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| | number = ML082960642 | | | number = ML082960642 |
| | issue date = 10/22/2008 | | | issue date = 10/22/2008 |
| | title = Davis-Besse EAL - RAIs | | | title = EAL - RAIs |
| | author name = | | | author name = |
| | author affiliation = NRC/NRR | | | author affiliation = NRC/NRR |
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| =Text= | | =Text= |
| {{#Wiki_filter:Davis-Besse NRC Request for Additional Information (RAI) | | {{#Wiki_filter:Davis-Besse NRC Request for Additional Information (RAI) |
| Page 1 RAI # EAL Question GENERIC It is expected that licensee's 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 by enforcing the expectation that licensees adhere to NRC reviewed and endorsed guidance with no non-design related deviations and little to no differences. While the NRC is not proposing verbatim compliance with the endorsed guidance, where applicable, the NRC will be pointing out areas where we expect compliance with the endorsed guidance. This is primarily based upon industry and NRC experience with issues related to the particular EAL. 1 DEFINITIONS 1. Explain why you deviated from the endorsed guidance by not including a definition for "extortion," "sabotage," or "security condition," or incorporate the definitions as expected. 2. The site definition of "large aircraft" is considered potential official use only (OUO) by the NRC and is not to be incorporated into the EAL scheme. 2 ISFSI, HU6 It is expected that the EAL related to ISFSI be incorporated using a separate numbering convention. The endorsed guidance uses E-HU1, but EU1 has been found acceptable at other utilities. Please explain why this deviation is necessary.
| | RAI # 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 licensees particular design. This is to ensure regulatory stability by enforcing the expectation that licensees adhere to NRC reviewed GENERIC and endorsed guidance with no non-design related deviations and little to no differences. While the NRC is not proposing verbatim compliance with the endorsed guidance, where applicable, the NRC will be pointing out areas where we expect compliance with the endorsed guidance. This is primarily based upon industry and NRC experience with issues related to the particular EAL. |
| 3 PAGE 5, 1 ST PARAGRAPH This is a deviation from endorsed guidance. Please explain why this deviation is necessary or follow endorsed guidance.
| | : 1. Explain why you deviated from the endorsed guidance by not including a definition for extortion, sabotage, or security condition, or incorporate 1 DEFINITIONS the definitions as expected. |
| 4 FISSION BARRIER Does your site use Critical Function Status Trees? | | : 2. The site definition of large aircraft is considered potential official use only (OUO) by the NRC and is not to be incorporated into the EAL scheme. |
| 5 FUEL CLAD, POTENTIAL LOSS Please explain why low level AND high temperatures are needed for this barrier? As high temperature is already considered in the FB matrix, this appears redundant and unnecessary.
| | It is expected that the EAL related to ISFSI be incorporated using a separate numbering convention. The endorsed guidance uses E-HU1, but EU1 has 2 ISFSI, HU6 been found acceptable at other utilities. Please explain why this deviation is necessary. |
| 6 RG1, RS1, RA1, RU1, HU4, SS1, SA1, SU1, SS2, SS4, SA4, SU4, CA1, CU1, CU2, CG7, CS7, CA7, CU7, CU8, CU10 Add the timing notes from the endorsed guidance or explain their omission. These were added due to the numerous issues related to licensee's understanding the NRC's expectations related to the timeliness of EAL declarations. 7 RG1, RS1 Please explain how you will address CDE Thyroid for adults. This question was answered via telecon between NSIR reviewer D.Johnson and Davis-Besse licensing, dated 10/15/2008 8 RS1 "-using actual meteorology" in the IC is a deviation from the endorsed guidance. Please explain the deviation or follow the endorsed guidance.
| | ST PAGE 5, 1 This is a deviation from endorsed guidance. Please explain why this deviation 3 |
| | PARAGRAPH is necessary or follow endorsed guidance. |
| | FISSION 4 Does your site use Critical Function Status Trees? |
| | BARRIER FUEL CLAD, Please explain why low level AND high temperatures are needed for this 5 POTENTIAL barrier? As high temperature is already considered in the FB matrix, this LOSS appears redundant and unnecessary. |
| | RG1, RS1, RA1, RU1, HU4, SS1, SA1, SU1, Add the timing notes from the endorsed guidance or explain their omission. |
| | SS2, SS4, These were added due to the numerous issues related to licensees 6 SA4, SU4, understanding the NRCs expectations related to the timeliness of EAL CA1, CU1, declarations. |
| | CU2, CG7, CS7, CA7, CU7, CU8, CU10 Please explain how you will address CDE Thyroid for adults. |
| | 7 RG1, RS1 This question was answered via telecon between NSIR reviewer D.Johnson and Davis-Besse licensing, dated 10/15/2008 using actual meteorology in the IC is a deviation from the endorsed 8 RS1 guidance. Please explain the deviation or follow the endorsed guidance. |
| | Page 1 |
| | |
| Davis-Besse NRC Request for Additional Information (RAI) | | Davis-Besse NRC Request for Additional Information (RAI) |
| Page 2 RAI # EAL Question 9 RA1 Please explain how EAL decision-makers will be able to differentiate between "top of scale" as an EAL entry condition versus failed instrumentation.
| | RAI # EAL Question Please explain how EAL decision-makers will be able to differentiate between 9 RA1 top of scale as an EAL entry condition versus failed instrumentation. |
| 10 RA3 You included site specific information as to why CAS is on the list but did not mention that maintaining access through site doors and security barriers is the basis for CAS being on this list. This may lead to misconceptions as to the intent of the EAL. Please explain why this was not incorporated or revise to reflect the above information.
| | You included site specific information as to why CAS is on the list but did not mention that maintaining access through site doors and security barriers is the 10 RA3 basis for CAS being on this list. This may lead to misconceptions as to the intent of the EAL. Please explain why this was not incorporated or revise to reflect the above information. |
| 11 HA1 Please explain why you deviated from endorsed guidance and added potentially 'official use only" information to the EAL by stating "large aircraft" instead of "airliner". While the term does not create a potential OUO issue directly in the EAL, it's use led to it being defined, which leads to the potential OUO. 12 HU1 The term "security condition" was developed by a joint EP-Security industry team to better align EALs with the upcoming revision to site security contingency plans via a revision to NEI 03-12. This term is important to this needed alignment. Please explain the deviation or revise to follow endorsed guidance.
| | Please explain why you deviated from endorsed guidance and added potentially official use only information to the EAL by stating large aircraft 11 HA1 instead of airliner. While the term does not create a potential OUO issue directly in the EAL, its use led to it being defined, which leads to the potential OUO. |
| 13 HA3, HU3, HA4, HU4 Please explain why your diesel generator room(s) are not considered a safe shutdown vital area.
| | The term security condition was developed by a joint EP-Security industry team to better align EALs with the upcoming revision to site security 12 HU1 contingency plans via a revision to NEI 03-12. This term is important to this needed alignment. Please explain the deviation or revise to follow endorsed guidance. |
| 14 HU4 You stated "For the purposes of declaring an emergency event, the term "extinguished" means no visible flames." Explain why excessive smoke or other indications of a possible fire are not included as a discriminator for defining when a fire is extinguished. 15 SA1, SA3 Please explain the deviation in the IC or revise accordingly. 16 SS3 Please elaborate as to what "controls area" means. Is this synonymous with the reactor control console? 17 SA3 Please explain the deviation of not adding the expected EAL 1b or add accordingly.
| | HA3, HU3, Please explain why your diesel generator room(s) are not considered a safe 13 HA4, HU4 shutdown vital area. |
| 18 SS4, SA4, SU4 The expectation for the logic is an "or" or "either". Please elaborate on why consideration must be given to endorse a new EAL scheme or revise accordingly.}}
| | You stated For the purposes of declaring an emergency event, the term extinguished means no visible flames. Explain why excessive smoke or 14 HU4 other indications of a possible fire are not included as a discriminator for defining when a fire is extinguished. |
| | 15 SA1, SA3 Please explain the deviation in the IC or revise accordingly. |
| | Please elaborate as to what controls area means. Is this synonymous with 16 SS3 the reactor control console? |
| | Please explain the deviation of not adding the expected EAL 1b or add 17 SA3 accordingly. |
| | The expectation for the logic is an or or either. Please elaborate on why SS4, SA4, 18 consideration must be given to endorse a new EAL scheme or revise SU4 accordingly. |
| | Page 2}} |
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Category:Request for Additional Information (RAI)
MONTHYEARML24274A1482024-09-30030 September 2024
NRR E-mail Capture - Davis-Besse - RAI Re Relief Request L-23-214
ML24260A2382024-09-16016 September 2024
Notification of an NRC Biennial Licensed Operator Requalification Program Inspection and Request for Information
ML24249A1602024-09-0505 September 2024
Information Request to Support Upcoming Material Control and Accounting Inspection at Davis-Besse Nuclear Power Station
ML24204A0012024-07-17017 July 2024
NRR E-mail Capture - Request for Additional Information Vistraops Fleet Exemption for the Requirements in 10 CFR 50.71 Pertaining to the Submittal of Updated Final Safety Analysis Reports
ML24142A3532024-05-21021 May 2024
Station—Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection
ML24089A2582024-04-0101 April 2024
Request for Information for the NRC Quuadrennial Comprehensive Engineering Team Inspection: Inspection Report 05000346/2024010
ML23338A3172023-12-0606 December 2023
Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000346/2024001
ML23193A7842023-07-13013 July 2023
Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000346/2023402
ML23131A2732023-05-15015 May 2023
Notification of NRC Supplemental Inspection 95001 and Request for Information
ML23033A0322023-02-0101 February 2023
NRR E-mail Capture - Request for Additional Information for Davis-Besse's 2022 Steam Generator Inspection Report (L-2022-LRO-0115)
ML22357A0302022-12-23023 December 2022
Request for Information for NRC Commercial Grade Dedication Inspection: Inspection Report 05000346/2023010
ML22266A1102022-09-23023 September 2022
NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding July 21, 2022, Request for Withholding Information from Public Disclosure
ML22214A7042022-08-0202 August 2022
Reissue - Davis-Besse Nuclear Power Station, Unit 1 Notification of Nrc Fire Protection Team Inspection Request for Information: Inspection Report 05000346/2022011
ML22187A0992022-07-0606 July 2022
Notification of NRC Supplemental Inspection (95001) and Request for Information
ML22164A8572022-06-13013 June 2022
NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request to Revise the Emergency Plan
ML22118A6862022-04-28028 April 2022
NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding Alternative to Extend the Steam Generator Weld Inspection Interval
ML22112A1092022-04-22022 April 2022
NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request to Revise the Design Basis for the Shield Building
ML22055A0872022-02-23023 February 2022
NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding Relief Request RP-3
IR 05000346/20210912021-12-17017 December 2021
NRC Inspection Report (05000346/2021091) Preliminary Greater than Green Finding
ML21321A3792021-11-16016 November 2021
NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding Alternative to Extend the Steam Generator Weld Inspection Interval
ML21301A0992021-10-28028 October 2021
Draft Request for Additional Information: Proposed Alternate for Examination of Steam Generator Welds - Energy Harbor Nuclear Corp., Davis-Besse Nuclear Power Station, Unit No. 1
ML21203A3252021-07-28028 July 2021
Request for Information for an NRC Triennial Baseline Design Bases Assurance Inspection (Team): Inspection Report 05000346/2021011
ML21155A1952021-06-0404 June 2021
Information Request to Support Upcoming Problem Identification and Resolution (Pi&R) Inspection at Davis Besse Nuclear Power Station
ML21041A5452021-02-10010 February 2021
NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding Steam Generator Tube Inspection Reports
ML21007A3732021-01-0707 January 2021
NRR E-mail Capture - (External_Sender) (External) Request for Additional Information Regarding License Amendment Request to Incorporate the Applicable Standard Technical Specification 5.2.2, Unit Staff,
ML21004A1442020-12-30030 December 2020
NRR E-mail Capture - Request for Additional Information Regarding License Amendment Request to Incorporate the Applicable Standard Technical Specification 5.2.2, Unit Staff
ML20300A5592020-10-27027 October 2020
Notification of an NRC Biennial Licensed Operator Requalification Program Inspection and Request for Information
ML20154K7642020-06-0202 June 2020
NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request to Adopt TSTF-425
ML20133J9792020-05-14014 May 2020
Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection
ML20127H8672020-05-0606 May 2020
NRR E-mail Capture - Beaver Valley, Davis-Besse, and Perry - Request for Additional Information Regarding Request for Exemptions from Part 73 Security Requalification Requirements
ML20021A3162020-01-21021 January 2020
NRR E-mail Capture - Davis-Besse Nuclear Power Station - Request for Additional Information Regarding License Amendment Request to Revise Containment Leakage Rate Testing
ML19192A2222019-07-18018 July 2019
Request for Additional Information Regarding Application for Order Consenting to Transfer of Licenses and Conforming License Amendments
ML19179A1382019-06-28028 June 2019
NRR E-mail Capture - Davis-Besse - Request for Additional Information Regarding the Decommissioning Quality Assurance Program
ML19164A1532019-06-13013 June 2019
NRR E-mail Capture - Davis-Besse Nuclear Power Station - Request for Additional Information Regarding License Amendment Request for Post-Shutdown Emergency Plan
ML19162A3922019-06-11011 June 2019
NRR E-mail Capture - Davis-Besse Nuclear Power Station - Request for Additional Information Regarding License Amendment Request for Permanently Defueled Technical Specifications
ML19143A0732019-05-29029 May 2019
FENOC Fleet - Beaver Valley, Units 1 and 2; Davis-Besse, Unit 1, Perry, Unit 1 - Supplemental Information Needed for Acceptance of Requested Licensing Action; Application for Order Consenting to License Transfer and Conforming Amendments
ML18305B0192018-11-0101 November 2018
18 Davis-Besse Nuclear Power Station - Notification of an NRC Biennial Licensed Operator Requalification Program Inspection and Request for Information(Rdb)
ML18201A4122018-07-19019 July 2018
NRR E-mail Capture - Davis-Besse - Request for Additional Information Regarding License Amendment Request to Adopt NFPA 805
ML18190A4902018-07-0909 July 2018
Request for Information for an NRC Triennial Baseline Design Bases Assurance Inspection (Team), Inspection Report 05000346/2018011 (DRP-DXB)
ML18102B0852018-04-12012 April 2018
NRR E-mail Capture - Follow-up Request for Additional Information (RAI) FENOC FLEET-- Exemption Request for a Physical Barrier Requirement for Beaver
ML18043A0102018-02-0909 February 2018
NRR E-mail Capture - FENOC--MG0010-MG0011, MG-0012, MG0013-- Request for Additional Information (RAI) - Exemption Request Security Barrier in Physical Plans
ML17355A3722017-12-21021 December 2017
NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request to Adopt NFPA 805
ML17303B1582017-11-0707 November 2017
FENOC-Beaver Valley Power Station, Units 1 and 2, Davis-Besse Nuclear Power Station, Unit 1, Perry Nuclear Power Plant Unit 1 - Generic Letter 2016-01, Request for Supplemental Information
ML17257A1402017-09-14014 September 2017
NRR E-mail Capture - Davis-Besse Nuclear Power Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request to Adopt NFPA 805
ML17135A3612017-05-12012 May 2017
Information Request for NRC Triennial Evaluations of Changes, Tests, and Experiments (50.59) Baseline Inspection 05000346/2017010 (Jvb)
ML17129A4112017-05-0909 May 2017
Request for Additional Information Regarding Evaluation Submitted in Response to License Renewal Commitment No. 54
ML17100A1732017-04-19019 April 2017
Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Associated Standard 805
ML16364A2792017-01-23023 January 2017
Request for Additional Information Regarding License Renewal Commitment No. 42
ML16355A0352016-12-19019 December 2016
Ltr 12/19/16 Davis-Besse Nuclear Power Station, Unit 1 - Information Request for an NRC Post-Approval Site Inspection for License Renewal 05000346/2017009 (Bxj)
ML16256A0662016-10-18018 October 2016
Request for Additional Information Regarding License Amendment Request to Adopt National Fire Protection Associated Standard 805
2024-09-05
[Table view] |
Text
Davis-Besse NRC Request for Additional Information (RAI)
RAI # 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 licensees particular design. This is to ensure regulatory stability by enforcing the expectation that licensees adhere to NRC reviewed GENERIC and endorsed guidance with no non-design related deviations and little to no differences. While the NRC is not proposing verbatim compliance with the endorsed guidance, where applicable, the NRC will be pointing out areas where we expect compliance with the endorsed guidance. This is primarily based upon industry and NRC experience with issues related to the particular EAL.
- 1. Explain why you deviated from the endorsed guidance by not including a definition for extortion, sabotage, or security condition, or incorporate 1 DEFINITIONS the definitions as expected.
- 2. The site definition of large aircraft is considered potential official use only (OUO) by the NRC and is not to be incorporated into the EAL scheme.
It is expected that the EAL related to ISFSI be incorporated using a separate numbering convention. The endorsed guidance uses E-HU1, but EU1 has 2 ISFSI, HU6 been found acceptable at other utilities. Please explain why this deviation is necessary.
ST PAGE 5, 1 This is a deviation from endorsed guidance. Please explain why this deviation 3
PARAGRAPH is necessary or follow endorsed guidance.
FISSION 4 Does your site use Critical Function Status Trees?
BARRIER FUEL CLAD, Please explain why low level AND high temperatures are needed for this 5 POTENTIAL barrier? As high temperature is already considered in the FB matrix, this LOSS appears redundant and unnecessary.
RG1, RS1, RA1, RU1, HU4, SS1, SA1, SU1, Add the timing notes from the endorsed guidance or explain their omission.
SS2, SS4, These were added due to the numerous issues related to licensees 6 SA4, SU4, understanding the NRCs expectations related to the timeliness of EAL CA1, CU1, declarations.
CU2, CG7, CS7, CA7, CU7, CU8, CU10 Please explain how you will address CDE Thyroid for adults.
7 RG1, RS1 This question was answered via telecon between NSIR reviewer D.Johnson and Davis-Besse licensing, dated 10/15/2008 using actual meteorology in the IC is a deviation from the endorsed 8 RS1 guidance. Please explain the deviation or follow the endorsed guidance.
Page 1
Davis-Besse NRC Request for Additional Information (RAI)
RAI # EAL Question Please explain how EAL decision-makers will be able to differentiate between 9 RA1 top of scale as an EAL entry condition versus failed instrumentation.
You included site specific information as to why CAS is on the list but did not mention that maintaining access through site doors and security barriers is the 10 RA3 basis for CAS being on this list. This may lead to misconceptions as to the intent of the EAL. Please explain why this was not incorporated or revise to reflect the above information.
Please explain why you deviated from endorsed guidance and added potentially official use only information to the EAL by stating large aircraft 11 HA1 instead of airliner. While the term does not create a potential OUO issue directly in the EAL, its use led to it being defined, which leads to the potential OUO.
The term security condition was developed by a joint EP-Security industry team to better align EALs with the upcoming revision to site security 12 HU1 contingency plans via a revision to NEI 03-12. This term is important to this needed alignment. Please explain the deviation or revise to follow endorsed guidance.
HA3, HU3, Please explain why your diesel generator room(s) are not considered a safe 13 HA4, HU4 shutdown vital area.
You stated For the purposes of declaring an emergency event, the term extinguished means no visible flames. Explain why excessive smoke or 14 HU4 other indications of a possible fire are not included as a discriminator for defining when a fire is extinguished.
15 SA1, SA3 Please explain the deviation in the IC or revise accordingly.
Please elaborate as to what controls area means. Is this synonymous with 16 SS3 the reactor control console?
Please explain the deviation of not adding the expected EAL 1b or add 17 SA3 accordingly.
The expectation for the logic is an or or either. Please elaborate on why SS4, SA4, 18 consideration must be given to endorse a new EAL scheme or revise SU4 accordingly.
Page 2
