affecting Safety Related Equipment.
l NEl Response to NRC 120398 LTR ATTI. doc 12/10/98 I
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1 2.3.21 HS1 NESP-007 IC HS1 is:
Confirmed Security Event in a Plant Vita! Area The following EAL was added to this IC:
BOMB discovered within the VITAL AREA potentially affecting (site-specific) equipment A bomb discovered within the Vital Area meets the condition specified in the IC, i.e., Confirmed Security Event in a / Plant Vital Area."
Comment:
As immediately above, it is not appropriate to include the need to assess whether the bomb must "potentially" affect safety-related equipment for EAL to meet the threshold for a Site Area Emergency declaration.
NEl ITF Response - 12/10/98:
ITF believes that the qualifier "potentially affecting (site specife) Safety Related Equipment" is desirable to ensure that unnecessary classifications do not occur for bombs in the vital area that have no potential for affecting Safety Related Equipment.
2.3.24 HS3 The NESP-007 EAL HS3-1 is:
Other conditions exist which in thejudgement of the emergency director indicate actual or likely major failures ofplant functions needed forprotection of the public This EAL was modified as follows:
Other conditions exist which in the judgment of the Emergency Director indicate that events are in process or have occurred which involve actual or likely major failures of plant functions needed for protection of the public. Any releases are not expected to resultin exposure levels which exceed EPA Protective Action Guideline exposure levels 0;;;us rmat the site boundary.
bry M This EAL was modified to match the description of the Site Area Emergency Classification provided in NUREG-0654.
Comment:
Releases that exceed the EPA PAGs at or beyond the site boundary warrant a General Emergency classification. Although this EAL matches the description of a Site Area Emergency provided in NUREG-06S4, it is not appropriate to include this supplemental statement in the EAL.
NEl ITF Response - 12/10/98:
ITF believes that the changes made were in accordance with the NRC Lessons learned item #
60 and are appropriate.
NEI Response to NRC 120398 LTR ATTI. doc 12/10/98 8
2.3.24 HG1 i
NESP-007 IC HG is:
Security Event Resulting in Loss of Ability to Reach and Maintain Cold Shutdown.
This IC was modified as follows:
Security Event Resulting in Loss Of Physical Control of the Facility.
The NESP-007 EALs under NESP-007 IC HG1 are:
Loss of physical control of the controlroom due to security event.
Loss of physical control of the remote shutdown capability due to security event.
These EALs were replaced by the following EAL:
A HOSTILE FORCE has taken control ofplant equipment such thatplantpersonnelare unable to operate equipment required to maintain safety functions.
The IC was modified to more closely reflect the plant condition of concern as reflected in the EALs under this IC. The EAL was modified to recognize that a loss of physical control of the plant varies based upon plant specific configurations of equipment and controls. The basis section of this EAL was modified to provide additional guidance on the site-specific implementation of this EAL.
Comment:
The justification was not provided for inclusion of the last statement in the basis section of this IC. The statement implies that site-specific areas are to be specified in the EAL.
NElITF Response 12/10/98:
ITF agrees that reference to site specific should be deleted such that the paragraph starting on line 29 of page 5-H 19 reads as follows:
Loss of physical control of the control room or remote shutdown capability alone mey not prevent the ability to maintain safety functions per se. Design of the remote shutdown capability and the location of the transfer switches should be taken into account.
2.4.4 SU8 Inadvertent Criticality
' Revision 3 included a new IC and EAL for inadvertent criticality, i.e.:
1 IC:
Inadvertent Criticality EAL: An extended and UNPLANNED positive period or sustainedpositive startup rate observed on nuclear instrumentation L
Comment:
Please provide additional information which describes any notices or evaluations which prompted the addition of this IC and EAL.
NEl Response to NRC 120398 LTR ATrl. doc 12/10/98 9
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NEl ITF Response - 12/10/98:
As discussed in the basis, this issue grew from the cold shutdown arena, specifically, NUREG 1449 (Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States). Based on this NUREG, the ITF concluded that this EAL could be added to include all modes (except Power Operation) to ensure that this potentially serious event type is classified appropriately.
i In addition, the following editorial comments are provided:
1.
HA1 Natural and Destructive Phenomenon Affecting Plant Vital Area Tornado or high winds striking plant vital areas: tornado or high winds greater than (site-specific) mph strike within protected area kundary.
This EAL was modified as follows:
Tornado or high winds greater than (sitespecific) mph within PROTECTED AREA i
boundary and resulting in VISIBLE DAMAGE to any of the following plant structures or equipment therein or controlindication of degradedperformance of those systems.
Comment:
The intent of the last part of the last sentence,i.e.,"controlindication of degraded performance of those systems"is not evident. This appears to be an editorial mistake.
NEl ITF Response - 12/10/98:
ITF agrees to clarify the statement as follows:
Tornado or high winds greater than (sitaspecific) mph within PROTECTED AREA boundary and resulting in VISIBLE DAMAGE to any of the following plant structures or equipment or Control Room indication of degraded performance of those systems.
2.
HU3 Comment:
There appears to be a typographical error in the following basis statement:
This wouldpreclude small or incidental releases, or releases that impact structures needed forplant operation.
We believe that the intent was to preclude releases that dm_gfimpact structures needed for plant operation.
NEl ITF Response - 12/10/98:
ITF agrees to change the wording as follows:
l This wouldpreclude small or incidental releases, or releases that do not impact structures
(
needed forplant operation.
NEl Response to NRC 120398 LTR A'ITI. doc 12/10/98 10 1
3.
HA3 Both the EALs under this IC are numbered as 1.
NEl ITF Response - 12/10/98:
ITF agrees: EALs will be renumbered as 1 and 2.
4.
FP-CONT-L2 The NESP-007 EAL is:
Rapid unexplaineddecrease following initialincrease OR Containmentpressure or sump levelresponse not consistent with LOCA conditions This EAL was revised as follows:
Rapid nr unexplained decrease following initialincrease OR Containmentpressure or sump levelresponse not consistent with LOCA conditions The corresponding BWR EAL was not modified. This may be an editorial error.
NEl ITF Response - 12/10/98:
ITF agrees and will remove the "or" from the PWR Table 5-F-4.
5.
FP-RCS-PL2 The NESP 007 potentialloss of RCS for a SGTR event was deleted. However, the statements regarding the potential loss EAL were not deleted in the basis section.
NEl ITF Response - 12/10/98:
This comment is related to a formatting error in Table 4 of NESP-007. This formatting error was j
corrected in NEl 97 03.
6.
FP-CONT-PL3 Basis NEl 97 03 adds the following (in bold) to the basis:
In this EAL, the function restoration procedures are those emergency operating procedures that address the recovery of the core cooling criticalsafety functions. The procedure is considered effective if the temperature is decreasing or if the vessel water NEl Response to NRC 120398 LTR ATTI. doc 12/10/98 11
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L j-levelis increasing For units using the CSF status trees a direct correlation to those status trees can be made if the effectiveness of the restoration procedures is also evaluated as stated below.
The statement below this paragraph does not appear to relate to it. This may be an editorial
- error, NElITF Response 12/10/98:
l' ITF agrees. Paragraph 1 on page 5 F 19 (lines 1-5) need to be moved so that it follows pe.ragraph 2 (lines 7-14).
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NE! Response to NRC 120398 LTR ATTI. doc 12/10/98 12 1
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7
SUMMARY
OF ISSUES DISCUSSED DURING DECEMBER 11,1998 MEETING BETWEEN NRC AND NEl ON j
OCTOBER 1998 DRAFT OF NEl 97-03 of this meeting summary provides NEl's proposed resolution to comments included in Attachment 1 of the NRC letter (CMiller to ANelson) dated December 3,1998. The following is a summary of discussion on these issues. Additional issues concerning NEl 97-03 discussed during the December 11,1998, meeting are described at the end of this attachment.
1.1 Section 3.12 Classification of Transient Events NEl 97-03 describes two approaches for classifying transient events. The guidance in this section needs to be consistent with 10 CFR 50.72 notification guidance.
NEl response (included in Attachment 2 of this meeting summary) appears appropriate.
2.2.2 Steam Generator Emergency Action Levels (EALs)
Issue 1:
NESP-007 specified that " primary-to-secondary laakage GREATER THAN tech spec allowable" was indication of a loss of containment. In NEl 97-03, the magnitude of the leak was raised to 4
10 gpm from 1 gpm (as specified in the Westinghouse standard technical specifications). No justification was provided for raising this limit.
NEl response (included in Attachment 2 of this meeting summary) appears appropriate.
Issue 2:
The condition " RUPTURED S/G is also FAULTED outside of containment" was added to this EAL. This condition would be encompassed by the 10 gpm leak rate condition and, therefore, would not be necessary for this EAL.
Issue 3:
The loss of RCS criteria specified in NEl-97-03 is "SGTR that results in an ECCS (SI)." It is not clear how this condition relates to the condition " GREATER THAN available make-up capacity as indicated by a loss of RCS subcooling," which is used in a related loss of RCS EAL.
Justification was not provided for utilizing the condition "SGTR that results in an ECCS (SI)
Actuation"in thic EAL NEl response (included in Attachment 2 of this meeting semmary) appears appropriate.
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2.2.3 FB-RCS-L1 Main Steam Line Break EAL in the June 1993 Q&A, it was determined that inclusion of an isolated main steam line break as an EAL (outside of the fission product barrier matrix) was appropriate because of the puff release associated with this event. An EAL of this type was not included in NEl 97-03.
l NEl is further evaluating this issue.
2.2.4 FB-RCS PL3 Primary Containment Flooding l
The basis section for this EAL has conflicting statements. One sentence states that this condition indicates that a core melt is in progress. A second sentence states that this condition l
represents imn.inent core melt sequences, j
NEl response (included in Attachment 2 of this meeting summary) appears appropriate.
2.3.6 HU3 The justification was not provided for the removal of information regarding the DOT Evacuation Tables.
NEl response (included in Attachment 2 of this meeting summary) appears appropriate.
2.3.8 HU4-2 The NESP-007 EAL was modified to add the condition "and reported by the (site-specific) security shift supervision." The justification was not provided for this change.
NEl response appears appropriate. NEl is considering adding information contained in its response to the Basis section of this EAL.
2.3.9 HU4 Basis NEl response appears appropriate. NEl is considering adding information contained in its response to the Basis section of this EAL and other security related EALs.
2.3.12 HA1-4 The justification was not provided for deleting this EAL.
NEl response (included in Attachment 2 of this meeting summary) appears appropriate.
2.3.17 HA4-1
~ This EAL was modified to specify that the intrusion is " ongoing." The justification was not provided for modifying this EAL.
NEl response (included in Attachment 2 of this meeting summary) appears appropriate, o
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2.3.18 New EAL under HA4 Although the condition of a bomb discovered in the protected area is consistent with the IC for this EAL (HA4), i.e., " Confirmed Security Event in a Plant PROTECTED AREA"it is not appropriate to include the need to assess whether the bomb must "potentially" affect safety-related equipment for EAL to meet the threshold for an Alert declaration.
NEl intends to remove this EAL because it is more appropriately classified as an intrusion into the protected area by a hostile force. NEl is considering whether the definition of intrusion needs to be evaluated (or the EAL for intrusion into the protected area revised) so that intentional sabotage via placement of a bomb in the protected area by a person authorized access will be applicable to this EAL.
2.3.21 HS1 it is not appropriate to include the need to assess whether the bomb must "potentially" affect safety-related equipment for EAL to meet the threshold for a Site Area Emergency declaration.
NEl response to this issue is the same as discussed under 2.3.18.
2.3.24 HS3 This EAL was modified to match the description of the Site Area Emergency Classification provided in NUREG-0654. Although this EAL matches the description of a Site Area Emergency provided in NUREG-0654, it is not appropriate to include this supplemental statement in the EAL.
NEl intends to modify the last part of the EAL so that it is clear that exceeding EPA PAGs beyond the site boundary is a General Emergency.
2.3.24 HG1
.The justification was not provided for inclusion of the last statement in the basis section of this
- 10. The statement implies that site-specific areas are to be specified in the EAL.
NEl response (included in Attachment 2 of this meeting summary) appears appropriate.
2.4.4 SU8 Inadvertent Criticality Please provide additional information which describes any notices or evaluations which prompted the addition of this IC and EAL.
NEl response (included in Attachment 2 of this meeting summary) appears appropriate.
3
l The following issues were discussed in addition to those described above.
- 1. AU2-2 NEl 97-03 added the following to the basis for the dry cast storage EAL:
The value of (site specific dose rate ) should be based on not exceeding a dose rate of 0.10 mR/hr at the closest point for public access, which should be considered the site's Restricted Area Boundary. This value is consistent with 10 CFR Part 20 limits for members of the public.
NEl will provide justification for the values specified in this Basis section.
2.
Fission Product Table The definition of " imminent" was changed from within 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in Table 5-F-1 and from 1 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in Table 5-F-2. NEl stated that this change was made to have consistency between the two tables and to provide a more clear definition of what is meant by
" imminent."
3.
Fission Product Table -- Basis for PWR Containment Isolation Valve Status NEl described the rationale for the following statements included in the Basis section for this EAL.
The use of the modifier direct in defining the release path discriminates against release paths through interfacing liquid systems. The existence of an in-line charcoal filter does not make a release path indirect since the filter is not effective at removing fission noble gases. Typicalfilters have an efficiency of 95-99% removalofiodine. Given the magnitude of the core inventory ofiodine, significant releases could still occur. In addition, since the fission product release would be driven by boiling in the reactor vessel, the high humidity in the release stream can be expected to render the filters ineffective in a short period 4.
Vehicle Crash NRC questioned whether there may be difficulty in developing site specific EALs using the NEl guidance. NEl stated that it did not see any difficulties with developing site-specific EALs.
5.
Internal Flooding NRC and NEl discussed the intent of this EAL and issues related to the site-specific application of thiu EAL.
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Removal of Uncontrolled secondary depressurization from emergency coordinator judgement EAL.
NRC and NEI discussed the basis for removing this emergency coordinatorjudgment EAL.
NRC stated that this EAL was discussed in the Regulatory Analysis supporting NUMARC/NESP-007 and that it was not clear if this was considered when NEI proposed
' removing this EAL in NEI 97-03. NEI stated that it will further evaluate whether guidance for
. developing an EAL for this type of event is needed.
l 7.
= Wind speeds (HAl)
NRC and NEI discussed whether the intent of this EAL is to utilize the same wind speed for the
. Unusual Event and Alert kevel EALs.
8.
Fire EAL HA2
- NRC and NEI discussed whether this EAL only applic s to equipment required for the current mode of operation of the plant.
9.
HS1 NRC identified that portions of the Basis statement for the Site Area Emergency classification level EAL were the same as that for the Alert level EAL and questioned whether this was the.
. intent of the Basis statement. NE! stated that it will re-evcluate the basis statement.
P HG1 1
. NEl described how site-specific EALs under this IC may be developed.
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