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| {{Adams | | {{Adams |
| | number = ML18212A229 | | | number = ML18212A227 |
| | issue date = 07/26/2018 | | | issue date = 07/26/2018 |
| | title = Response to Request for Additional Information Regarding License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. (Pa | | | title = Response to Request for Additional Information Regarding License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. (Pa |
| | author name = | | | author name = Curtland D |
| | author affiliation = NextEra Energy Duane Arnold, LLC | | | author affiliation = NextEra Energy Duane Arnold, LLC |
| | addressee name = | | | addressee name = |
| | addressee affiliation = NRC/NRO | | | addressee affiliation = NRC/Document Control Desk, NRC/NRO |
| | docket = 05000331 | | | docket = 05000331 |
| | license number = DPR-049 | | | license number = DPR-049 |
| | contact person = | | | contact person = |
| | case reference number = NG-18-0090 | | | case reference number = NG-18-0090 |
| | document type = Response to Request for Additional Information (RAI) | | | document type = Letter type:NG, Response to Request for Additional Information (RAI) |
| | page count = 187 | | | page count = 13 |
| }} | | }} |
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| =Text= | | =Text= |
| {{#Wiki_filter:ATTACHMENT 1 NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATING TO LICENSE AMENDMENT REQUEST TSCR-166 UPDATED REDLINE MARKUP OF NEI 99-01 REVISION 6 311 pages follow NEI 99*0 1 [Revision | | {{#Wiki_filter:NEXTeraM ENERGY~ DUANE ARNOLD July 26, 2018 NG-18-0090 10 CFR 50.90 10 CFR 50, Appendix E U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Duane Arnold Energy Center Docket No. 50-331 Renewed Facility Operating License No. DPR-49 Response to Request for Additional Information Regarding License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors" |
| &] , lepment of Deve
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| * Levels Emergency Action fer on-N Passive Reactors November 2012
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| [THIS PA.GE IS LEFT BL1i\NK INTENTIONA.LLY]
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| NEI 99 01 [Revision
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| &] Nuclear Energy Institute Duane Arnold Energy Center (DAEC) Emergency Action Levels Technical Bases Document TBD,2018 November 2012 Nue.'-ear Energy Institute , I 77G I Street N W , &.*ite 4()(), Washingten D. C. (2Q2. 739.8()()0)
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| ACKNOWLEDGMENTS This document 1 Nas prepared by the Nuclear Energy Institute (l'J:EI) Emergency Action Level (EAL) Task Foree. NEI Chairpersen:
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| David Young Preparatien Team Larry Baker E>celon Nuelear/Corporate Craig Banner PSEG Nuclear/Salem and Hope Creek Nuelear Generating Stations/US,A, John Egdorf Dominion Generation/Ke 1.vaunee Power Station Jade Lewis Entergy Nuelear/Corporate C. Kelly Walker Operations Support Ser11ices , Inc. Review Team Chris Boone Southern Nuelear/Corporate John Callahan Xcel Energ)s'Corporate/USA Bill Chausse Enereon Services , Inc. Kent Crocker Progress Energy/Brunswick
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| }foclear Plant Don Crowl Duke Energy/Corporate Roger Freeman Constellation Energy Nuclear Group/Corporate Walt Lee TVA Nuclear/Corporate Ken Meade FENOC/Corporate Don Mathena }l"e)ctEra Energy/Corporate David Stobaugh EP Consulting , LLC }tick Turner Cal !away Plant/STARS Maureen Za1,valick Diab lo Canyon Power Plant/STARS NOTICE Neither NEI , nor any of its employees , members , supporting organizations , contractors , or consultants make any warranty , expressed or implied , or assume any legal responsibility for the accuracy or completeness of , or assume any liability for damages resulting from any use of , any information apparatus , methods , or process disclosed in this report or that such may not infringe privately 01,vned rights. N u e l-ee1r Ener gy In st itute , J 77 6 J Slreet A'. W , Sti'ite 4{)(), W*1Shingten D. C. (2()2. 739.8()()Q)
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| EXECUTl\fE
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|
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|
| ==SUMMARY==
| | ==References:== |
| Jl>ffil 99 0 I (Re;*isioA 6) November 2012 Federal regulations require that a nuclear pov,1er plant operator develop a scheme for the classification of emergenC)' events and conditions.
| | : 1. NextEra Energy Duane Arnold, LLC letter NG-17-0235, License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non- |
| This scheme is a fundamental component of an emergency plan in that it provides the defined thresholds that *will allow site personnel to rapidly implement a range of pre planned emergency response measures.
| |
| An emergency classification scheme also facilitates timely decision making by an Offsite Response Organization (ORO) concerning the implementation of precautionary or protective actions for the public. The purpose of Nuclear E nergy Institute (NEI) 99 01 is to provide guidance to nuclear power plant operators for the development of a site specific emergency classification scheme. The methodology described in this document is consistent with Federal regulations , and related US : Nuclear Regulatory Commission (NRG) requirements and guidance.
| |
| In particular , this methodology has been endorsed by the NRG as an acceptable approach to meeting the requirements of 10 CFR § 50.47(b)(4), related sections of 10 CFR § 50 , Appendix E , and the associated planning standard evaluation elements of}nJREG 0654/ FEMA REP 1 , Rev. 1 , Criteri*l for PrcpBr*ltien mui E?*l!u*ltien
| |
| &jRBmelegie8l Emergeney Respen s e P !*ins mui: Prcp8redness in Suppert f>jNuele*lr Pewer Pl*ll9ts , November 1980. NEI 99 01 contains a set of generic Initiating Conditions (ICs), Emergency Action Levels (EALs) and fission product barrier status thresholds.
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| It also includes supporting technical basis information , developer notes and recommended classification instructions for users. Users should implement ICs , EALs and thresholds that are as close as possible to the generic material presented in this document with allowance for changes necessary to address site specific considerations such as plant design , location , terminology , etc. Properly implemented , the guidance in JI.JEI 99 01 will yield a site specific emergency classification scheme 1 Nith clearly defined and r e adily observable EALs and thresholds.
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| Other benefits include the development of a sound basis document , the adoption of industry standard instructions for emergency classification (e.g., transient events , classification of multiple events , upgrading , downgrading , etc.), and incorporation of features to improve human performance.
| |
| An emergency classification using this scheme will be appropriate to the risk posed to plant workers and the public , and should be the same as that made by another NEI 99 01 user plant in response to a similar event. The individuals responsible for developing an emergency classification scheme are strongly encouraged to review all applicable NRG requirements and guidance prior to beginning their efforts. Questions concerning this document may be directed to the NEI Emergency Preparedness staff , NEI EAL task force members or submitted to the Emergency Preparedness Frequently Asked Questions process. Finally , unique State and local requirements associated with an emergency classification scheme are not reflected in this guidance.
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| Incorporation of these requirements may be performed on a case by case basis in conjunction with the appropriate ORO agency. Any such changes will require a review under the applicable sections of 10 CFR 50.
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| },JEJ 99 g 1 (Re¥isioA a) },foyember 2912 [THIS PAGE IS LEFT BLANK INTENTIONA.LLY]
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| ll TABLE OF CONTENTS NEI 99 0 l (Re*,*isioA e) l>Jo>,*emeer 2012 EXECUTIJJE
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| | |
| ==SUMMARY==
| |
| ........................................................................................................
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| i 1 BASIS FOR EMERGENCY ACTION LEVELS .................................................................
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| 1 1.1 OPERATING REACTORS ****.******....**.......*...*.*.......*****..*.***....****.***.***..*.***...*.*.*.*....****.******
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| 1 1.2 INDEPENDENT SPENT FUEL STORAGE INSTALLATION
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| {ISFSI) .....................................
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| 2 1.3 NRC ORDER EA-12-051
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| ******************************
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| *********************************
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| *********************************
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| 4 2 KEY TERMINOLOGY USED IN DAEC EAL SCHEME .......................................
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Category:Letter type:NG
MONTHYEARNG-23-0010, Supplement to Duane Arnold Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule2023-12-0606 December 2023 Supplement to Duane Arnold Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule NG-23-0009, Part 73 Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule2023-11-16016 November 2023 Part 73 Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule NG-23-0006, Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update2023-05-23023 May 2023 Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update NG-23-0004, 2022 Annual Radioactive Material Release Report2023-04-25025 April 2023 2022 Annual Radioactive Material Release Report NG-23-0003, 2022 Annual Exposure Report - Form 5s2023-04-21021 April 2023 2022 Annual Exposure Report - Form 5s NG-23-0002, 10 CFR 50.59 Report, Commitment Changes, 10 CFR 72.48 Report, Quality Assurance Program Changes, Technical Specification Basis Changes, and Revision of the DAEC Defueled Safety Analysis Report2023-03-27027 March 2023 10 CFR 50.59 Report, Commitment Changes, 10 CFR 72.48 Report, Quality Assurance Program Changes, Technical Specification Basis Changes, and Revision of the DAEC Defueled Safety Analysis Report NG-23-0001, 2023 Annual Decommissioning and Spent Fuel Management Funding Status Report2023-03-27027 March 2023 2023 Annual Decommissioning and Spent Fuel Management Funding Status Report NG-22-0055, Revision to Duane Arnold Energy Center (DAEC) ISFSI-Only Emergency Plan2022-05-20020 May 2022 Revision to Duane Arnold Energy Center (DAEC) ISFSI-Only Emergency Plan NG-22-0053, 2021 Annual Radiological Environmental Operating Report2022-05-0606 May 2022 2021 Annual Radiological Environmental Operating Report NG-22-0052, Regulatory Issue Summary 2000-11. NRC Emergency Telecommunications System, Statement of Intent to Implement the Proposed Voluntary Initiative2022-05-0404 May 2022 Regulatory Issue Summary 2000-11. NRC Emergency Telecommunications System, Statement of Intent to Implement the Proposed Voluntary Initiative NG-22-0050, Revised Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program, Revision 02022-04-26026 April 2022 Revised Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program, Revision 0 NG-22-0049, 2021 Annual Radioactive Material Release Report2022-04-26026 April 2022 2021 Annual Radioactive Material Release Report NG-22-0035, Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program. Revision 02022-04-13013 April 2022 Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program. Revision 0 NG-22-0047, Registration of Independent Spent Fuel Installation Storage Cask and Notification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool2022-04-11011 April 2022 Registration of Independent Spent Fuel Installation Storage Cask and Notification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool NG-22-0042, Registration of Independent Spent Fuel Installation Storage Casks2022-04-0808 April 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0041, and Independent Spent Fuel Storage Installation, 2022 Annual Decommissioning and Spent Fuel Management Funding Status Report2022-03-31031 March 2022 and Independent Spent Fuel Storage Installation, 2022 Annual Decommissioning and Spent Fuel Management Funding Status Report NG-22-0031, 2021 Annual Exposure Report - Form 5s2022-03-23023 March 2022 2021 Annual Exposure Report - Form 5s NG-22-0030, Registration of Independent Spent Fuel Installation Storage Casks2022-03-23023 March 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0025, Registration of Independent Spent Fuel Installation Storage Casks2022-03-0808 March 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0021, Registration of Independent Spent Fuel Installation Storage Casks2022-02-24024 February 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0014, Registration of Independent Spent Fuel Installation Storage Casks2022-02-10010 February 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0009, Registration of Independent Spent Fuel Installation Storage Casks2022-01-20020 January 2022 Registration of Independent Spent Fuel Installation Storage Casks NG-22-0001, Supplement to Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61BTH Type 2 Dry Shielded Canister2022-01-0606 January 2022 Supplement to Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61BTH Type 2 Dry Shielded Canister NG-21-0038, Registration of Independent Spent Fuel Installation Storage Casks2021-12-22022 December 2021 Registration of Independent Spent Fuel Installation Storage Casks NG-21-0035, Supplement to Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61 Bth Type 2 Dry Shielded Canister2021-12-10010 December 2021 Supplement to Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61 Bth Type 2 Dry Shielded Canister NG-21-0030, Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61 Bth Type 2 Dry Shielded Canister2021-10-21021 October 2021 Exemption Request for Failed Fuel Can Weight in a Certificate of Compliance 1004 Renewed Amendment 17 61 Bth Type 2 Dry Shielded Canister NG-21-0028, Request for Approval of NextEra Energy Duane Arnold, Llc'S Decommissioning Quality Assurance Program Revision 02021-07-30030 July 2021 Request for Approval of NextEra Energy Duane Arnold, Llc'S Decommissioning Quality Assurance Program Revision 0 NG-21-0010, License Amendment Request (TSCR-192): Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme2021-06-28028 June 2021 License Amendment Request (TSCR-192): Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme NG-21-0026, CFR 72.48 Report of Changes. Tests. and Experiments2021-06-16016 June 2021 CFR 72.48 Report of Changes. Tests. and Experiments NG-21-0011, Submittal of 2020 Annual Radiological Environmental Operating Report2021-05-0404 May 2021 Submittal of 2020 Annual Radiological Environmental Operating Report NG-21-0009, Report of Facility Changes. Tests and Experiments. and Commitment Changes2021-04-27027 April 2021 Report of Facility Changes. Tests and Experiments. and Commitment Changes NG-21-0021, Supplement to License Amendment Request (TSCR-185): Application to Revise Operating License to Remove Cyber Security Plan Requirements2021-04-22022 April 2021 Supplement to License Amendment Request (TSCR-185): Application to Revise Operating License to Remove Cyber Security Plan Requirements NG-21-0006, 2021 Annual Decommissioning and Spent Fuel Management Funding Status Report2021-03-31031 March 2021 2021 Annual Decommissioning and Spent Fuel Management Funding Status Report NG-21-0005, NextEra Energy Duane Arnold, LLC - Transmittal of the DAEC Defueled Safety Analysis Report Revision 02021-03-29029 March 2021 NextEra Energy Duane Arnold, LLC - Transmittal of the DAEC Defueled Safety Analysis Report Revision 0 NG-20-0094, License Amendment Request (TSCR-189): Revision to Facility License and Technical Specifications to Reflect Permanent Removal of Spent Fuel from the Spent Fuel Pool2021-02-19019 February 2021 License Amendment Request (TSCR-189): Revision to Facility License and Technical Specifications to Reflect Permanent Removal of Spent Fuel from the Spent Fuel Pool NG-21-0004, Response to Request for Additional Information Related to Post Shutdown Decommissioning Activities Report2021-02-0505 February 2021 Response to Request for Additional Information Related to Post Shutdown Decommissioning Activities Report NG-20-0078, Update to Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb)2021-01-13013 January 2021 Update to Spent Fuel Management Plan Pursuant to 10 CFR 50.54(bb) NG-20-0101, Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(1)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to COVID-19 Pandemic2020-12-29029 December 2020 Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(1)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to COVID-19 Pandemic NG-20-0099, Response to Request for Additional Information Relating to License Amendment Request (TSCR-187): Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme2020-12-0101 December 2020 Response to Request for Additional Information Relating to License Amendment Request (TSCR-187): Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme NG-20-0093, Supplement to License Amendment Request (TSCR-187): Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme2020-10-29029 October 2020 Supplement to License Amendment Request (TSCR-187): Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme NG-20-0090, Certification of Permanent Removal of Fuel from the Reactor Vessel for Duane Arnold Energy Center2020-10-12012 October 2020 Certification of Permanent Removal of Fuel from the Reactor Vessel for Duane Arnold Energy Center NG-20-0083, Registration of Independent Spent Fuel Installation Storage Casks2020-10-12012 October 2020 Registration of Independent Spent Fuel Installation Storage Casks NG-20-0069, Response to Request for Additional Information Relating to Request for Exemption from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E2020-10-0707 October 2020 Response to Request for Additional Information Relating to Request for Exemption from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E NG-20-0082, Registration of Independent Spent Fuel Installation Storage Casks2020-09-28028 September 2020 Registration of Independent Spent Fuel Installation Storage Casks NG-20-0071, Request for One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Evaluated Exercise Requirements Due to COVID-19 Pandemic2020-09-22022 September 2020 Request for One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Evaluated Exercise Requirements Due to COVID-19 Pandemic NG-20-0077, Registration of Independent Spent Fuel Installation Storage Casks2020-09-10010 September 2020 Registration of Independent Spent Fuel Installation Storage Casks NG-20-0073, Notice Regarding Proposed Amendment to Decommissioning Trust Agreements2020-09-0101 September 2020 Notice Regarding Proposed Amendment to Decommissioning Trust Agreements NG-20-0074, Certification of Permanent Cessation of Power Operations2020-08-27027 August 2020 Certification of Permanent Cessation of Power Operations NG-20-0067, Registration of Independent Spent Fuel Installation Storage Casks2020-08-12012 August 2020 Registration of Independent Spent Fuel Installation Storage Casks NG-20-0035, Request for Exemption from 10 CFR 50.54(w)(1)2020-07-16016 July 2020 Request for Exemption from 10 CFR 50.54(w)(1) 2023-05-23
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARNG-22-0050, Revised Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program, Revision 02022-04-26026 April 2022 Revised Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program, Revision 0 NG-22-0035, Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program. Revision 02022-04-13013 April 2022 Response to Request for Additional Information Relating to Decommissioning Quality Assurance Program. Revision 0 NG-21-0004, Response to Request for Additional Information Related to Post Shutdown Decommissioning Activities Report2021-02-0505 February 2021 Response to Request for Additional Information Related to Post Shutdown Decommissioning Activities Report NG-20-0099, Response to Request for Additional Information Relating to License Amendment Request (TSCR-187): Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme2020-12-0101 December 2020 Response to Request for Additional Information Relating to License Amendment Request (TSCR-187): Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme NG-20-0069, Response to Request for Additional Information Relating to Request for Exemption from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E2020-10-0707 October 2020 Response to Request for Additional Information Relating to Request for Exemption from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E NG-20-0050, Response to Request for Additional Information - NextEra Energy Duane Arnold, LLC Quality Assurance Topical Report (FPL-3)2020-06-26026 June 2020 Response to Request for Additional Information - NextEra Energy Duane Arnold, LLC Quality Assurance Topical Report (FPL-3) NG-20-0045, Response to Request for Additional Information (RAI) - Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1 )(Iv)2020-05-29029 May 2020 Response to Request for Additional Information (RAI) - Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1 )(Iv) NG-20-0042, Response to Request for Additional Information Regarding Exemption Request for Security Training Requirements Due to COVID-19 Pandemic2020-05-20020 May 2020 Response to Request for Additional Information Regarding Exemption Request for Security Training Requirements Due to COVID-19 Pandemic ML20016A2752020-01-13013 January 2020 Letter to NRC (1-13-20) FEMA Review of RAI Responses Pertaining to DAEC Emergency Plan to Address the Permanently Shutdown Condition NG-19-0124, Response to Request for Additional Information Relating to Proposed Changes to the Emergency Plan for Permanently Defueled Condition2019-10-28028 October 2019 Response to Request for Additional Information Relating to Proposed Changes to the Emergency Plan for Permanently Defueled Condition NG-19-0071, Response to Request for Additional Information Regarding Request for Approval of Certified Fuel Handler Training Program2019-05-30030 May 2019 Response to Request for Additional Information Regarding Request for Approval of Certified Fuel Handler Training Program NG-18-0121, Response to Second Round - Request for Additional Information (RAI) - Duane Arnold Energy Center (DAEC) - LAR TSCR-166, Adoption of EAL Scheme Pursuant to NEI 99-012018-10-18018 October 2018 Response to Second Round - Request for Additional Information (RAI) - Duane Arnold Energy Center (DAEC) - LAR TSCR-166, Adoption of EAL Scheme Pursuant to NEI 99-01 ML18212A2272018-07-26026 July 2018 Response to Request for Additional Information Regarding License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. (Pa ML18212A2292018-07-26026 July 2018 Response to Request for Additional Information Regarding License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. (Pa ML18212A2312018-07-26026 July 2018 Response to Request for Additional Information Regarding License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. (Pa ML18212A2322018-07-26026 July 2018 Response to Request for Additional Information Regarding License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. (Pa NG-18-0090, Response to Request for Additional Information Regarding License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. (2018-07-26026 July 2018 Response to Request for Additional Information Regarding License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. (Pa NG-18-0068, Supplemental Response to Request for Additional Information, Fifth Lnservice Inspection Interval Program Plan, Relief Request RR-052018-06-0505 June 2018 Supplemental Response to Request for Additional Information, Fifth Lnservice Inspection Interval Program Plan, Relief Request RR-05 NG-18-0046, Response to Request for Additional Information, Fifth Inservice Inspection Interval Program Plan, Relief Request RR-052018-04-27027 April 2018 Response to Request for Additional Information, Fifth Inservice Inspection Interval Program Plan, Relief Request RR-05 L-2018-068, Florida Power and Light Co. - Response to Request for Additional Information Re Decommissioning Funding Plan Updates for Independent Spent Fuel Storage Installations2018-04-0303 April 2018 Florida Power and Light Co. - Response to Request for Additional Information Re Decommissioning Funding Plan Updates for Independent Spent Fuel Storage Installations NG-18-0024, Response to Request for Additional Information Regarding License Amendment Request (TSCR-170), Revision to Technical Specification 3.5.1, EGGS-Operating2018-03-0101 March 2018 Response to Request for Additional Information Regarding License Amendment Request (TSCR-170), Revision to Technical Specification 3.5.1, EGGS-Operating NG-18-0013, Response to Second Request for Additional Information, Fifth Inservice Inspection Lnterval Program Plan, Relief Request RR-032018-01-26026 January 2018 Response to Second Request for Additional Information, Fifth Inservice Inspection Lnterval Program Plan, Relief Request RR-03 NG-17-0241, Supplemental Response to Request for Additional Information, Fifth Inservice Inspection Interval Program Plan, Relief Request RR-032017-12-0707 December 2017 Supplemental Response to Request for Additional Information, Fifth Inservice Inspection Interval Program Plan, Relief Request RR-03 NG-17-0207, Response to Request for Additional Information Regarding License Amendment Request (TSCR-168), Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control.2017-11-0101 November 2017 Response to Request for Additional Information Regarding License Amendment Request (TSCR-168), Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control. NG-17-0180, Response to Request for Additional Information, Fifth Lnservice Inspection Interval Program Plan, Relief Request RR-042017-09-12012 September 2017 Response to Request for Additional Information, Fifth Lnservice Inspection Interval Program Plan, Relief Request RR-04 NG-17-0177, Response to Request for Additional Information, Fifth Lnservice Inspection Interval Program Plan, Relief Request RR-012017-09-0505 September 2017 Response to Request for Additional Information, Fifth Lnservice Inspection Interval Program Plan, Relief Request RR-01 NG-17-0117, Revision to Request for Additional Information Relating to Revision to Staff Augmentation Times in the Duane Arnold Energy Center Emergency Plan2017-06-19019 June 2017 Revision to Request for Additional Information Relating to Revision to Staff Augmentation Times in the Duane Arnold Energy Center Emergency Plan NG-17-0077, Response to Request for Additional Information Relating to Revision to Staff Augmentation Times in the Duane Arnold Energy Center Emergency Plan2017-04-0707 April 2017 Response to Request for Additional Information Relating to Revision to Staff Augmentation Times in the Duane Arnold Energy Center Emergency Plan L-2016-188, Response to Generic Letter 2016-01, Monitoring of Neutron Absorbing Materials in Spent Fuel Pools, Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)2016-11-0303 November 2016 Response to Generic Letter 2016-01, Monitoring of Neutron Absorbing Materials in Spent Fuel Pools, Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) ML16267A4392016-09-23023 September 2016 Request for Information Letter 9/23/16 (LAS) NG-16-0180, Response to Request for Additional Information, License Amendment Request (TSCR-159) to Revise Technical Specifications Fuel Storage-Requirements - MF74862016-09-21021 September 2016 Response to Request for Additional Information, License Amendment Request (TSCR-159) to Revise Technical Specifications Fuel Storage-Requirements - MF7486 NG-16-0178, Response to Request for Additional Information Relating to Beyond Design Based External Event Staffing Study2016-09-15015 September 2016 Response to Request for Additional Information Relating to Beyond Design Based External Event Staffing Study NG-16-0153, Response to Request for Information Supporting Flooding Hazards Reevaluation Report Audit2016-08-12012 August 2016 Response to Request for Information Supporting Flooding Hazards Reevaluation Report Audit NG-16-0118, Supplemental Response to Request for Additional Information; License Amendment Request (TSCR-143) to Extend Containment Leakage Test Frequency2016-05-31031 May 2016 Supplemental Response to Request for Additional Information; License Amendment Request (TSCR-143) to Extend Containment Leakage Test Frequency NG-16-0076, Response to Request for Additional Information. License Amendment Request (TSCR-143) to Extend Containment Leakage Test Frequency2016-04-14014 April 2016 Response to Request for Additional Information. License Amendment Request (TSCR-143) to Extend Containment Leakage Test Frequency NG-16-0080, Response to Request for Additional Information, License Amendment Request (TSCR-153) to Reduce the Reactor Steam Dome Pressure Specified in the Reactor Core Safety Limits2016-04-12012 April 2016 Response to Request for Additional Information, License Amendment Request (TSCR-153) to Reduce the Reactor Steam Dome Pressure Specified in the Reactor Core Safety Limits NG-16-0055, Resubmittal of Affidavit Submitted with Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report - MF66172016-03-11011 March 2016 Resubmittal of Affidavit Submitted with Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report - MF6617 ML16055A1262016-02-19019 February 2016 Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report - MF6617 NG-16-0042, Duane Arnold - Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report - MF66172016-02-19019 February 2016 Duane Arnold - Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report - MF6617 NG-16-0029, Response to Request for Additional Information, License Amendment Request (TSCR-143) to Extend Containment Leakage Test Frequency2016-01-29029 January 2016 Response to Request for Additional Information, License Amendment Request (TSCR-143) to Extend Containment Leakage Test Frequency NG-15-0361, Six-Month Status Report and Phase 1 and 2 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions..2015-12-22022 December 2015 Six-Month Status Report and Phase 1 and 2 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions.. NG-15-0342, High Frequency Supplement to Seismic Hazard Screening Report, Response to NRC Request for Information, Per to 10CFR50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of: Insights from the Fukushima Dai-ichi Accident2015-12-15015 December 2015 High Frequency Supplement to Seismic Hazard Screening Report, Response to NRC Request for Information, Per to 10CFR50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of: Insights from the Fukushima Dai-ichi Accident NG-15-0248, Submittal of 10 CFR 72.48 Report of Changes, Tests, and Experiments2015-07-16016 July 2015 Submittal of 10 CFR 72.48 Report of Changes, Tests, and Experiments 2022-04-26
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NEXTeraM ENERGY~ DUANE ARNOLD July 26, 2018 NG-18-0090 10 CFR 50.90 10 CFR 50, Appendix E U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Duane Arnold Energy Center Docket No. 50-331 Renewed Facility Operating License No. DPR-49 Response to Request for Additional Information Regarding License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors"
References:
- 1. NextEra Energy Duane Arnold, LLC letter NG-17-0235, License Amendment Request (TSCR-166), Adoption of Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors" (ML17363A069)
- 2. NRC E-Mail: Draft request for additional information (RAI) -Duane Arnold Energy Center (DAEC) -LAR TSCR-166, Adoption of EAL Scheme Pursuant to NEI 99-01 -EPID L-2017-LLA-0420.
From Mahesh Chawla, NRC,June 15, 2018 In Reference 1, NextEra Energy Duane Arnold, LLC (NextEra) submitted a license amendment request (LAR) for Duane Arnold Energy Center (DAEC). The proposed change adopts an Emergency Action Level (EAL) scheme pursuant to NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors." In Reference 2, the NRC staff requested additional information to support its review of the LAR. The Enclosure to this letter provides NextEra's response to the request for additional information (RAI). The following information is provided as attachments to the Enclosure to aid NRC review and approval and replaces the Attachments in their entirety from Reference 1:
- Attachment 1 -Updated Redline Markup of NEI 99-01 Revision 6 ;4x4~
- Attachment 2 -Updated Clean Copy of the Proposed DAEC EAL Scheme
- Attachment 3 -Updated Deviations and Differences Matrix rJ((IL
- Attachment 4 -Updated Supporting Technical Information
- Attachment 5 -Updated DAEC EAL Scheme Wallboards NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324 This RAI response does not alter the conclusions in Reference 1 that the changes do not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the changes. No new or revised commitments are included in this letter. If you have any questions or require additional information, please contact J. Michael Davis, Licensing Manager, at 319-851-7032.
I declare under penalty of perjury that the foregoing is true and correct. Executed on July 26, 2018 Dean Curtland Site Director NextEra Energy Duane Arnold, LLC Enclosure cc: Regional Administrator, USNRC, Region III, Project Manager, USNRC, Duane Arnold Energy Center Resident Inspector, USNRC, Duane Arnold Energy Center A. Leek (State of Iowa) NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324 ENCLOSURE DUANE ARNOLD ENERGY CENTER NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 Request for Additional Information (RAI), June 15, 2018 EPID L-2017-LLA-0420.
10 pages follow plus Attachments Enclosure to NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-1 Section 4.4 of NE/ 99-01, Revision 6, states that alternative methods for presenting EAL scheme information may be developed for use provided that it contains all the information needed to make a correct emergency classification.
This information includes the Initiating Conditions, Operating Mode Applicability criteria, EALs, and Notes. DAEC provides a Hot Classification Matrix and a Cold Classification Matrix as alternative presentation methods. a. The DAEC EAL alternative method for presenting EAL scheme information does not include the notes as provided in the proposed EAL Technical Basis document.
This could lead to inaccurate or delayed emergency classifications.
Please revise the DAEC Hot and Cold Matrices to include the applicable notes as described in NE/ 99-01, Revision 6, or provide justification for omission.
- b. The DAEC EAL alternative method for presenting EAL scheme information is not consistent with the proposed EAL Technical Basis document.
This could lead to inaccurate or delayed emergency classifications.
A partial list of examples of inconsistencies are as follows: (NOTE: These items should not be considered a complete list of potential inconsistencies.)
- Fuel clad damage assessment corresponding to Containment Barrier Potential Loss 5A provides a value of 5% vice the value of 20% which is provided in the technical basis document.
- SA1.1 provides *~c power capability to 1A3 and 1A3" vice *~c power capability to 1 A3 and 1 A4 buses."
- Table E-1 Cask On Contact Dose Rates implies all readings should be taken On Contact vice three feet from the HSM [horizontal storage module].
- The tables used on the alternate method for presenting EAL scheme information have different layouts and titles than the technical basis document tables. In some cases, there is no corresponding technical basis document table. (see attached table of additional comments)
Please review the DAEC EAL alternative method for presenting EAL scheme information and ensure the method is technically accurate and addresses human factors issues that could impact timely and accurate EAL assessments.
DAEC Response DAEC has revised the wallcharts and Technical Basis Document for better consistency and prevention of EAL assessor confusion (consideration of human factors).
This revision addressed all the listed examples provided in the RAI, as well as other examples observed during a 100% comparison of the I Cs and EALs between the two documents.
The revised documents are provided in the updated versions of Attachments 1, 2, and 5 provided in this letter. 1 Enclosure to NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-2 On Page 17, the proposed DAEC Section 5. 1, "General Considerations," state: As used here, promptly" means at the first available opportunity (e.g., if the Shift Manager is receiving an update from the fire brigade at the 15 minute mark, it is expected that the declaration will occur as the next action after the call ends). The above statement could infer that it is acceptable for the Shift Manager to make the EAL declaration after the 15 minute mark, if the Shift Manager was on the phone or otherwise busy. Guidance in Section IV.H.8 to NSIR!DPR-ISG-01, "Emergency Staff Guidance for Nuclear Power Plants," provides that delays beyond 15 minutes could be . found compliant under the following conditions:
- The delay was caused by a licensee actively performing another action immediately needed to protect the public health and safety such that a delay in declaration qualitatively represents the lesser risk.
- The cause of the delay was not reasonably within the licensee's ability to foresee and prevent. Based on the NRG guidance cited above, unless the Shift Manager was performing actions immediately needed to protect public health and safety, it would be reasonable to expect him to obtain the required information needed to make a declaration within 15 minutes of the initiation of the event. Please explain how the Shift Manager/Emergency Director would not potentially infer that it is acceptable to make a declaration greater than 15 minutes from the initial detection of a fire, or revise accordingly to align with NRG guidance.
DAEC Response After further clarifying discussion with the NRC staff during a June 26, 2018 telephone call, DAEC now believes the guidance in Section IV.H.8 to NSIR/DPR-ISG-01 is best suited for use in EAL assessor training where the full context of the guidance can be considered.
Therefore, DAEC has removed the partial clarifying guidance supplied by Section IV.H.8 to NSIR/DPR-ISG-01 and returns proposed Section 5.1 to the wording provided in NEI 99-01 alone. The revised documents are provided in the updated versions of Attachments 1 and 2 provided in this letter. 2 Enclosure to* NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-3 The proposed DAEC EAL RA1.1, RS1.1, and RG1.1 have values for the Offgas Stack radiation monitor that were rounded from 4.45Exx to 4.5Exx and the Turbine Building ventilation radiation monitor setpoint was rounded from 1. 44Exx to 1. OExx. This could result in a difference of approximately 50% for the Turbine building ventilation radiation monitors.
The staff could not determine why apparently different rounding methodologies were used for the Offgas Stack and Turbine Building ventilation radiation monitors.
Please explain the basis used for the apparently different rounding methodologies or revise accordingly.
DAEC Response DAEC has reevaluated the averaging and rounding methodologies used in selection of these thresholds and agrees that too much emphasis was placed on creation of a stepped escalation progression from UE to GE. A more standard method of averaging and rounding has now been employed to determine these threshold values as shown in the revised Table R-1 below: Reactor Building ventilation rad monitor 1.lE+OO uci/cc 1.lE-01 uci/cc 1.lE-02 uci/cc 8.0E-04 uci/cc (Kaman 3/4, 5/6, 7/8) "' Turbine Building ventilation rad monitor 1.4E+OO uci/cc 1.4E-01 uci/cc 1.4E-02 uci/cc 8.0E-04 ucifcc :::, (Kaman 1/2) 0 Q) "' Offgas Stack rad monitor Ctl 4.SE+02 uci/cc 4.SE+Ol uci/cc 2.0E-01 ucifcc \9 (Kaman 9/10) 4.5E+03 uci/cc LLRPSF rad monitor 1.4E-Ol uci/cc 1.4E-02 uci/cc 1.2E-03 uci/cc (Kaman 12) GSW rad monitor 1.7E+04 cps 1.5E+03 cps (RIS-4767)
"'C :::, RHRSW & ESW rad monitor 1.2E+04 cps 8.4E+02 cps C" (RM-1997)
- RHRSW & ESW Rupture Disc rad monitor 1.8E+04 cps 1.0E+03 cps (RM-4268)
The revised threshold values are provided in the updated versions of Attachments 1, 2, 3, 4, and 5 provided in this letter. 3 Enclosure to NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-4 NE/ 99-01, Revision 6, EAL CU1 is intended to result in the declaration of a Notification of Unusual Event (Unusual Event) if there is an unplanned loss of reactor pressure vessel (RPV) inventory that results in a RPV level below a minimum operating level required by the governing procedure for greater than 15 minutes. DAEC proposes to use this threshold value only when RPV level is below the RPV flange. Please explain what unique DAEC conditions require this deviation from proposed guidance for CU1. 1 or revise accordingly.
DAEC Response After further clarifying discussion with the NRC staff during a June 26, 2018 telephone call, DAEC has reevaluated the proposed site-specific implementation of CU1 .1 and proposes to return to the standard language provided in NEI 99-01 of: "UNPLANNED loss of reactor coolant results in RPV level less than a required lower limit for 15 minutes or longer." The revised documents are provided in the updated versions of Attachments 1, 2, 3, and 5 provided in this letter. 4 Enclosure to NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-5 The proposed DAEC EALs CU4. SS2.1, and SG2.1.b use 105 VDC for the threshold value. However, the Developer's Notes for these threshold values provides at least a 15 minute margin for a minimum DC voltage. The DAEC basis for the threshold value states that the inverter has an auto trip at 105 VDC decreasing.
As such, this threshold value would provide no margin. Please explain why the DAEC threshold values for CU4 and SS2. 1 and SG2. 1.b were not developed above the inverter auto trip setpoint to allow for with a 15 minute margin, or revise accordingly.
DAEC Response Duane Arnold has two Class 1 E 125 VDC station batteries (1 D1 and 1 D2). The Class 1 E station batteries have a capacity of 1200 ampere-hours at an 8-hour discharge rate to 1. 75 V per cell. Bus voltage of 105 VDC decreasing was chosen as the SS2 and SG2 loss of Vital DC power threshold due to this value being operationally significant and easy for operators to recognize since the 125V DC SYSTEM 1 TROUBLE, 125V DC CHARGER 1D12 TROUBLE, and 125V DC CHARGER 1D120 TROUBLE annunciators (Div 1) or 125V DC SYSTEM 2 TROUBLE and 125V DC CHARGER 1 D22 TROUBLE annunciators (Div 2) will activate at this minimum system design voltage. Due to differences in bus loading, these Division 1 and Division 2 subsystems are not expected to reach the minimum bus voltage necessary for adequate operation of SAFETY SYSTEM equipment simultaneously.
Therefore, operator response to the loss of one 125 VDC bus would provide adequate (>15 minute) margin as provided by the EAL Developer Note to focus operator attention on the potential EAL threshold.
Additionally, operator follow-up actions are provided in Abnormal Operating Procedure AOP-302.1, LOSS OF 125 VDC POWER, to reference EPIP 1.1 for EAL assessment for conditions that would only occur once battery voltage reaches 105 VDC (see annunciators listed above). The revised source reference is provided iri the updated version of Attachment 4 provided in this letter. 5 Enclosure to NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-6 The proposed EALs CA6 and SAB are intended to result in the declaration of an Alert classification if a hazardous event resulted in degraded performance to one train of a safety system, with either visible damage to or degraded performance of a second train of safety equipment.
The proposed DAEC EALs CA6 and SAB include the following threshold value that that does not appear to be consistent with the overall intent for these EALs: "Loss of the safety function of a single train SAFETY SYSTEM." It was not apparent where such that a single support system issue would compromise public health and safety during a radiological event. As such, please explain which single safety systems would result in compromising public health and safety during a radiological event if they were compromised, or revise accordingly.
As provided, DAEC EALs CA6 and SAB are neither consistent with NE/ 99-01, Revision 6, nor with the guidance provided by EPFAQ 2016-02, "Clarification of Equipment Damage as a Result of a Hazardous Event" (ADAMS Accession No. ML 17195A299).
Please explain what specific design DAEC features preclude using the guidance provided by EPFAQ 2016-02, or revise accordingly to preclude a possible unwarranted event classification.
DAEC Response Using the clarifying guidance provided in draft EALFAQ 2018-04, DAEC has removed the proposed threshold value for single train safety systems that is not consistent with the overall intent for these EALs. DAEC has added the clarifying language provided in this draft EALFAQ to the Basis for proposed EALs CA6 and SA8 as an aid to the plant operators to promote a consistent conclusion in evaluation of these EALs. With the exception of one additional clarifying Basis paragraph as provided by EALFAQ 2018-04, these EALs are now consistent with the guidance provided by EPFAQ 2016-02. The revised documents are provided in the updated versions of Attachments 1, 2, 3, 4, and 5 provided in this letter. 6 Enclosure to NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-7 The proposed DAEC EAL threshold values forCS1.3.b and CG1.2.b include "Erratic source range indication" as a core uncover[y]
indication.
This indication is typically applicable to pressurized water (PWR) reactors and not boiling water reactors (BWR). Please justify using a threshold value that is typically applicable to a PWR for DAEC, which is a BWR, or revise accordingly.
DAEC Response DAEC agrees that use of this indication of potential core uncovery is unreliable for BWR designs and has removed it from the listing of potential indications in DAEC proposed EALs CS1 and CG1. The revised documents are provided in the updated versions of Attachments 1, 2, 3, and 5 provided in this letter. 7 Enclosure to NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-8 The proposed DAEC EAL threshold values for fission product barrier degradation, based on containment radiation monitors, do not appear appropriate.
Considering that the Fuel Clad Loss threshold value should correspond to 2% to 5% clad_ damage, and the Containment Barrier Potential Loss threshold value should be 20% (as provided by NE/ 99-01, Revision 6), it would be reasonable for the radiation values to be different by a factor of 4 to 10. However, the value for the Containment Barrier Loss drywe/1 radiation monitor reading is 25 times higher than the Primary Containment Loss radiation monitor reading, while the corresponding Torus Radiation Monitor reading for a Containment Barrier Potential Loss is 2. 5 times the Fuel Clad Barrier Loss threshold value. Additionally, it appears the Fuel Clad Barrier Loss was developed based on an intact RCS, which is not consistent with the guidance provided by NE/ 99-01, Revision 6, or the DAEC Technical Basis for the Torus Radiation Monitor Containment Loss threshold value, which is based on a loss of RCS inventory.
Please verify that the Fuel Clad Barrier threshold values for the Drywe/1 and Torus radiation monitors are based on a loss of the RCS with between approximately 2% and 5% clad damage and that the Containment Barrier Potential Loss radiation monitors are based on approximately 20% clad damage, or revise accordingly.
DAEC Response After further clarifying discussion with the NRC staff during a June 26, 2018 telephone call, DAEC has updated the proposed Fuel Clad Loss radiation monitor threshold value to reflect a value based on a loss of the RCS with between approximately 2% and 5% clad damage (Loss 4.A). The proposed radiation monitor threshold values for Drywell and Torus Containment Barrier Potential Loss are now both 2.5 times the Fuel Clad Barrier Loss threshold value. Additionally, the standardized threshold for RCS Activity due to Fuel Clad Loss (Loss 1.A) has been added to the Fission Product Barrier Matrix to provide an alternate method of assessing this barrier if coolant samples results are available.
Both changes are consistent with the guidance provided by NEI 99-01, Revision 6. The revised documents are provided in the updated versions of Attachments 1, 2, 3, 4, and 5 provided in this letter. 8 Enclosure to NG-1 S-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-9 The proposed DAEC EAL HU3 includes threshold values that do not appear to be consistent with the overall intent of EAL HU3 to address hazardous events, including a threshold value for high river level and a River Water Supply (RWS) pit low level alarm. Considering that internal room or area flooding is specifically addressed by HU3.2, the threshold value for river level appears redundant.
Additionally, a high river level alone may, or may not, involve internal room or area flooding.
Although a RWS pit low level alarm may be the result of a hazardous event, the RWS pit low level condition does not appear to represent an actual hazardous event. Please verify whether a high river level or a river water supply pit low level alarm should be considered as hazardous events, or revise accordingly.
DAEC Response DAEC agrees that the proposed thresholds for high river level and a River Water Supply (RWS) pit low level alarm are not consistent with the overall intent of EAL HU3 and these examples have been removed. Additionally, the same conditions were listed as example hazardous events in EAL SAS. DAEC has determined that these conditions are adequately covered by the existing standardized examples provided in NEI 99-01, Revision 6, and has removed the high river level and a River Water Supply (RWS) pit low level alarm conditions from EAL SUS as redundant to the other examples provided.
The revised documents are provided in the updated versions of Attachments 1, 2, 3, 4, and 5 provided in this letter. 9 Enclosure to NG-18-0090 Response to Adoption of EAL Scheme Pursuant to NEI 99-01 RAls RAI-DAEC-10 The proposed DAEC EAL HU4.2 is intended to provide licensees thirty (30) minutes to validate whether or not a single fire alarm is valid. BWRs typically inert the Drywe/1 and Torus when at power. DAEC EAL HU4.2 does not appear to have a note or other statement that indicates that an Unusual Event should not be declared if the Drywe/1 and Torus are inerted. Please verify that there is a need to declare DAEC EAL HU4 for containment if the DAEC Drywe/1 and Torus are inerted, or revise accordingly.
DAEC Response Due to the absence of fire alarms within the Drywell and Torus, DAEC is not susceptible to false fire alarms in those areas and the accompanying potential for an erroneous NOUE declaration using EAL HU4.2. These areas do remain listed on the Table H-1 fire areas for use in the evaluation of EAL HU4.1 in the event of a fire report from the field during those times that the Drywell and Torus are not inerted and can be accessed by plant personnel.
No changes were made the proposed EAL HU4. 10