ML24072A416
| ML24072A416 | |
| Person / Time | |
|---|---|
| Issue date: | 03/15/2024 |
| From: | Leslie Fields Licensing Processes Branch |
| To: | Gerond George Licensing Processes Branch |
| References | |
| Download: ML24072A416 (1) | |
Text
Summary of IC and EAL Change Comments and Questions in NEI 99-01 Revision 7 Page 1 of 4
- Additional Issues/Editorial Corrections:
- 1. Section 5.5 CLASSIFICATION OF IMMINENT CONDITIONS is removed with no basis.
- 2. FPB Table 9-F-3 Containment Integrity or Bypass Basis and Developer Notes section removed with no basis. See page 105.
- 3. Page 90 is missing.
- 4. Please review document for inaccurate links (e.g. page 37 of 58 Containment barrier loss 4.A is described as being in rev 6 and rev 7 however FPB Table 9-F-3 Containment Integrity or Bypass line #4 was deleted from rev 7).
Rev. 6 IC and EAL#
Rev. 6 Wording Rev. 7 IC and EAL#
Rev. 7 Wording Change Summary/Basis IC CA6 EAL #1 Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode.
(1) a. The occurrence of ANY of the following hazardous events:
Seismic event (earthquake)
Internal or external flooding event High winds or tornado strike FIRE EXPLOSION (site-specific hazards)
Other events with similar hazard characteristics as determined by the Shift Manager IC CA6 EAL #1 Hazardous event affecting two or more SAFETY SYSTEM trains.
(1) a. The occurrence of ANY of the following hazardous events:
Seismic event (earthquake)
Internal or external flooding event High winds or tornado strike FIRE EXPLOSION (site-specific hazards)
Other events with similar hazard characteristics as determined by the Shift Manager The IC and EAL were revised to incorporate concepts captured in EPFAQs 2016-02 and 2018-04. These EPFAQs were a starting point, information in both significantly evolved in the development of Revision 7 to address lessons learned from OE and comments from NRC staff. The key point is an event would need to impact two or more safety system trains to be considered an actual or potential substantial degradation of the level of safety of the plant (i.e., an Alert).
Rev 7 is missing needed for the current operating mode.
Missing Notes from EPFAQ 2016-02:
If the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then this emergency classification is not warranted.
If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.
Rev 7 page 49 says:
CA6 Hazardous event affecting SAFETY SYSTEM trains required for the current operating mode Page 61 does not say current operating mode.
Summary of IC and EAL Change Comments and Questions in NEI 99-01 Revision 7 Page 2 of 4 Rev. 6 IC and EAL#
Rev. 6 Wording Rev. 7 IC and EAL#
Rev. 7 Wording Change Summary/Basis IC SA9 EAL #1 Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode.
IC SA7 EAL #1 Hazardous event affecting two or more SAFETY SYSTEM trains. needed for the current operating mode. This is missing.
The IC and EAL were revised to incorporate concepts first captured in EPFAQs 2016-02 and 2018-04. Although these EPFAQs were a starting point, the information in both were significantly evolved during the development of Revision 7 to address lessons learned from operating experience and comments from the NRC staff. The key point is that an event would need to impact two or more safety system trains to be considered an actual or potential substantial degradation of the level of safety of the plant (i.e., an Alert).
IC CA6 (the cold version of this IC) see comments above.
IC SA5 EAL #1 Automatic or manual (trip
[PWR] / scram [BWR]) fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.
- a. Automatic or manual (trip [PWR] / scram
[BWR]) fails to shutdown the reactor, and
- b. subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.
Actual rev 7
- a. An automatic or manual (trip [PWR] / scram [BWR])
did not shutdown the reactor.
AND
- b. Manual actions taken at the reactor control consoles are not successful in shutting down the reactor.
IC and EAL relocated from Alert to NOUE no changes made to the IC or EAL wording.
The change made based on a reassessment of the potential event risk, consequences, and operating experience. Sites have procedures and capabilities to respond to an unsuccessful reactor trip/scram (e.g.,
strategies and equipment to meet 10 CFR 50.62),
including the use of alternative measures to shut down the reactor before a fission product barrier is challenged (e.g., local opening of reactor trip breakers).
In addition, some plant response actions would be required by Technical Specifications report to the NRC in accordance with 10 CFR 50.72.
Further, this condition does not require ERO mobilization or offsite support to assess and correct.
Should the event lead to a challenge of either the Fuel Clad Barrier or RCS Barrier, then an Alert classification would be made in accordance with the thresholds in the FPB Tables. Absent such a challenge, an NOUE declaration is appropriate.
Summary of IC and EAL Change Comments and Questions in NEI 99-01 Revision 7 Page 3 of 4 Rev. 6 IC and EAL#
Rev. 6 Wording Rev. 7 IC and EAL#
Rev. 7 Wording Change Summary/Basis FPB Table 9-F-3 CNMT Barrier Potential Loss 4.A A. Containment pressure greater than (site-specific value)
FPB Table 9-F-3 CNMT Barrier Potential Loss 4.A A. Containment pressure greater than (site-specific value)
No change to the threshold.
FPB Table 9-F-3 Line #4 in Rev 7 is now Emergency Director Judgment.
FPB Table 9-F-3 CNMT Barrier Potential Loss 4.B B. Explosive mixture exists inside containment FPB Table 9-F-3 CNMT Barrier Potential Loss 4.B B. Flammable mixture in containment atmosphere Changed explosive to flammable as this is the term used for the mixture of concern in PWR EOPs/SAMGs.
Revised the Basis accordingly.
Rev. 7 IC and EAL# description should 3.B vs 4.B FPB Table 9-F-3 CNMT Barrier Potential Loss 4.C C. 1. Containment pressure greater than (site-specific pressure setpoint)
AND
- 2. Less than one full train of (site-specific system or equipment) is operating per design for 15 minutes or longer FPB Table 9-F-3 CNMT Barrier Potential Loss 4.C C. Dose assessment using actual meteorology indicates doses greater than 750 mrem TEDE at or beyond (site-specific dose receptor point).
There are two parts to this change:
Part 1 - The old threshold was removed because it may lead to a GE declaration and PARs during conditions when there is no (or a minimal) release in progress and no immediate challenge to containment integrity. Atmospheric pressure-related challenges to containment integrity are best bounded by Containment Barrier Potential Loss threshold 4.A, Containment pressure greater than (site-specific value), where the value is the containment design pressure.
Part 2 - The new threshold replaces the existing radiation monitor threshold in Containment Barrier Potential Loss 3.A. It is set to 75% of the lower limit of the EPA PAG for sheltering-or evacuation of the public. Releases of this magnitude are far greater than normal containment leakage and, when combined with the loss of the fuel clad and RCS barriers, warrant the declaration of a General Emergency. The resulting PARs, which may include an evacuation, will be more appropriate given that a significant release is in progress (i.e., one that exceeds expected normal containment leakage).
Summary of IC and EAL Change Comments and Questions in NEI 99-01 Revision 7 Page 4 of 4 Rev. 6 IC and EAL#
Rev. 6 Wording Rev. 7 IC and EAL#
Rev. 7 Wording Change Summary/Basis N/A N/A FPB Table 9-F-3 CNMT Barrier Potential Loss 4.D D. Field survey results indicate closed window dose rates greater than 750 mR/hr at or beyond (site-specific dose receptor point) that are expected to continue for 60 minutes or longer.
This is a companion threshold for Containment Barrier Potential Loss 4.C; see above discussion for Part 2.
FPB Table 9-F-3 Line #4 in Rev 7 is now Emergency Director Judgment.
Appendix C See new Appendix C, Guidance for Radiation Effluent Monitor EALs.
The new Appendix C addresses the development of EALs based on calculated effluent radiation monitor readings per the Developer Notes in AA1, AS1, and AG2. Also adds information from EPFAQ 2015-09.
This change appears inconsistent with the request to delete EAL #1 from AA1, AS1, and AG1.