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| | issue date = 07/29/2010 | | | issue date = 07/29/2010 |
| | title = Attachment to Draft RAIs -Exelon EAL Upgrade Project | | | title = Attachment to Draft RAIs -Exelon EAL Upgrade Project |
| | author name = DiFrancesco N J | | | author name = Difrancesco N |
| | author affiliation = NRC/NRR/DORL/LPLIII-2 | | | author affiliation = NRC/NRR/DORL/LPLIII-2 |
| | addressee name = Gropp R | | | addressee name = Gropp R |
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| {{#Wiki_filter:Exelon EAL Upgrade Project NRC Request for Additional Information Dresden Nuclear Power Quad Cities Nuclear Draft RAI# I EAL Question GENERIC It is expected that licensees adhere to endorsed guidance, particularly for Initiating Conditions and Definitions, with no differences or deviations other than those related to a licensee's particular design. This is to ensure regulatory stability of the Emergency Action Level (EAL) scheme. This also ensures that, as stated in Title 10 of the Code of Federal Regulations, (10 CFR), Paragraph 50.47(b)(4), licensees implement "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters | | {{#Wiki_filter:Exelon EAL Upgrade Project NRC Request for Additional Information Dresden Nuclear Power Station Quad Cities Nuclear Station Draft RAI# I EAL Question It is expected that licensees adhere to endorsed guidance, particularly for Initiating Conditions and Definitions, with no differences or deviations other than those related to a licensee's particular design. This is to ensure regulatory stability of the Emergency Action Level (EAL) scheme. |
| ... : While the NRC staff is not enforcing strict verbatim compliance with the endorsed guidance, where applicable, the NRC staff will be pointing out areas where it expects the endorsed guidance to be used to ensure implementation of a standard scheme. This is primarily based upon industry and NRC staff experience with issues related to a particular EAL. While formatting is usually not technically relevant to the NRC staffs review of EALs, when inconsistent formatting may result in potential misunderstanding, an RAI will be developed to correct the formatting or to obtain additional information in support of the deviation. | | This also ensures that, as stated in Title 10 of the Code of Federal Regulations, (10 CFR), Paragraph 50.47(b)(4), licensees implement "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters ... : |
| Dresden/Quad Cities Draft RAIs pg.l RAI# I EAL GENERIC Exelon EAL Upgrade Project NRC Request for Additional Information Dresden Nuclear Power Station Quad Cities Nuclear Station Draft Question It is expected that licensees adhere to endorsed guidance, particularly for Initiating Conditions and Definitions, with no differences or deviations other than those related to a licensee's particular design. This is to ensure regulatory stability of the Emergency Action Level (EAL) scheme. This also ensures that, as stated in Title 10 of the Code of Federal Regulations, (10 CFR), Paragraph 50.47(b)(4), licensees implement "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters | | GENERIC While the NRC staff is not enforcing strict verbatim compliance with the endorsed guidance, where applicable, the NRC staff will be pointing out areas where it expects the endorsed guidance to be used to ensure implementation of a standard scheme. This is primarily based upon industry and NRC staff experience with issues related to a particular EAL. |
| ... : While the NRC staff is not enforcing strict verbatim compliance with the endorsed guidance, where applicable, the NRC staff will be pointing out areas where it expects the endorsed guidance to be used to ensure implementation of a standard scheme. This is primarily based upon industry and NRC staff experience with issues related to a particular EAL. While formatting is usually not technically relevant to the NRC staffs review of EALs, when inconsistent formatting may result in potential misunderstanding, an RAI will be developed to correct the formatting or to obtain additional information in support of the deviation. | | While formatting is usually not technically relevant to the NRC staffs review of EALs, when inconsistent formatting may result in potential misunderstanding, an RAI will be developed to correct the formatting or to obtain additional information in support of the deviation. |
| Dresden/Quad Cities Draft RAIs pg.l Exelon EAL Upgrade Project NRC Request for Additional Dresden Nuclear Power Quad Cities Nuclear Draft RAI# EAL Question 1 GENERAL 1. 2. 3. 4. 5. 6. 7. Please confirm that all stated values, set points, and indications provided are within the calibrated range of the applicable instrumentation and that the instrumentation is appropriate for the EAL Off-scale high or low thresholds are usually not within the calibrated range of instrumentation.
| | Dresden/Quad Cities Draft RAIs pg.l |
| Please explain how the EALs that use one or the other of these thresholds will not be confused with failed instrumentation. | | |
| The NEIIC Cross-Reference Table has several errors and should be revised to ensure a quality EAL Technical Basis Document: | | Exelon EAL Upgrade Project NRC Request for Additional Information Dresden Nuclear Power Station Quad Cities Nuclear Station Draft RAI# EAL Question |
| : a. MU2 (Exelon) not reflected as CU3 (NEI) b. HS4 (Exelon) incorrectly referenced, it is actually HS2 (Exelon) Sections 3.9, 3.10, and 3.11 from the endorsed guidance contain important information necessary to understand the intent of the guidance as well as NRC staff expectations.
| | : 1. Please confirm that all stated values, set points, and indications provided are within the calibrated range of the applicable instrumentation and that the instrumentation is appropriate for the EAL |
| Please indicate whether these sections will be incorporated into the document or fully document the technical basis for why it cannot be incorporated.
| | : 2. Off-scale high or low thresholds are usually not within the calibrated range of instrumentation. Please explain how the EALs that use one or the other of these thresholds will not be confused with failed instrumentation. |
| Missing EAL Basis Document pages, from 3-9 through 3-28 (3-29 Dresden).
| | : 3. The NEIIC Cross-Reference Table has several errors and should be revised to ensure a quality EAL Technical Basis Document: |
| The staff needs to review the entire EAL Technical Basis Document and supporting information.
| | : a. MU2 (Exelon) not reflected as CU3 (NEI) |
| Please provide the missing information or explain the discrepancy.
| | : b. HS4 (Exelon) incorrectly referenced, it is actually HS2 (Exelon) |
| The entire paragraph from Section 3.1 related to "EALs are for unplanned events ... " is incorrect and not in accordance with staff expectations or in accordance with the standard EAL scheme (section 3.9) endorsed by the NRC. Please revise to incorporate the endorsed expectation or provide technical justification to support the deviation.
| | : 4. Sections 3.9, 3.10, and 3.11 from the endorsed guidance contain important information necessary to understand the intent of the guidance as well as NRC staff expectations. Please indicate whether these sections will be 1 GENERAL incorporated into the document or fully document the technical basis for why it cannot be incorporated. |
| The NRC staff requests that ADAMS Accession No. ML080450149 be used to reference NEI 99-01, Revision 5, to ensure that the multiple draft copies of this document that are in ADAMS are not inadvertently referenced . Dresden/Quad Cities Draft RAIs pg.2 RAI# EAL 1. 2. 3. 4. 1 GENERAL 5. 6. 7. Exelon EAL Upgrade Project NRC Request for Additional Information Dresden Nuclear Power Station Quad Cities Nuclear Station Draft Question Please confirm that all stated values, set points, and indications provided are within the calibrated range of the applicable instrumentation and that the instrumentation is appropriate for the EAL Off-scale high or low thresholds are usually not within the calibrated range of instrumentation.
| | : 5. Missing EAL Basis Document pages, from 3-9 through 3-28 (3-29 Dresden). |
| Please explain how the EALs that use one or the other of these thresholds will not be confused with failed instrumentation.
| | The staff needs to review the entire EAL Technical Basis Document and supporting information. Please provide the missing information or explain the discrepancy. |
| The NEIIC Cross-Reference Table has several errors and should be revised to ensure a quality EAL Technical Basis Document: | | : 6. The entire paragraph from Section 3.1 related to "EALs are for unplanned events ... " is incorrect and not in accordance with staff expectations or in accordance with the standard EAL scheme (section 3.9) endorsed by the NRC. Please revise to incorporate the endorsed expectation or provide technical justification to support the deviation. |
| : a. MU2 (Exelon) not reflected as CU3 (NEI) b. HS4 (Exelon) incorrectly referenced, it is actually HS2 (Exelon) Sections 3.9, 3.10, and 3.11 from the endorsed guidance contain important information necessary to understand the intent of the guidance as well as NRC staff expectations.
| | : 7. The NRC staff requests that ADAMS Accession No. ML080450149 be used to reference NEI 99-01, Revision 5, to ensure that the multiple draft copies of this document that are in ADAMS are not inadvertently referenced . |
| Please indicate whether these sections will be incorporated into the document or fully document the technical basis for why it cannot be incorporated.
| | Dresden/Quad Cities Draft RAIs pg.2 |
| Missing EAL Basis Document pages, from 3-9 through 3-28 (3-29 Dresden).
| | |
| The staff needs to review the entire EAL Technical Basis Document and supporting information.
| | Exelon EAL Upgrade Project NRC Request for Additional Information Dresden Nuclear Power Station Quad Cities Nuclear Station Draft RAI# EAL Question It is expected that definitions are verbatim from the endorsed guidance, with the exception of terms specifically defined by the licensee, to ensure implementation of a standard emergency classification and action level scheme. |
| Please provide the missing information or explain the discrepancy.
| | : 1. As noted above, please provide the site-specific definitions for the following terms rather than the generic wording used in the endorsed guidance: |
| The entire paragraph from Section 3.1 related to "EALs are for unplanned events ... " is incorrect and not in accordance with staff expectations or in accordance with the standard EAL scheme (section 3.9) endorsed by the NRC. Please revise to incorporate the endorsed expectation or provide technical justification to support the deviation.
| | : a. Containment closure 2 SECT 4.0 |
| The NRC staff requests that ADAMS Accession No. ML080450149 be used to reference NEI 99-01, Revision 5, to ensure that the multiple draft copies of this document that are in ADAMS are not inadvertently referenced . Dresden/Quad Cities Draft RAIs pg.2 Exelon EAL Upgrade Project NRC Request for Additional Information Dresden Nuclear Power Quad Cities Nuclear Draft Question RAI# EAL It is expected that definitions are verbatim from the endorsed guidance, with the exception of terms specifically defined by the licensee, to ensure implementation of a standard emergency classification and action level scheme. As noted above, please provide the site-specific definitions for the following terms rather than the generic wording used in the endorsed guidance:
| | : b. Protected area |
| : a. Containment closure SECT 4.0 2 Protected area Vital area Owner controlled area Explain the deviation with adding the caveat " ... group offive or more persons ... " to the definition of Civil Disturbance. The 2nd paragraph from the endorsed guidance is not considered by the staff to be EAL Developer information.
| | : c. Vital area |
| Please incorporate this information to ensure consistency in understanding, or provide further justification.
| | : d. Owner controlled area |
| 3 RS1 [OC] Explain how the threshold for EAL #1 can be read. The typical logarithmic scale would be difficult to read 1.62 E+06. RG1 Explain the resolution for the stated indicators as the stated values are RS1 difficult to read accurately on a typical logarithmic scale. 4 RA1 [DR] Provide justification for why the set point for EAL #2 is the same for RU1 RA1 and RS1, or revise The IC states "Radiological Effluent Technical Specifications/ODCM." Typically, RA1 5 licensees use one or the other, not both. Please verify that the wording aligns RU1 with your site's document.
| | : 2. Explain the deviation with adding the caveat " ... group offive or more persons ... " to the definition of Civil Disturbance. |
| Please explain why the Secondary Alarm Station (SAS) is in Table R2, or revise 6 accordingly. | | : 1. The 2nd paragraph from the endorsed guidance is not considered by the staff to be EAL Developer information. Please incorporate this information to ensure consistency in understanding, or provide further justification. |
| Typically, it is either the Central Alarm Station (CAS) or SAS, not both. RA3 The standard EAL scheme required by 10 CFR 50.47(b) (4), and endorsed by 7 the NRC (NEI 99-01 Revision 5), has this EAL as SU4. Explain why this EAL deviates from the endorsed guidance, or revise accordingly.
| | 3 RS1 |
| RU3 Dresden/Quad Cities Draft RAIs pg.3 RAI# EAL 2 SECT 4.0 3 RS1 RG1 RS1 4 RA1 RU1 FC5 RA1 5 RU1 6 RA3 7 RU3 Exelon EAL Upgrade Project NRC Request for Additional Information Dresden Nuclear Power Station Quad Cities Nuclear Station Draft Question It is expected that definitions are verbatim from the endorsed guidance, with the exception of terms specifically defined by the licensee, to ensure implementation of a standard emergency classification and action level scheme. 1. As noted above, please provide the site-specific definitions for the following terms rather than the generic wording used in the endorsed guidance:
| | : 2. [OC] Explain how the threshold for EAL #1 can be read. The typical logarithmic scale would be difficult to read 1.62 E+06. |
| : a. Containment closure b. Protected area c. Vital area d. Owner controlled area 2. Explain the deviation with adding the caveat " ... group offive or more persons ... " to the definition of Civil Disturbance.
| | RG1 RS1 1. Explain the resolution for the stated indicators as the stated values are difficult to read accurately on a typical logarithmic scale. |
| : 1. The 2nd paragraph from the endorsed guidance is not considered by the staff to be EAL Developer information.
| | 4 RA1 |
| Please incorporate this information to ensure consistency in understanding, or provide further justification.
| | : 2. [DR] Provide justification for why the set point for EAL #2 is the same for RU1 RA1 and RS1, or revise accordingly. |
| : 2. [OC] Explain how the threshold for EAL #1 can be read. The typical logarithmic scale would be difficult to read 1.62 E+06. 1. Explain the resolution for the stated indicators as the stated values are difficult to read accurately on a typical logarithmic scale. 2. [DR] Provide justification for why the set point for EAL #2 is the same for RA1 and RS1, or revise accordingly.
| | FC5 RA1 The IC states "Radiological Effluent Technical Specifications/ODCM." Typically, 5 licensees use one or the other, not both. Please verify that the wording aligns RU1 with your site's document. |
| The IC states "Radiological Effluent Technical Specifications/ODCM." Typically, licensees use one or the other, not both. Please verify that the wording aligns with your site's document.
| | Please explain why the Secondary Alarm Station (SAS) is in Table R2, or revise 6 RA3 accordingly. Typically, it is either the Central Alarm Station (CAS) or SAS, not both. |
| Please explain why the Secondary Alarm Station (SAS) is in Table R2, or revise accordingly.
| | The standard EAL scheme required by 10 CFR 50.47(b) (4), and endorsed by 7 RU3 the NRC (NEI 99-01 Revision 5), has this EAL as SU4. Explain why this EAL deviates from the endorsed guidance, or revise accordingly. |
| Typically, it is either the Central Alarm Station (CAS) or SAS, not both. The standard EAL scheme required by 10 CFR 50.47(b) (4), and endorsed by the NRC (NEI 99-01 Revision 5), has this EAL as SU4. Explain why this EAL deviates from the endorsed guidance, or revise accordingly.
| | Dresden/Quad Cities Draft RAIs pg.3 |
| Dresden/Quad Cities Draft RAIs pg.3 Exelon EAL Upgrade Project NRC Request for Additional Dresden Nuclear Power Quad Cities Nuclear Draft RAI# EAL Question 8 FISSION BARRIER MATRIX 1. 2. Need to see the Fission Barrier Matrix Table as it is part of the standard EAL scheme required by 10 CFR 50.47(b)(4), and endorsed by the NRC (NEI 99-01 Revision 5). Please provide sufficient justification to support not developing additional thresholds, Le., "other," as expected from the endorsed guidance.
| | |
| 9 CT7 1. i 2. Please explain the deviation from the endorsed guidance and standard EAL Scheme for LOSS 1.a, i.e., you did not state "all" isolation valves. This could lead to a misunderstanding as to the intent of the threshold.
| | Exelon EAL Upgrade Project NRC Request for Additional Information Dresden Nuclear Power Station Quad Cities Nuclear Station Draft RAI# EAL Question |
| Please explain in more detail why the 2nd paragraph was added to the Basis information as this is not as endorsed and not considered to be in alignment with the standard EAL scheme as it specifically excludes expected consideration of the threshold.
| | : 1. Need to see the Fission Barrier Matrix Table as it is part of the standard FISSION EAL scheme required by 10 CFR 50.47(b)(4), and endorsed by the NRC 8 BARRIER (NEI 99-01 Revision 5). |
| 10 MA2, MU3, MU4, MA5, MU5, MG8, MS8, MA8, MU8, MU9, MU10/MU6*
| | MATRIX 2. Please provide sufficient justification to support not developing additional thresholds, Le., "other," as expected from the endorsed guidance. |
| The standard EAL scheme required by 10 CFR 50.47(b) (4), and endorsed by the NRC (NEI 99-01 Revision 5), has these EALs in their own unique table, and own unique IC designation, for Cold/Refuel EALs. Explain why this EAL deviates from the endorsed guidance and from the regulatory required standard EAL scheme, or revise accordingly.
| | : 1. Please explain the deviation from the endorsed guidance and standard EAL Scheme for LOSS 1.a, i.e., you did not state "all" isolation valves. This could lead to a misunderstanding as to the intent of the threshold. |
| *MU10 and MU6 were combined for Cold and Hot operating modes. As stated above, the staff expects an IC/EAL for each. 11 MG1 MS1 MA1 MA2 MU2 Explain how the SBO Diesel Generator is addressed in your Tech Specs, specifically, how is this DG controlled such that it can be relied upon as part of this EAL set. 12 MA3 Explain how one threshold can be based on Reactor Power >6% and the other threshold be based upon Reactor Power This appears to be a contrad iction. 13 MU3 Explain the statement, "This EAL is satisfied when corrective actions are required in response to an unplanned sustained positive startup rate to mitigate the positive startup rate." This is not from the endorsed guidance and may lead to errors in meeting staff expectations for EAL classification.
| | 9 CT7 i 2. Please explain in more detail why the 2nd paragraph was added to the Basis information as this is not as endorsed and not considered to be in alignment with the standard EAL scheme as it specifically excludes expected consideration of the threshold. |
| Dresden/Quad Cities Draft RAIs pg.4 RAI# EAL FISSION 8 BARRIER MATRIX 9 CT7 MA2, MU3, MU4, MA5, 10 MU5, MG8, MS8, MA8, MU8, MU9, MU10/MU6*
| | The standard EAL scheme required by 10 CFR 50.47(b) (4), and endorsed by MA2, MU3, the NRC (NEI 99-01 Revision 5), has these EALs in their own unique table, and MU4, MA5, own unique IC designation, for Cold/Refuel EALs. Explain why this EAL MU5, MG8, deviates from the endorsed guidance and from the regulatory required standard 10 MS8, MA8, EAL scheme, or revise accordingly. |
| MG1 MS1 11 MA1 MA2 MU2 12 MA3 13 MU3 1. 2. 1. i 2. Exelon EAL Upgrade Project NRC Request for Additional Information Dresden Nuclear Power Station Quad Cities Nuclear Station Draft Question Need to see the Fission Barrier Matrix Table as it is part of the standard EAL scheme required by 10 CFR 50.47(b)(4), and endorsed by the NRC (NEI 99-01 Revision 5). Please provide sufficient justification to support not developing additional thresholds, Le., "other," as expected from the endorsed guidance.
| | MU8, MU9, MU10/MU6* *MU10 and MU6 were combined for Cold and Hot operating modes. As stated above, the staff expects an IC/EAL for each. |
| Please explain the deviation from the endorsed guidance and standard EAL Scheme for LOSS 1.a, i.e., you did not state "all" isolation valves. This could lead to a misunderstanding as to the intent of the threshold.
| | MG1 MS1 Explain how the SBO Diesel Generator is addressed in your Tech Specs, 11 MA1 specifically, how is this DG controlled such that it can be relied upon as part of this EAL set. |
| Please explain in more detail why the 2nd paragraph was added to the Basis information as this is not as endorsed and not considered to be in alignment with the standard EAL scheme as it specifically excludes expected consideration of the threshold.
| | MA2 MU2 Explain how one threshold can be based on Reactor Power >6% and the other 12 MA3 threshold be based upon Reactor Power ~%. This appears to be a contrad iction. |
| The standard EAL scheme required by 10 CFR 50.47(b) (4), and endorsed by the NRC (NEI 99-01 Revision 5), has these EALs in their own unique table, and own unique IC designation, for Cold/Refuel EALs. Explain why this EAL deviates from the endorsed guidance and from the regulatory required standard EAL scheme, or revise accordingly.
| | Explain the statement, "This EAL is satisfied when corrective actions are required in response to an unplanned sustained positive startup rate to mitigate 13 MU3 the positive startup rate." This is not from the endorsed guidance and may lead to errors in meeting staff expectations for EAL classification. |
| *MU10 and MU6 were combined for Cold and Hot operating modes. As stated above, the staff expects an IC/EAL for each. Explain how the SBO Diesel Generator is addressed in your Tech Specs, specifically, how is this DG controlled such that it can be relied upon as part of this EAL set. Explain how one threshold can be based on Reactor Power >6% and the other threshold be based upon Reactor Power This appears to be a contrad iction. Explain the statement, "This EAL is satisfied when corrective actions are required in response to an unplanned sustained positive startup rate to mitigate the positive startup rate." This is not from the endorsed guidance and may lead to errors in meeting staff expectations for EAL classification.
| | Dresden/Quad Cities Draft RAIs pg.4 |
| Dresden/Quad Cities Draft RAIs pg.4 Exelon EAL Upgrade Project NRC Request for Additional Dresden Nuclear Power Quad Cities Nuclear Draft RAI# EAL Question 14 MU7 Please explain why the information related to a stuck open relief valve was not incorporated into this EAL as endorsed in the guidance, or revise accordingly.
| | |
| 15 MU8 Please explain why you added the deviation from the endorsed guidance related to * ... restore and maintained
| | Exelon EAL Upgrade Project NRC Request for Additional Information Dresden Nuclear Power Station Quad Cities Nuclear Station Draft RAI# EAL Question Please explain why the information related to a stuck open relief valve was not 14 MU7 incorporated into this EAL as endorsed in the guidance, or revise accordingly. |
| ... " in the Basis information.
| | Please explain why you added the deviation from the endorsed guidance related 15 MU8 to * ... restore and maintained ... " in the Basis information. The expectation is that level must be back above the procedurally established limit. |
| The expectation is that level must be back above the procedurally established limit. 16 MU10 Please explain how the Nuclear Alert Reporting System (NARS) line can notify the NRC (for offsite).
| | Please explain how the Nuclear Alert Reporting System (NARS) line can notify 16 MU10 the NRC (for offsite). |
| 17 HU3 The standard EAL scheme required by 10 CFR 50.47(b) (4), and endorsed by the NRC (NEI 99-01 Revision 5), has the explosion EAL without the 'damage' caveat. Explain why you have a deviation from the endorsed guidance and from the regulatory required standard EAL scheme, or revise accordingly for the threshold and Basis. 18 HA4 HU4 Please explain how an earthquake could be so selective that it only impacts certain areas of the site and not others as stated in your basis in your definition of *in plan!"? 19 HA5 The Basis information is considered to be a deviation from the endorsed guidance and contrary to the regulatory requirement for a standard EAL scheme. The information from the endorsed guidance, particularly the 3rd paragraph, states the staff's expectations for this EAL. The 3rd and 4th paragraphs in your submittal conflict with that expectation.
| | The standard EAL scheme required by 10 CFR 50.47(b) (4), and endorsed by the NRC (NEI 99-01 Revision 5), has the explosion EAL without the 'damage' 17 HU3 caveat. Explain why you have a deviation from the endorsed guidance and from the regulatory required standard EAL scheme, or revise accordingly for the threshold and Basis. |
| Please provide sufficient justification for the deviation, or revise accordingly.
| | HA4 Please explain how an earthquake could be so selective that it only impacts 18 certain areas of the site and not others as stated in your basis in your definition HU4 of *in plan!"? |
| 20 HU5 The 4th and ih paragraphs of your Basis information are a deviation from the endorsed guidance.
| | The Basis information is considered to be a deviation from the endorsed guidance and contrary to the regulatory requirement for a standard EAL scheme. The information from the endorsed guidance, particularly the 3rd 19 HA5 paragraph, states the staff's expectations for this EAL. The 3rd and 4th paragraphs in your submittal conflict with that expectation. Please provide sufficient justification for the deviation, or revise accordingly. |
| Please explain in more detail, or revise accordingly.
| | The 4th and ih paragraphs of your Basis information are a deviation from the 20 HU5 endorsed guidance. Please explain in more detail, or revise accordingly. |
| Dresden/Quad Cities Draft RAIs pg.5 RAI# EAL 14 MU7 15 MU8 16 MU10 17 HU3 HA4 18 HU4 19 HA5 20 HU5 Exelon EAL Upgrade Project NRC Request for Additional Information Dresden Nuclear Power Station Quad Cities Nuclear Station Draft Question Please explain why the information related to a stuck open relief valve was not incorporated into this EAL as endorsed in the guidance, or revise accordingly.
| | Dresden/Quad Cities Draft RAIs pg.5}} |
| Please explain why you added the deviation from the endorsed guidance related to * ... restore and maintained
| |
| ... " in the Basis information.
| |
| The expectation is that level must be back above the procedurally established limit. Please explain how the Nuclear Alert Reporting System (NARS) line can notify the NRC (for offsite).
| |
| The standard EAL scheme required by 10 CFR 50.47(b) (4), and endorsed by the NRC (NEI 99-01 Revision 5), has the explosion EAL without the 'damage' caveat. Explain why you have a deviation from the endorsed guidance and from the regulatory required standard EAL scheme, or revise accordingly for the threshold and Basis. Please explain how an earthquake could be so selective that it only impacts certain areas of the site and not others as stated in your basis in your definition of *in plan!"? The Basis information is considered to be a deviation from the endorsed guidance and contrary to the regulatory requirement for a standard EAL scheme. The information from the endorsed guidance, particularly the 3rd paragraph, states the staff's expectations for this EAL. The 3rd and 4th paragraphs in your submittal conflict with that expectation.
| |
| Please provide sufficient justification for the deviation, or revise accordingly.
| |
| The 4th and ih paragraphs of your Basis information are a deviation from the endorsed guidance.
| |
| Please explain in more detail, or revise accordingly. | |
| Dresden/Quad Cities Draft RAIs pg.5}} | |
Letter Sequence Draft RAI |
|---|
|
|
MONTHYEARML1011602662010-06-0101 June 2010
University of Missouri at Columbia - Request for Additional Information License Renewal, Safety Analysis Report, 45-Day Response Questions
Project stage: RAI
ML1008800852010-07-21021 July 2010
Fleet - Acceptance Review Implementation of Emergency Action Level Schemes Developed from NEI 99-01m Rev. 5
Project stage: Acceptance Review
ML1021505302010-07-29029 July 2010
Attachment to Draft RAIs -Exelon EAL Upgrade Project
Project stage: Draft RAI
ML1021505272010-07-29029 July 2010
Draft NRC RAI Dresden and Quad - Emergency Action Levels Based on NEI 99-01 Rev 5
Project stage: Draft RAI
ML1023804012010-08-24024 August 2010
Request for Exemption from Physical Security Requirements
Project stage: Request
ML1029400142010-10-17017 October 2010
Supplement to Request for Exemption from Physical Security Requirements
Project stage: Supplement
ML1029206912010-10-17017 October 2010
Supplement to Request for Exemption from Physical Security Requirements
Project stage: Supplement
ML1032105082010-11-16016 November 2010
Units 1 & 2 - Electronic Transmission, Draft Request for Additional Information Regarding Request to Implement Emergency Action Level Scheme Change to NEI 99-01, Revision 5
Project stage: Draft RAI
ML1031203322010-12-14014 December 2010
Emergency Action Level Scheme Change to NEI 99-01; Revision 5
Project stage: Other
ML1034101262010-12-28028 December 2010
Request for Additional Information Implementation of Emergency Action Level Schemes Developed from NEI 99-01, Revision 5
Project stage: RAI
ML1036305532011-01-0606 January 2011
Summary of Meeting (Teleconference) with Exelon to Discuss RAI Regarding the Implementation of an Emergency Action Level Scheme Based on NEI 99-01, Rev. 5
Project stage: RAI
ML1116500972011-06-30030 June 2011
Fleet - Approval of Change from Emergency Action Level Scheme Based on NEI 99-01, Revision 4, to NEI 99-01, Revision 5
Project stage: Other
ML1131301972011-11-10010 November 2011
University of Missouri, Columbia - Approval for Request of Additional Time to Respond to NRC Request for Additional Information License Renewal (Tac No. ME3034)
Project stage: RAI
2010-07-21
[Table View] |
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|---|
Category:Request for Additional Information (RAI)
MONTHYEARML23349A0362023-12-14014 December 2023
NRR E-mail Capture - Draft Request for Additional Information Re Quad Cities Emergency Amendment Related to Unit 1 Diesel Generator Inoperability
ML23338A1192023-11-21021 November 2023
NRR E-mail Capture - Draft Request for Additional Information Quad Cities Relief Request I5R-26
ML23264A7992023-09-21021 September 2023
NRR E-mail Capture - Final RAI - Constellation Energy Generation, LLC Fleet Request License Amendment Request to Adopt TSTF-580, Revision 1
ML23187A0462023-07-0606 July 2023
Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000237/2023004
ML23118A1652023-04-28028 April 2023
NRR E-mail Capture - Request for Additional Information Quad Cities, Unit 2, Alternative Request I6R-11
ML23110A3202023-04-21021 April 2023
Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection
ML23065A2832023-03-0707 March 2023
Request for Information for the NRC Quadrennial Comprehensive Engineering Team Inspection: Inspection Report 05000254/2023010 and 05000265/2023010
ML23052A0652023-02-21021 February 2023
NRR E-mail Capture - Dresden Units 2 and 3 - Request for Additional Information for Alternative Request RV-23H
ML23037A9192023-02-0707 February 2023
Request for Information for the NRC Quadrennial Comprehensive Engineering Team Inspection: Inspection Report 05000237/2023011 and 05000249/2023011
ML23013A1502023-01-17017 January 2023
Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000254/2023002
ML23019A0132023-01-12012 January 2023
NRR E-mail Capture - Final RAI Dresden 2 and 3 - License Amendment Pertaining to GNF3 Fuel Transition
ML23004A0262022-12-16016 December 2022
NRR E-mail Capture - Draft Request for Additional Information - Quad Cities Alternative RV-04, Inservice Testing of High Pressure Coolant Injection Drain Pot Solenoid Valves (EPD L-2022-LLR-0070)
ML22348A0452022-12-14014 December 2022
NRR E-mail Capture - Draft Request for Additional Information Regarding Quad Cities Alternative I6R-09
ML22290A0842022-10-13013 October 2022
NRR E-mail Capture - Dresden 2 and 3 - RAI License Amendment Request Regarding New Fuel Storage Vault and Spent Fuel Storage Pool Criticality Methodologies
ML22227A1152022-09-27027 September 2022
Request for Withholding Information from Public Disclosure
ML22270A1032022-09-27027 September 2022
Notification of NRC Baseline Inspection and Request for Information (05000249/2022004)
ML22256A0112022-09-12012 September 2022
NRR E-mail Capture - Request for Additional Information LaSalle County Station, Units 1 and 2 and Quad Cities Nuclear Power Station, Units 1 and 2 License Amendments Related to Fuel Storage
ML22249A2332022-09-0606 September 2022
Notification of NRC Fire Protection Team Inspection Request for Information Inspection Report 05000254/2022011 05000265/2022011
ML22203A0442022-07-21021 July 2022
Request for Additional Information (RAI)
ML22206A0352022-07-13013 July 2022
NRR E-mail Capture - Draft RAI Quad Cities Alternative Related to Sblc Nozzle Inspection
ML22199A2422022-07-13013 July 2022
NRR E-mail Capture - Draft RAI Dresden 2 and 3 Proposed Alternative Related to Sblc Nozzle Inspection for the Sixth Inservice Inspection Interval
ML22193A0412022-07-11011 July 2022
NRR E-mail Capture - RAI Quad Cities License Amendment to Expand the Use of Prime Methods
ML22182A1992022-07-0101 July 2022
NRR E-mail Capture - RAI Alternative RV-11, Code Case OMN-28
ML22178A1362022-06-28028 June 2022
Information Request to Support Upcoming Problem Identification and Resolution (Pi&R) Inspection at Quad Cities Station
ML22164A7852022-06-13013 June 2022
NRR E-mail Capture - RAI Quad Cities Amendment for Spent Fuel Pool Storage Analysis
ML22164A8562022-06-13013 June 2022
NRR E-mail Capture - RAI Quad Cities Alternative RV-08, Safety Relief Valves
ML22164A8582022-06-13013 June 2022
NRR E-mail Capture - RAI Alternative RV-09, MSSVs
ML22076A1122022-03-15015 March 2022
Request for Additional Information Related to the Amendment Request to Transition to GNF3 Fuels (EPID L-2021-LLA-0159) (Redacted)
ML22059A9902022-03-0101 March 2022
Supplemental Information Needed for Acceptance of Requested Licensing Action Amendment to Implement Prime Methodologies for Evaluating Thermal Overpower and Mechanical Overpower Limits for Non-Global Nuclear Fuels Fuel
ML22041B5362022-02-10010 February 2022
NRR E-mail Capture - Constellation Energy Generation, LLC - Request for Additional Information Regarding Fleet License Amendment Request to Adopt TSTF-541
ML22039A1912022-02-0808 February 2022
Information Request for an NRC Triennial 10 CFR 50.59 (Evaluation of Changes, Tests, and Experiments) Baseline Inspection
ML22020A0642022-01-13013 January 2022
NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative for Repair of Water Level Instrumentation Partial Penetration Nozzles
ML21342A3842021-12-0808 December 2021
NRR E-mail Capture - Request for Additional Information: Quad Cities 1 & 2 License Amendment Request Transition to GNF3 Fuel
ML21294A0032021-10-26026 October 2021
Supplemental Information Needed for Acceptance of Requested Licensing Action License Amendment Request Regarding Transition to GNF3 Fuel
ML21256A1902021-09-10010 September 2021
NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application
ML21238A3142021-08-26026 August 2021
Notification of an NRC Triennial Heat Sink Performance Inspection and Request for Information; Inspection Report 05000254/2021004; 05000265/2021004
ML21244A4012021-08-10010 August 2021
(Final) Request for Information (RAI) Dresden, Units 1, 2, 3, and ISFSI Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50 Appendix E
ML21190A0192021-07-0808 July 2021
NRR E-mail Capture - Exelon Fleet - Request for Additional Information Regarding Adoption of TSTF-582 and TSTF-583-T
ML21144A2132021-05-24024 May 2021
NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application
ML21097A2602021-04-0808 April 2021
Notification of an NRC Biennial Licensed Operator Requalification Program Inspection and Request for Information
ML21096A1752021-04-0606 April 2021
Notification of NRC Fire Protection Team Inspection Request for Information: Inspection Report 05000237/2021011; 05000249/2021011
ML21063A3202021-03-0202 March 2021
RAIs for Dresden, Units 2 and 3, Proposed Defueled Technical Specifications and Revised License Conditions for Permanently Defueled Condition (EPID L-2020-LLA-0239) (E-mail)
ML21062A0652021-03-0101 March 2021
NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative to Documentation Requirements for Pressure Retaining Bolting
ML21049A2572021-02-18018 February 2021
Request for Additional Information Byron/Dresden Proposed Changes to Site Emergency Plans to Support Post-Shutdown and Permanently Defueled Conditions (EPID-2020-LLA-0240 & EPID-2020-LLA-0237)
ML20337A4242020-12-0202 December 2020
Information Request for the Cyber-Security Full Implementation Inspection, Notification to Perform Inspection 05000237/2021401 and 05000249/2021401
ML20239A7982020-08-25025 August 2020
NRR E-mail Capture - Exelon Generation Company, LLC - Fleet License Amendment Request to Adopt TSTF-568, Revision 2
ML20231A7432020-08-18018 August 2020
Request for Additional Information (IOLB/HFT-RAI-1) Dresden MSIV LAR
ML20224A3532020-08-11011 August 2020
Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000249/2020004
ML20183A2852020-07-0101 July 2020
Request for Information for an NRC Triennial Baseline Bases Assurance Inspection (Team): Inspection Report 05000254/2020011 and 05000265/2020011
ML20135H1972020-05-14014 May 2020
NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Request to Extend Safety Relief Valve Test Interval
2023-09-21
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Exelon EAL Upgrade Project NRC Request for Additional Information Dresden Nuclear Power Station Quad Cities Nuclear Station Draft RAI# I EAL Question It is expected that licensees adhere to endorsed guidance, particularly for Initiating Conditions and Definitions, with no differences or deviations other than those related to a licensee's particular design. This is to ensure regulatory stability of the Emergency Action Level (EAL) scheme.
This also ensures that, as stated in Title 10 of the Code of Federal Regulations, (10 CFR), Paragraph 50.47(b)(4), licensees implement "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters ... :
GENERIC While the NRC staff is not enforcing strict verbatim compliance with the endorsed guidance, where applicable, the NRC staff will be pointing out areas where it expects the endorsed guidance to be used to ensure implementation of a standard scheme. This is primarily based upon industry and NRC staff experience with issues related to a particular EAL.
While formatting is usually not technically relevant to the NRC staffs review of EALs, when inconsistent formatting may result in potential misunderstanding, an RAI will be developed to correct the formatting or to obtain additional information in support of the deviation.
Dresden/Quad Cities Draft RAIs pg.l
Exelon EAL Upgrade Project NRC Request for Additional Information Dresden Nuclear Power Station Quad Cities Nuclear Station Draft RAI# EAL Question
- 1. Please confirm that all stated values, set points, and indications provided are within the calibrated range of the applicable instrumentation and that the instrumentation is appropriate for the EAL
- 2. Off-scale high or low thresholds are usually not within the calibrated range of instrumentation. Please explain how the EALs that use one or the other of these thresholds will not be confused with failed instrumentation.
- 3. The NEIIC Cross-Reference Table has several errors and should be revised to ensure a quality EAL Technical Basis Document:
- a. MU2 (Exelon) not reflected as CU3 (NEI)
- b. HS4 (Exelon) incorrectly referenced, it is actually HS2 (Exelon)
- 4. Sections 3.9, 3.10, and 3.11 from the endorsed guidance contain important information necessary to understand the intent of the guidance as well as NRC staff expectations. Please indicate whether these sections will be 1 GENERAL incorporated into the document or fully document the technical basis for why it cannot be incorporated.
- 5. Missing EAL Basis Document pages, from 3-9 through 3-28 (3-29 Dresden).
The staff needs to review the entire EAL Technical Basis Document and supporting information. Please provide the missing information or explain the discrepancy.
- 6. The entire paragraph from Section 3.1 related to "EALs are for unplanned events ... " is incorrect and not in accordance with staff expectations or in accordance with the standard EAL scheme (section 3.9) endorsed by the NRC. Please revise to incorporate the endorsed expectation or provide technical justification to support the deviation.
- 7. The NRC staff requests that ADAMS Accession No. ML080450149 be used to reference NEI 99-01, Revision 5, to ensure that the multiple draft copies of this document that are in ADAMS are not inadvertently referenced .
Dresden/Quad Cities Draft RAIs pg.2
Exelon EAL Upgrade Project NRC Request for Additional Information Dresden Nuclear Power Station Quad Cities Nuclear Station Draft RAI# EAL Question It is expected that definitions are verbatim from the endorsed guidance, with the exception of terms specifically defined by the licensee, to ensure implementation of a standard emergency classification and action level scheme.
- 1. As noted above, please provide the site-specific definitions for the following terms rather than the generic wording used in the endorsed guidance:
- a. Containment closure 2 SECT 4.0
- b. Protected area
- c. Vital area
- d. Owner controlled area
- 2. Explain the deviation with adding the caveat " ... group offive or more persons ... " to the definition of Civil Disturbance.
- 1. The 2nd paragraph from the endorsed guidance is not considered by the staff to be EAL Developer information. Please incorporate this information to ensure consistency in understanding, or provide further justification.
3 RS1
- 2. [OC] Explain how the threshold for EAL #1 can be read. The typical logarithmic scale would be difficult to read 1.62 E+06.
RG1 RS1 1. Explain the resolution for the stated indicators as the stated values are difficult to read accurately on a typical logarithmic scale.
4 RA1
- 2. [DR] Provide justification for why the set point for EAL #2 is the same for RU1 RA1 and RS1, or revise accordingly.
FC5 RA1 The IC states "Radiological Effluent Technical Specifications/ODCM." Typically, 5 licensees use one or the other, not both. Please verify that the wording aligns RU1 with your site's document.
Please explain why the Secondary Alarm Station (SAS) is in Table R2, or revise 6 RA3 accordingly. Typically, it is either the Central Alarm Station (CAS) or SAS, not both.
The standard EAL scheme required by 10 CFR 50.47(b) (4), and endorsed by 7 RU3 the NRC (NEI 99-01 Revision 5), has this EAL as SU4. Explain why this EAL deviates from the endorsed guidance, or revise accordingly.
Dresden/Quad Cities Draft RAIs pg.3
Exelon EAL Upgrade Project NRC Request for Additional Information Dresden Nuclear Power Station Quad Cities Nuclear Station Draft RAI# EAL Question
- 1. Need to see the Fission Barrier Matrix Table as it is part of the standard FISSION EAL scheme required by 10 CFR 50.47(b)(4), and endorsed by the NRC 8 BARRIER (NEI 99-01 Revision 5).
MATRIX 2. Please provide sufficient justification to support not developing additional thresholds, Le., "other," as expected from the endorsed guidance.
- 1. Please explain the deviation from the endorsed guidance and standard EAL Scheme for LOSS 1.a, i.e., you did not state "all" isolation valves. This could lead to a misunderstanding as to the intent of the threshold.
9 CT7 i 2. Please explain in more detail why the 2nd paragraph was added to the Basis information as this is not as endorsed and not considered to be in alignment with the standard EAL scheme as it specifically excludes expected consideration of the threshold.
The standard EAL scheme required by 10 CFR 50.47(b) (4), and endorsed by MA2, MU3, the NRC (NEI 99-01 Revision 5), has these EALs in their own unique table, and MU4, MA5, own unique IC designation, for Cold/Refuel EALs. Explain why this EAL MU5, MG8, deviates from the endorsed guidance and from the regulatory required standard 10 MS8, MA8, EAL scheme, or revise accordingly.
MU8, MU9, MU10/MU6* *MU10 and MU6 were combined for Cold and Hot operating modes. As stated above, the staff expects an IC/EAL for each.
MG1 MS1 Explain how the SBO Diesel Generator is addressed in your Tech Specs, 11 MA1 specifically, how is this DG controlled such that it can be relied upon as part of this EAL set.
MA2 MU2 Explain how one threshold can be based on Reactor Power >6% and the other 12 MA3 threshold be based upon Reactor Power ~%. This appears to be a contrad iction.
Explain the statement, "This EAL is satisfied when corrective actions are required in response to an unplanned sustained positive startup rate to mitigate 13 MU3 the positive startup rate." This is not from the endorsed guidance and may lead to errors in meeting staff expectations for EAL classification.
Dresden/Quad Cities Draft RAIs pg.4
Exelon EAL Upgrade Project NRC Request for Additional Information Dresden Nuclear Power Station Quad Cities Nuclear Station Draft RAI# EAL Question Please explain why the information related to a stuck open relief valve was not 14 MU7 incorporated into this EAL as endorsed in the guidance, or revise accordingly.
Please explain why you added the deviation from the endorsed guidance related 15 MU8 to * ... restore and maintained ... " in the Basis information. The expectation is that level must be back above the procedurally established limit.
Please explain how the Nuclear Alert Reporting System (NARS) line can notify 16 MU10 the NRC (for offsite).
The standard EAL scheme required by 10 CFR 50.47(b) (4), and endorsed by the NRC (NEI 99-01 Revision 5), has the explosion EAL without the 'damage' 17 HU3 caveat. Explain why you have a deviation from the endorsed guidance and from the regulatory required standard EAL scheme, or revise accordingly for the threshold and Basis.
HA4 Please explain how an earthquake could be so selective that it only impacts 18 certain areas of the site and not others as stated in your basis in your definition HU4 of *in plan!"?
The Basis information is considered to be a deviation from the endorsed guidance and contrary to the regulatory requirement for a standard EAL scheme. The information from the endorsed guidance, particularly the 3rd 19 HA5 paragraph, states the staff's expectations for this EAL. The 3rd and 4th paragraphs in your submittal conflict with that expectation. Please provide sufficient justification for the deviation, or revise accordingly.
The 4th and ih paragraphs of your Basis information are a deviation from the 20 HU5 endorsed guidance. Please explain in more detail, or revise accordingly.
Dresden/Quad Cities Draft RAIs pg.5
