View source for LIC-15-0139, ISFSI - Supplemental OPPD Response to NRC Request for Additional Information License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6

{{Adams
| number = ML15342A409
| issue date = 12/08/2015
| title = ISFSI - Supplemental OPPD Response to NRC Request for Additional Information License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6
| author name = Cortopassi L
| author affiliation = Omaha Public Power District
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NMSS, NRC/NRR
| docket = 05000285, 07200054
| license number = DPR-040
| contact person = 
| case reference number = LIC-15-0139, NEI 99-01, Rev. 6, TAC MF5466
| document type = Letter type:LIC, Response to Request for Additional Information (RAI)
| page count = 15
| project = TAC:MF5466
| stage = Supplement
}}

=Text=
{{#Wiki_filter:LIC-15-0139 December 8, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Fort Calhoun Station (FCS), Unit 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285 Fort Calhoun Station Independent Spent Fuel Storage Installation NRC Docket No. 72-054

==Subject:==
Supplemental OPPD Response to NRC Request for Additional Information RE: License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6 (TAC No. MF5466)

==References:==
Page 3 Following a teleconference with NRC Staff on November 23, 2015, the Omaha Public Power District (OPPD) is supplementing its Reference 3 response to the Reference 2 NRC request for additional information (RAI) regarding License Amendment Request (LAR) 14-06 (Reference 1). LAR 14-06 proposes to revise the Emergency Plan for Fort Calhoun Station to adopt the Nuclear Energy lnstitute's (NEl's) revised Emergency Action Level (EAL) scheme described in NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors.
Enclosure 1 contains a revised response to RAI 24 to be more consistent with guidance contained in the Emergency Operating Procedures. Enclosure 2 contains a revised procedure matrix reflecting the change and an editorial correction to mode titles contained in the footnote. Enclosure 3 contains revised pages for the EAL Basis Document for EALs MS3, MA3, and MU3.
This letter contains no regulatory commitments .
. . - - - - - - - - - - - - - - -..:...44'-"-'
4 SOUTH 16TH STREET MALL* OMAHA, NE 68102-2247

U.S. Nuclear Regulatory Commission LIC-15-0139 Page 2 If you should have any questions regarding this submittal or require additional information, please contact Mr. Bill R. Hansher at 402-533-6894.
Louis P. Cortopassi Site Vice President and CNO LPC/EJP/mle

==Enclosures:==
: 1. Revised OPPD Response to NRC RAI 24 Regarding License Amendment Request (LAR) 14-06
: 2. Procedure Matrix Revised Page for EALs MS3, MA3, and MU3
: 3. EAL Basis Document Revised Pages for EALs MS3, MA3, and MU3 c:     M. L. Dapas, NRC Regional Administrator, Region IV (w/o Enclosures 2, 3, 4)
C. F. Lyon, NRC Senior Project Manager S. M. Schneider, NRC Senior Resident Inspector (w/o Enclosures 2, 3, 4)
Manager Radiation Control Program, Nebraska Health & Human Services, R & L Public Health Assurance, State of Nebraska (w/o Enclosures 2, 3, 4)

U. S. Nuclear Regulatory Commission LIC-15-0139 Page 3

==References:==
: 1. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk),
                 "License Amendment Request 14-06 to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors," dated December 26, 2014 (LIC-14-0098)
(ML14365A123)
: 2. Letter from NRC (C. F. Lyon) to OPPD (L. P. Cortopassi) , "Fort Calhoun Station, Unit No. 1 - Request for Additional Information Re: License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6 (TAC No. MF5466)," dated July 14, 2015 (NRC-15-061)
(ML15194A272)
: 3. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "OPPD Response to NRC Request for Additional Information RE: License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01 ,
Revision 6 (TAC No. MF5466) ," dated September 11 , 2015 (LIC-15-0102)
: 4. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk),
                 "Supplemental OPPD Response to NRC Request for Additional Information RE: License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01 , Revision 6 (TAC No. MF5466), " dated November 2, 2015 (LIC-15-0121)

LIC-15-0139 Page 1 Revised OPPD Response to NRC RAI 24 Regarding License Amendment Request (LAR) 14-06

LIC-15-0139 Page2 REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO ADOPT EMERGENCY ACTION LEVEL SCHEME PURSUANT TO NEI 99-01. REVISION 6 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO. 1 DOCKET NO. 50-285 By letter dated December 26, 2014, Omaha Public Power District (OPPD, the licensee) requested approval for an emergency action level (EAL) scheme change for the Fort Calhoun Station, Unit 1 (FCS) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14365A123). OPPD proposes to revise its current EAL scheme to one based upon Revision 6 to Nuclear Energy Institute (NEI) document NEI 99-01 , "Development of Emergency Action Levels for Non-Passive Reactors," November 2012 (ADAMS Accession No. ML12326A805),
instead of Revision 5.
The requests for additional information (RAls) listed below, in regards to Attachment 2, Enclosure 2C, "Emergency Action Level Basis Document," of the submittal, are needed to support U.S.
Nuclear Regulatory Commission (NRC) staffs continued technical review of the proposed EAL scheme change.
FC-RAl-24 For ICs MU3, MA3, and MS3, please justify why the words:" ... as indicated by reactor power~ 2%," were added to the EALs, or revise accordingly. Relying solely on a reactor power level of 2 percent is not consistent with EOP criteria as provided by NEI 99-01, Revision 6.
FC-RAl-24 Response (REVISED)
Revised to add "Reactor power is not < 2%" and "Startup rate is not negative" to the existing reactor power indication to be consistent with guidance provided in EOPs.

LIC-15-0139 Procedure Matrix Revised Page FC 3-16 for EALs MS3, MA3, and MU3

I System Malfunction MS3 Inability to shutdown the reactor causing a                        MA3 Automatic or manual trip fails to shutdown                ff]!]   MU3 Automatic or manual trip fails to shutdown the reactor, and subsequent manual actions taken at the challenge to core cooling or RCS heat removal.                       1 reactor control consoles are not successful in shutting down        I I
the reactor.
the reactor.
Emergency Action Levels (EAL) :                                        Emergency Action Levels (EAL) :
1 1
Emergency Action Levels (EAL):                                            I 1 . Automatic or Manual Trip failed to shutdown the reactor as         Note: A manual action is any operator action, or set of actions,      Note: A manual action is any operator action, or set of actions, which 1       indicated by ANY of the following:                                           which causes the control rods to be rapidly inserted into           causes the control rods to be rapidly inserted into the core, and 1
* Reactor power is not < 2%                                               the core, and does not include manually driving in                  does not include manually driving in control rods or control rods or implementation of boron injection                   implementation of boron injection strategies.
* Startup rate is not negative                                            strategies.                                                 1. a. Automatic Trip failed to shutdown the reactor as indicated by AND                                                                1. Automatic or Manual Trip failed to shutdown the                               ANY of the following :
: 2. All manual actions failed to shutdown the reactor as indicated            reactor as indicated by ANY of the following:
* Reactor power is not< 2%
by ANY of the following:
* Reactor power is not < 2%
* Startup rate is not negative
* Reactor power is not < 2%
* Startup rate is not negative                                            AND
* Startup rate is not negative AND                                                                    b. Subsequent manual action taken at the Console Center is LL                                                  AND
: 2. Manual actions taken at the Console Center failed successful in shutting down the reactor.
   "'c..0:::                                           3. EITHER of the following conditions exist:                                 to shutdown the reactor as indicated by ANY of the                      OR
: a. Core exit thermocouples > 1550&deg;F.                           following:                                                      2. a. Manual Trip failed to shutdown the reactor as indicated by ANY of the following :
OR
* Reactor power is not < 2%
* Reactor power is not < 2%
: b. RVLMS indicates 0.0%
* Startup rate is not negative OR
* Startup rate is not negative AND
: c. Once-Through-Cooling, EOP-20 HR4 in effect.
: b. EITHER of the following:
: 1. Subsequent manual action taken at the Console Center is successful in shutting down the reactor.
OR
                                                                                                                                                                                                                   .2. Subsequent automatic Trip is successful in shutting down the reactor.
MA4        UNPLANNED loss of Control Room                             MU4       UNPLANNED loss of Control Room Table M1 Control Room Parameters                              Table M2 Significant Transients                               indications for 15 minutes or longer with a significant               ind ications for 15 minutes or longer.
(/)
c:                                                                                                                                 transient in progress .
0                                                                                                                     I
   ;;
* Reactor Power                                                                                           ; Emergency Action Levels (EAL) :                                       Emergency Action Levels (EAL) :
I
   =s"'c:
(.)
* Electrical Load Rejection >25% full electrical load
* PZR Level                        i
* Reactor Trip                                          Note: The Emergency Director should declare the event                 Note: The Emergency Director should declare the event promptly upon
* RCS Pressure                                                                                                        promptly upon determining that the applicable time                  determining that the applicable time has been exceeded, or will E
* ECCS Actuation                                                  has been exceeded, or will likely be exceeded                       likely be exceeded 0
* In Core/Core Exit Temperature 0
0:::
* Level in at least one OTSG .                                                                               1. a      An UNPLANNED event results in the inability to             An UNPLANNED event resu lts in the inability to monitor ANY Table M1 u
0 i..
c:
0
* Auxiliary Feed Water Flow                                                                                           monitor ANY Table M1 parameters from within the Control Room for~ 15 minutes.
AND
: b. ANY Table M2 transient in progress.
                                                                                                                                                                                                  ! parameters from within the Control Room for~ 15 minutes.
Mode:            1 - Power Operations           2 - Hot Standby               3 - Hot Shutdown          4 - Cold Shutdown      5 - Refueling Shutdown D - Defueled Month 20XX                       COLD SHUTDOWN/REFUELING MATRIX                                                                  FC 3-16                                   COLD SHUTDOWN/REFUELING MATRIX                                            EP-XX-XXXX (Revision XX)

LIC-15-0139 EAL Basis Document Revised Pages for EALs MS3, MA3, and MU3

Ft. Calhoun Station                                        Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS3 Initiating Condition:
Inability to shutdown the reactor causing a challenge to core cooling or RCS heat removal.
Operating Mode Applicability:
1, 2 Emergency Action Level (EAL}:
: 1. Automatic or Manual Trip failed to shutdown the reactor as indicated by ANY of the following:
* Reactor power is not < 2%
* Startup rate is not negative AND
: 2. All manual actions failed to shutdown the reactor as indicated by ANY of the following:
* Reactor power is not < 2%
* Startup rate is not negative AND
: 3. EITHER of the following conditions exist:
: a. Core exit thermocouples> 1550&deg;F.
OR
: b. RVLMS indicates 0.0%
OR
: c. Once-Through-Cooling, EOP-20 HR4 in effect.
Basis:
This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown , all subsequent operator manual actions, both inside and outside the Control Room including driving in control rods and boron injection, are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency.
In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs. This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shutdown the reactor. The inclusion of this IC and EAL ensures the timely Month 20XX                                FC 3-89             EP-XX-XXXX (Revision XX)

Ft. Calhoun Station                                       Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS3 (cont)
Basis (cont):
declaration of a Site Area Emergency in response to prolonged failure to shutdown the reactor.
A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
Escalation of the emergency classification level would be via IC RG1 or FG1.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, SS5 Month 20XX                               FC 3-90             EP-XX-XXXX (Revision XX)

Ft. Calhoun Station                                           Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA3 Initiating Condition:
Automatic or manual trip fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.
Operating Mode Applicability:
1, 2 Emergency Action Level (EAL):
Note:
* A manual action is any operator action , or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.
: 1. Automatic or Manual Trip failed to shutdown the reactor as indicated by ANY of the following:
* Reactor power is not < 2%
* Startup rate is not negative AND
: 2. Manual actions taken at the Console Center failed to shutdown the reactor as indicated by ANY of the following:
* Reactor power is not < 2%
* Startup rate is not negative Basis:
This IC addresses a failure of the RPS to initiate or complete an automatic reactor trip that results in a reactor shutdown, and subsequent operator manual actions taken at the Console Center to shutdown the reactor are also unsuccessful. This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if the reactor is subsequently shutdown by an action taken away from the Console Center since this event entails a significant failure of the RPS.
A manual action at the Console Center is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor trip . This action does not include manually driving in control rods or implementation of boron injection strategies. If this action(s) is unsuccessful , operators would immediately pursue additional manual actions at locations away from the Console Center (e.g., locally opening breakers). Actions taken at back-panels or other locations within the Control Room , or any location outside the Control Room , are not considered to be "at the Console Center''.
Month 20XX                                 FC 3-91              EP-XX-XXXX (Revision XX)

Ft. Calhoun Station                                        Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA3 {cont)
Basis (cont):
The plant response to the failure of an automatic or manual reactor trip will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If the failure to shutdown the reactor is prolonged enough to cause a challenge to the core cooling or RCS heat removal safety functions , the emergency classification level will escalate to a Site Area Emergency via IC MS3. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. Absent the plant conditions needed to meet either IC MS3 or FS1, an Alert declaration is appropriate for this event.
It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F ICs; however, this IC and EAL are included to ensure a timely emergency declaration.
A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
Basis Reference(s):
: 1.       NEI 99-01 Rev 6, SA5 Month 20XX                                 FC 3-92            EP-XX-XXXX (Revision XX)

Ft. Calhoun Station                                          Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 Initiating Condition:
Automatic or manual trip fails to shutdown the reactor.
Operating Mode Applicability:
1, 2 Emergency Action Level (EAL):
Note:
* A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.
: 1. a. Automatic Trip failed to shutdown the reactor as indicated by ANY of the following:
* Reactor power is not < 2%
* Startup rate is not negative AND
: b. Subsequent manual action taken at the Console Center is successful in shutting down the reactor.
OR
: 2.      a. Manual Trip failed to shutdown the reactor as indicated by ANY of the following:
* Reactor power is not < 2%
* Startup rate is not negative AND
: b. EITHER of the following:
1 . Subsequent manual action taken at the Console Center is successful in shutting down the reactor.
OR
: 2. Subsequent automatic Trip is successful in shutting down the reactor.
Basis:
This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and either a subsequent operator manual action taken at the Console Center or an automatic trip is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.
Month 20XX                                 FC 3-93              EP-XX-XXXX (Revision XX)

Ft. Calhoun Station                                               Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 (cont)
Basis (cont):
EAL #1 Basis Following the failure on an automatic reactor trip, operators will promptly initiate manual actions at the Console Center to shutdown the reactor (e.g., initiate a manual reactor trip).
If these manual actions are successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems.
EAL#2 Basis If an initial manual reactor trip is unsuccessful, a concurrent plant condition, may lead to the generation of an automatic reactor trip signal. If a subsequent automatic trip is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems.
A manual action at the Console Center is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor trip). This action does not include manually driving in control rods or implementation of boron injection strategies. Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the Console Center".
The plant response to the failure of an automatic or manual reactor trip will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the Console Center are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC MA3. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC MA3 or FA 1, an Unusual Event declaration is appropriate for this event.
A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
Should a reactor trip signal be generated as a result of plant work (e.g., RPS setpoint testing), the following classification guidance should be applied.
* If the signal generated as a result of plant work causes a plant transient that creates a real condition that should have included an automatic reactor trip and the RPS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated.
* If the signal generated as a result of plant work does not cause a plant transient but should have generated an RPS trip signal and the trip failure is determined through other means (e.g., assessment of test results), then th is IC and the EALs are not applicable and no classification is warranted.
Month 20XX                                  FC 3-94                 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station                            Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 (cont)
Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU5 Month 20XX                         FC 3-95       EP-XX-XXXX (Revision XX)}}