ML16056A242

Response to Request for Additional Information Regarding the License Amendment Request (LAR) to Change the Emergency Plan to Upgrade Emergency Action Levels Based on NEI 99-01, Revision 6

ML16056A242
Person / Time
Site:	McGuire, Mcguire
Issue date:	02/18/2016
From:	Capps S D Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16056A254	List: ML16056A242 ML16056A243 ML16056A245 MNS-16-016, Emergency Action Level Technical Bases, Revision 1 Redline. Part 1 of 2
References
MNS-16-016
Download: ML16056A242 (13)

Text

S DUKESteven D. Capps Vice President ENERGY McGuire Nuclear Station MG01VP 1 12700 Hagers Ferry Road Huntersville, NC 28078 o: 980.875.4805 f- 980.875.4809 Steven.Capps@duke-energy.com 10 CFR 50.90 10 CFR 50 Appendix E February 18, 2016 MNS-1 6-016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Duke Energy Carolinas, LLC (Duke Energy)McGuire Nuclear Station Units 1 and 2 Docket Nos. 50-369, 50-370 Renewed License Nos. NPF-9 and NPF-17

Subject:

Response to Request for Additional Information Regarding the License Amendment Request (LAR) to Change the McGuire Nuclear Station (MNS) Emergency Plan to Upgrade MNS Emergency Action Levels Based on NEI 99-01, Revision 6 By letter dated May 7, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML1 5141 A047), Duke Energy requested approval of a proposed change to the Emergency Action Levels (EALs) used at McGuire Nuclear Station (MNS). Duke Energy proposes to revise their current MNS EAL scheme to one based upon Nuclear Energy Institute (NEI) document NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6 (ADAMS Accession No. ML12326A805).

The NRC staff reviewed the request and determined that additional information is needed to complete their review. A letter requesting additional information was sent on January 20, 2016 (ADAMS Accession No. ML16014A688).

Enclosure 1 of this letter provides the MNS response to the request for additional information and additional changes identified during the RAl process which were deemed necessary.

Enclosure 2 provides the MNS redline version of the revised Emergency Action Level Technical Bases Document.

Enclosure 3 provides the MNS final (clean) version of the Emergency Action Level Technical Bases Document.This letter makes no new regulatory commitments or changes to any existing commitments.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated North Carolina State Officials.

United States Nuclear Regulatory Commission February 18, 2016 Page 2 If there are any questions related to this submittal contact George Murphy at (980) 875-5715.I declare under penalty of perjury that the foregoing is true and correct. Executed on February 18, 2016.Steven D. Capps

Enclosures:

Enclosure 1 -Response to Request for Additional Information Enclosure 2 -MNS Emergency Action Level Technical Bases Document Redline Enclosure 3 -MNS Emergency Action Level Technical Bases Document Final United States Nuclear Regulatory Commission February 18, 2016 Page 3 xc: C. Haney, Region II Administrator U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 G. E. Miller, Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 8 G9A Rockville, MD 20852-2738 J. Zeiler NRC Senior Resident Inspector McGuire Nuclear Station W.L. Cox Ill, Section Chief North Carolina Department of Environment and Natural Resources Division of Environmental Health Radiation Protection Section 1645 Mail Service Center Raleigh. NC 27699-1 645 ENCLOSURE 1 MNS RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGE MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 RAI # SECTION/ usinMSRsos MNS- EALQesinNSepoe Section 4.3, "Instrumentation Used for EALs," to NEI 99-01, MNS has confirmed that all setpoints and indications used Revision 6, states (in part): "Scheme developers should in the proposed EAL scheme are within the calibrated ensure that specific values used as EAL setpoints are range(s) of the stated instrumentation and that the within the calibrated range of the referenced resolution of the instrumentation is appropriate for the 4.3 instrumentation." Please confirm that all setpoints and setpoint/indication.

indications used in the proposed EAL scheme are within the calibrated range(s) of the stated instrumentation and that the resolution of the instrumentation is appropriate for the setpoint/indication.

Section 2.5, "Technical Bases Information, "states: "A The MNS site specific and NEI 99-01 generic bases sections Plant-specific basis section that provides MNS-relevant have been combined into a single bases section for each information concerning the EAL. This is followed by a EAL. Section 2.5 "Technical Bases Information" has been Generic basis section that provides a description of the revised accordingly.

rationale for the EAL as provided in NEI 99-01 Rev. 6." Due to the high probability that EAL decision-makers will beReudnbaswreplibehvbeneet.

confused between these two sections when the information appears to be inconsistent, please justify why the rational 2 GENERALfor two sections when it is acceptable to just have one basis section that is specific to the plant, or revise accordingly to eliminate potential confusion by user.Page 2 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

('RAI)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGE MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 RAI # SECTION!/usinMSRsos MNS- EALQusinMSRpoe Section 5.0, "Definitions," does not include definitions for The following definitions have been added to Section 5.1 the following:

consistent with NEI 99-01 Revision 6:* Alert,

• Alert,* Notification of Unusual Event,

• Unusual Event,* Site Area Emergency,

• Site Area Emergency,* General Emergency,

• General Emergency, 3 5.1

• Emergency Action Level,

• Emergency Action Level,* Emergency Classification Level, o Emergency Classification Level,* Fission Product Barrier Threshold, and o Fission Product Barrier Threshold, and* Initiating Condition.

• Initiating Condition.

Please provide justification for omitting these definitions, or revise to incorporate these definitions consistent with NEI 99-01, Revision 6.For the following EALs, please explain why the listed Deleted Note 3 from RA1 .2, RS1 .2 and RG1 .2.RA1 .2 NOTEs were included, or revise accordingly:

4 RS1.2

• RA1.2- NOTE-3* RS1l.2 -NOTE-3 RGI.2 RG1.2-NOTE-3 For EAL RA2.2, the information in the NEI 99-01 Basis Re-instated the following text to the RA2.2 bases: section does not contain all of the actual information from "This EAL applies to irradiated fuel that is licensed for dry 5 A22 NEI 99-01, as it is germane to this particular EAL. Please storage up to the point that the loaded storage cask is RA2.2 explain why this information was omitted, or revise sae.Oc eld aaet oddcs asn accordingly.

loss of the CONFINEMENT BOUNDARY is classified in_____ _______ ______________________________________

accordance with EAL EUI. 1." Page 3 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (PAl)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGE MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 RAI # SECTION/ usinMSRsos MNS- EALQusinMSRpoe For EAL RU1 .2 and PAl .3, please explain why RU1 .2 uses The MNS Selected License Commitments (SLC) specify RUI1.2 the term "Selected Licensee Commitment (SLC)," while release rate limits per license commitments.

The Offsite 6 RA1 .3 uses "Offsite Dose Calculation Manual (ODCM)." Dose Calculation Manual (ODCM) provides the methodology RAl .3 Typically both use the ODCM. Please confirm and for performing dose assessments relative to the SLCs.elaborate on basis for difference, or revise accordingly.

CUI1.2 For EALs CU1 .2, CAl1.2, CS1 .1 and CG1 .1, please provide The following sumps and tanks have been identified for inclusion in C~l .2 further detail as to why additional sumps and tanks cannot EALs CUI1.2, CA1 .2, CS1 .1 and CG1 .1: be used for these EALs, or revise accordingly.

• NCDT -Reactor Coolant Drain Tank CS 1.1* PRT -Pressurizer Relief Tank CG1.1

• CFAE -Containment Floor and Equipment sump 7* ND/NS -RHR/Containment Spray Sump* RHT -Recycle Holdup Tank* WDT- Waste Drain Tank* WEFT -Waste Evaporator Feed Tank* SRST -Spent Resin Storage Tank Please provide further detail as to why CS1 .1 and CSI1.2 Although the current NUMARC/NESP-007 Rev. 2 based from NEI 99-01, Revision 6, cannot be adequately EALs provide thresholds utilizing NCS narrow range water developed.

A review of the current MNS EAL scheme level below the bottom of the hot leg, the design and shows that, while limited, MNS does have NCS water level operation of the MNS water level instrumentation is such that 8 CS 1 monitoring capability.

Please justify the removal of these the "site-specific level" (6" below the bottom ID of the NCS CS1 .2 EALs from the proposed MNS EAL scheme, or revise loop and top of fuel) cannot be determined at any time during accordingly.

Cold Shutdown or Refueling modes because the RVLIS instrumentation is not available at all times during these modes. There are no alternative means of assessing NCS______ _______ _______________________________________water below the bottom of the NCS loop.Page 4 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI')EMERGENCY ACTION LEVEL (EAL) SCHEME CHANGE MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 RAI #* SECTION!/usinMSRsos MNS- EALQusinMSRpoe For EALs CA2.1, SS1.1 and SGI1.2, please explain Deleted reference to Table C-2/S-1 AC power source tables C21 inclusion of the table and basis language related to the from CA2.1, SSI.1 and SG1.2. Revised associated bases to 10 S51.1 Standby Shutdown Diesel Generator, or revise accordingly, credit the Standby Shutdown Diesel Generator only if aligned SI2 as these EALs are for a loss of all sources to power within the associated EAL timing threshold.

essential 4160V buses 1(2) ETA and 1(2) ETB.For EAL CA3.1, please explain why the MNS Basis has a Added new Note 9 to CA3.1 that reads: statmen reate towha to o wen elibleNCS"In the absence of reliable NCS temperature indication temperature indication is absent. If this is an accurate cue ytels fdcyha eoa aaiiy 11 CA3.1 statement, then please explain why this is not provided as a classification should be based on the NCS pressure NOTE for the EAL, or revise accordingly.

increase criteria when in Mode 5 or based on time to boil data when in Mode 6" For EAL HU2.1, please explain in further detail the process Immediate control room alarm indication of an earthquake of used to determine if the seismic activity has exceeded the either 0.08 g horizontal or 0.053 g vertical or greater is Operating Basis Earthquake (OBE) threshold and its annunciated through the system's network control center classification timeliness.

If the OBE threshold (vertical) is (NCC), following seismic trigger actuation by at least two not recognized in a timely fashion from indications in, or accelerographs (vertical switch settings are 2/3 of the near, the Control Room, then explain why the alternative respective horizontal switch settings).

Therefore exceeding 12 HU2.1 EAL was not developed in accordance with NEI 99-01, either the horizontal or vertical OBE thresholds actuates the Revision 6, or revise accordingly.

specified alarm.Classification is based upon receipt of this alarm.The HU2.1 bases has been revised to clarify that the OBE alarm is received based on exceeding either acceleration.

Page 5 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGE MCGU IRE NUCLEAR STATION. UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 RAI # SECTION!/usinMSRsos MNS- EALQusinMSRpoe Please explain why there was no EAL developed, possibly There is no site-specific lake level threat that is not as HU3.5, for ultimate heat sink (i.e., lake level) level adequately addressed through other Hazard and/or System issues, or revise accordingly.

Malfunction EALs. High lake level is adequately addressed by HU3.4. Loss of heat sink is adequately addressed by CU3.I.13 HU3.5 For EALs HU4.1 and HU4.2, the areas listed in Table H-I Table H-I Fire Areas are based on MCS-1465.00-00-0022 seem to be vague or too all-encompassing.

Please explain Design Basis Specification for the Appendix R Safe if the listed areas are all the areas that contain equipment Shutdown Analysis and AP/0/A/5500/45 Plant Fire. Table H-needed for safe operation, safe shutdown and safe cool- 1 Fire Areas include those structures containing functions down, and if these areas can be fine-tuned to limit and systems required for safe operation, shutdown and consideration for these EALs, or revise accordingly.

cooldown of the plant (SAFETY SYSTEMS).A balance must be established between defining major plant 14 HU4.1 structures containing safe shutdown equipment as fire areas HU4.2 versus a detailed list of areas for every safety system component location.

The Table H-i list of fire areas achieves that balance in support of timely and accurate emergency classification for the end-user.No further refinement can be achieved.Page 6 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

('RAI)EMERGENCY ACTION LEVEL (EAL) SCHEME CHANGE MCGU IRE NUCLEAR STATION. UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 RAI # SECTIONI/usinMSRsos MNS- EALQusinMSRpoe For EALs HU4.3 and HU4.4, please confirm that the The MNS ISESI is contained wholly within the plant Protected Independent Spent Fuel Storage Installation (ISESI) would Area. Therefore the ISFSI would be applicable to EALs be an area applicable to these EALs, or revise accordingly.

HU4.3 and HU4.4 for fires within the plant Protected Area.HU4.3 15 HU4.4 For EAL HA5.1, please note in the MNS Basis that this EAL The following note was added to the HA5.1 bases to ensure is typically applicable in all operating modes, but is limited HA5.1 mode applicability remains in alignment with to operating modes 3 and 4 based upon a review of Table H-2 Room/Area mode applicability:

applicable areas of concern. However, if the plant is "NOTE:/IC HA5 mode applicability has been limited to the modified such that additional areas and/or operating modes applicable modes identified in Table H-2 Safe Operation

&become applicable, this EAL must be revised accordingly.

Shutdown Rooms/Areas./If due to plant operating Please explain what process is in place which ensures that poeueo ln ofgrto hneteapial futue plnt hangs ar cosideed fr oher hanplant modes specified in Table H-2 are changed,a 16 HAS.1I operating modes 3 and 4 under EAL HAS. 1. corresponding change to Attachment 3 'Safe Operation

&Shutdown Areas Tables R-2 & H-2 Bases' and to IC HA5 mode applicability is required." AD-LS-ALL-0007, Applicability Determination Process and AD-EG-ALL-1 132, Preparation and Control of Design Change and Engineering Changes provide for review of changes that could affect the emergency plan and or Station Emergency______________

________________________________________Preparedness Page 7 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGE MCGU IRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 RAI # SECTION/QusinMSRpoe MNS- EALQusinMSRpoe For EAL HS6.1, please explain why the operating mode Revised HS6.1 mode applicability from ALL to Modes 1 -6.specificity to the key safety functions listed in the EAL was Revised HS6.1 based upon an assessment of applicable not incorporated, or revise accordingly.

modes for each of the listed safety function as follows: 'An event has resulted in plant control being transferred from the Control Room to the Auxiliary Shutdown Panels or 17 HS6.1 Standby Shutdown Facility (SSF)AND Control of any of the following key safety functions is not reestablished within 15 min. (Note 1):* Reactivity (Modes 1, 2 and 3 only)* Core Cooling* NCS heat removal" SU3.1 For EALs SU3.1 and SA3.1, please correct the Corrected typographical errors related to specifying the 18 typographical errors related to specifying the wrong tables wrong tables to be referenced.

SA3.1 to be referenced.

Under Category E -Independent Spent Fuel Storage Deleted the following cited statement from the Category E Installation (ISFSI) guidance, the statement: "Formal offsite introduction planning is not required because the postulated worst-case "Formal offsite planning is not required because the accident involving an ISFSI has insignificant consequences postulated worst-case accident involving an ISFSI has to the public health and safety," is not applicable to this 19 EUI .1 proposed EAL scheme. Please provide further justification insignificant consequences to the public health and safety." for this statement or revise accordingly to remove. Revised the ISESI category introduction to read: In addition, please incorporate guidance related to the fact "The MNS ISFSI is contained wholly within the plant that EALs HU1 and HA1 are also considered for events that Protected Area. Therefore a security event related to the occur at the ISFSI, or explain basis for not including.

ISFSI would be applicable to EALs HUI. 1, HAl. land HSI. 1." Page 8 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL (EAL) SCHEME CHANGE MCGUIRE NUCLEAR STATION. UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 RAI # SECTIONI/usinMSRsos MNS- EALQusinNSRpoe Under the Fission Product Barrier (FPB) Matrix, the cited As per response to RAI-2, the MNS site specific and NEI 99-NEI 99-0 1 Basis sections for several of the FPB criteria are 01 Revision 6 bases have been unified.FPB not from the NRC-endorsed NEI 99-01, Revision 6. Please 20 Bases either revise to what has actually been endorsed, or (depending on the response to RAI-03), unify the basis sections into one.For Fuel Clad Barrier Potential Loss 2 and Reactor Coolant The plant-specific bases was added to support interpretation System Potential Loss 1, please provide further justification of the words "...and heat sink is required" added to the FPB as to why the Heat Sink Red language was added to the potential loss thresholds related to Heat Sink CSFST red Plant-Specific Basis section, as no documentation was path. This is consistent with the generic bases which states: provided to justify its inclusion, and it appears to provide a "In accordance with EOPs, there may be unusual accident FC caveat to declaration, or revise accordingly.

conditions during which operators intentionally reduce the Potential heat removal capability of the steam generators; during Loss 2 these conditions, classification using threshold is not 21 RSwarranted" Potential The added bases also supports the condition where, due to a Loss 1 large break LOCA with RCS pressure less than SG pressure, heat sink is not required even though heat sink red path conditions exist.In both instances the determination is quickly made that heat sink is not required upon entry into FR-H.1 Response to Loss of Secondary Heat Sink.Page 9 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL ('EAL') SCHEME CHANGE MCGU IRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 Attachment A Summary of EAL Changes NOT Associated with RAI Responses The table below summarizes changes that have been introduced to the EAL submittal documentation for reasons other than the responses to the NRC RAIs.EAL Tech Basis#Change? Description SA9.1 Yes MNS Reference

1. 7 NEI source IC corrected to read SA9 vs. CA6.HU1.1 Yes Split EAL HUI.1 into three separate EALs: HU1.1, HU1.2 and HU1.3 to better support the offsite notification process.HA1.1 Yes Split EAL HA1.1 into two separate EALs: HA1.1 and HA1.2 to better support the offsite notification process.SU8.1 Yes Added new Note 10 consistent with response to Catawba Nuclear Station RAI #20 related to re-enforcement of the VX-CARF actuation time delay bases discussion.

CMT Potential Yes Added new Note 10 consistent with response to Catawba Nuclear Station RAI #20 related to re-Loss D.3 enforcement of the VX-CARF actuation time delay bases discussion.

SU4.1 Yes Revised SU4.1 and related bases to accurately reflect Technical Specification 3.4.16 NCS activity limits: NCS activity > any of the following Technical Specification 3.4.16 limits:-Dose Equivalent 1-131 > 1.0 IpCi/gm for > 48 hrs.-Dose Equivalent 1-131 > 60 pCi/gm-Dose Equivalent Xe-i133 > 280 pCi/gm Page 10 of 10 S DUKESteven D. Capps Vice President ENERGY McGuire Nuclear Station MG01VP 1 12700 Hagers Ferry Road Huntersville, NC 28078 o: 980.875.4805 f- 980.875.4809 Steven.Capps@duke-energy.com 10 CFR 50.90 10 CFR 50 Appendix E February 18, 2016 MNS-1 6-016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Duke Energy Carolinas, LLC (Duke Energy)McGuire Nuclear Station Units 1 and 2 Docket Nos. 50-369, 50-370 Renewed License Nos. NPF-9 and NPF-17

Subject:

Response to Request for Additional Information Regarding the License Amendment Request (LAR) to Change the McGuire Nuclear Station (MNS) Emergency Plan to Upgrade MNS Emergency Action Levels Based on NEI 99-01, Revision 6 By letter dated May 7, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML1 5141 A047), Duke Energy requested approval of a proposed change to the Emergency Action Levels (EALs) used at McGuire Nuclear Station (MNS). Duke Energy proposes to revise their current MNS EAL scheme to one based upon Nuclear Energy Institute (NEI) document NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6 (ADAMS Accession No. ML12326A805).

The NRC staff reviewed the request and determined that additional information is needed to complete their review. A letter requesting additional information was sent on January 20, 2016 (ADAMS Accession No. ML16014A688).

Enclosure 1 of this letter provides the MNS response to the request for additional information and additional changes identified during the RAl process which were deemed necessary.

Enclosure 2 provides the MNS redline version of the revised Emergency Action Level Technical Bases Document.

Enclosure 3 provides the MNS final (clean) version of the Emergency Action Level Technical Bases Document.This letter makes no new regulatory commitments or changes to any existing commitments.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated North Carolina State Officials.

United States Nuclear Regulatory Commission February 18, 2016 Page 2 If there are any questions related to this submittal contact George Murphy at (980) 875-5715.I declare under penalty of perjury that the foregoing is true and correct. Executed on February 18, 2016.Steven D. Capps

Enclosures:

Enclosure 1 -Response to Request for Additional Information Enclosure 2 -MNS Emergency Action Level Technical Bases Document Redline Enclosure 3 -MNS Emergency Action Level Technical Bases Document Final United States Nuclear Regulatory Commission February 18, 2016 Page 3 xc: C. Haney, Region II Administrator U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 G. E. Miller, Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 8 G9A Rockville, MD 20852-2738 J. Zeiler NRC Senior Resident Inspector McGuire Nuclear Station W.L. Cox Ill, Section Chief North Carolina Department of Environment and Natural Resources Division of Environmental Health Radiation Protection Section 1645 Mail Service Center Raleigh. NC 27699-1 645 ENCLOSURE 1 MNS RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGE MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 RAI # SECTION/ usinMSRsos MNS- EALQesinNSepoe Section 4.3, "Instrumentation Used for EALs," to NEI 99-01, MNS has confirmed that all setpoints and indications used Revision 6, states (in part): "Scheme developers should in the proposed EAL scheme are within the calibrated ensure that specific values used as EAL setpoints are range(s) of the stated instrumentation and that the within the calibrated range of the referenced resolution of the instrumentation is appropriate for the 4.3 instrumentation." Please confirm that all setpoints and setpoint/indication.

indications used in the proposed EAL scheme are within the calibrated range(s) of the stated instrumentation and that the resolution of the instrumentation is appropriate for the setpoint/indication.

Section 2.5, "Technical Bases Information, "states: "A The MNS site specific and NEI 99-01 generic bases sections Plant-specific basis section that provides MNS-relevant have been combined into a single bases section for each information concerning the EAL. This is followed by a EAL. Section 2.5 "Technical Bases Information" has been Generic basis section that provides a description of the revised accordingly.

rationale for the EAL as provided in NEI 99-01 Rev. 6." Due to the high probability that EAL decision-makers will beReudnbaswreplibehvbeneet.

confused between these two sections when the information appears to be inconsistent, please justify why the rational 2 GENERALfor two sections when it is acceptable to just have one basis section that is specific to the plant, or revise accordingly to eliminate potential confusion by user.Page 2 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

('RAI)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGE MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 RAI # SECTION!/usinMSRsos MNS- EALQusinMSRpoe Section 5.0, "Definitions," does not include definitions for The following definitions have been added to Section 5.1 the following:

consistent with NEI 99-01 Revision 6:* Alert,

• Alert,* Notification of Unusual Event,

• Unusual Event,* Site Area Emergency,

• Site Area Emergency,* General Emergency,

• General Emergency, 3 5.1

• Emergency Action Level,

• Emergency Action Level,* Emergency Classification Level, o Emergency Classification Level,* Fission Product Barrier Threshold, and o Fission Product Barrier Threshold, and* Initiating Condition.

• Initiating Condition.

Please provide justification for omitting these definitions, or revise to incorporate these definitions consistent with NEI 99-01, Revision 6.For the following EALs, please explain why the listed Deleted Note 3 from RA1 .2, RS1 .2 and RG1 .2.RA1 .2 NOTEs were included, or revise accordingly:

4 RS1.2

• RA1.2- NOTE-3* RS1l.2 -NOTE-3 RGI.2 RG1.2-NOTE-3 For EAL RA2.2, the information in the NEI 99-01 Basis Re-instated the following text to the RA2.2 bases: section does not contain all of the actual information from "This EAL applies to irradiated fuel that is licensed for dry 5 A22 NEI 99-01, as it is germane to this particular EAL. Please storage up to the point that the loaded storage cask is RA2.2 explain why this information was omitted, or revise sae.Oc eld aaet oddcs asn accordingly.

loss of the CONFINEMENT BOUNDARY is classified in_____ _______ ______________________________________

accordance with EAL EUI. 1." Page 3 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (PAl)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGE MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 RAI # SECTION/ usinMSRsos MNS- EALQusinMSRpoe For EAL RU1 .2 and PAl .3, please explain why RU1 .2 uses The MNS Selected License Commitments (SLC) specify RUI1.2 the term "Selected Licensee Commitment (SLC)," while release rate limits per license commitments.

The Offsite 6 RA1 .3 uses "Offsite Dose Calculation Manual (ODCM)." Dose Calculation Manual (ODCM) provides the methodology RAl .3 Typically both use the ODCM. Please confirm and for performing dose assessments relative to the SLCs.elaborate on basis for difference, or revise accordingly.

CUI1.2 For EALs CU1 .2, CAl1.2, CS1 .1 and CG1 .1, please provide The following sumps and tanks have been identified for inclusion in C~l .2 further detail as to why additional sumps and tanks cannot EALs CUI1.2, CA1 .2, CS1 .1 and CG1 .1: be used for these EALs, or revise accordingly.

• NCDT -Reactor Coolant Drain Tank CS 1.1* PRT -Pressurizer Relief Tank CG1.1

• CFAE -Containment Floor and Equipment sump 7* ND/NS -RHR/Containment Spray Sump* RHT -Recycle Holdup Tank* WDT- Waste Drain Tank* WEFT -Waste Evaporator Feed Tank* SRST -Spent Resin Storage Tank Please provide further detail as to why CS1 .1 and CSI1.2 Although the current NUMARC/NESP-007 Rev. 2 based from NEI 99-01, Revision 6, cannot be adequately EALs provide thresholds utilizing NCS narrow range water developed.

A review of the current MNS EAL scheme level below the bottom of the hot leg, the design and shows that, while limited, MNS does have NCS water level operation of the MNS water level instrumentation is such that 8 CS 1 monitoring capability.

Please justify the removal of these the "site-specific level" (6" below the bottom ID of the NCS CS1 .2 EALs from the proposed MNS EAL scheme, or revise loop and top of fuel) cannot be determined at any time during accordingly.

Cold Shutdown or Refueling modes because the RVLIS instrumentation is not available at all times during these modes. There are no alternative means of assessing NCS______ _______ _______________________________________water below the bottom of the NCS loop.Page 4 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI')EMERGENCY ACTION LEVEL (EAL) SCHEME CHANGE MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 RAI #* SECTION!/usinMSRsos MNS- EALQusinMSRpoe For EALs CA2.1, SS1.1 and SGI1.2, please explain Deleted reference to Table C-2/S-1 AC power source tables C21 inclusion of the table and basis language related to the from CA2.1, SSI.1 and SG1.2. Revised associated bases to 10 S51.1 Standby Shutdown Diesel Generator, or revise accordingly, credit the Standby Shutdown Diesel Generator only if aligned SI2 as these EALs are for a loss of all sources to power within the associated EAL timing threshold.

essential 4160V buses 1(2) ETA and 1(2) ETB.For EAL CA3.1, please explain why the MNS Basis has a Added new Note 9 to CA3.1 that reads: statmen reate towha to o wen elibleNCS"In the absence of reliable NCS temperature indication temperature indication is absent. If this is an accurate cue ytels fdcyha eoa aaiiy 11 CA3.1 statement, then please explain why this is not provided as a classification should be based on the NCS pressure NOTE for the EAL, or revise accordingly.

increase criteria when in Mode 5 or based on time to boil data when in Mode 6" For EAL HU2.1, please explain in further detail the process Immediate control room alarm indication of an earthquake of used to determine if the seismic activity has exceeded the either 0.08 g horizontal or 0.053 g vertical or greater is Operating Basis Earthquake (OBE) threshold and its annunciated through the system's network control center classification timeliness.

If the OBE threshold (vertical) is (NCC), following seismic trigger actuation by at least two not recognized in a timely fashion from indications in, or accelerographs (vertical switch settings are 2/3 of the near, the Control Room, then explain why the alternative respective horizontal switch settings).

Therefore exceeding 12 HU2.1 EAL was not developed in accordance with NEI 99-01, either the horizontal or vertical OBE thresholds actuates the Revision 6, or revise accordingly.

specified alarm.Classification is based upon receipt of this alarm.The HU2.1 bases has been revised to clarify that the OBE alarm is received based on exceeding either acceleration.

Page 5 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGE MCGU IRE NUCLEAR STATION. UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 RAI # SECTION!/usinMSRsos MNS- EALQusinMSRpoe Please explain why there was no EAL developed, possibly There is no site-specific lake level threat that is not as HU3.5, for ultimate heat sink (i.e., lake level) level adequately addressed through other Hazard and/or System issues, or revise accordingly.

Malfunction EALs. High lake level is adequately addressed by HU3.4. Loss of heat sink is adequately addressed by CU3.I.13 HU3.5 For EALs HU4.1 and HU4.2, the areas listed in Table H-I Table H-I Fire Areas are based on MCS-1465.00-00-0022 seem to be vague or too all-encompassing.

Please explain Design Basis Specification for the Appendix R Safe if the listed areas are all the areas that contain equipment Shutdown Analysis and AP/0/A/5500/45 Plant Fire. Table H-needed for safe operation, safe shutdown and safe cool- 1 Fire Areas include those structures containing functions down, and if these areas can be fine-tuned to limit and systems required for safe operation, shutdown and consideration for these EALs, or revise accordingly.

cooldown of the plant (SAFETY SYSTEMS).A balance must be established between defining major plant 14 HU4.1 structures containing safe shutdown equipment as fire areas HU4.2 versus a detailed list of areas for every safety system component location.

The Table H-i list of fire areas achieves that balance in support of timely and accurate emergency classification for the end-user.No further refinement can be achieved.Page 6 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

('RAI)EMERGENCY ACTION LEVEL (EAL) SCHEME CHANGE MCGU IRE NUCLEAR STATION. UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 RAI # SECTIONI/usinMSRsos MNS- EALQusinMSRpoe For EALs HU4.3 and HU4.4, please confirm that the The MNS ISESI is contained wholly within the plant Protected Independent Spent Fuel Storage Installation (ISESI) would Area. Therefore the ISFSI would be applicable to EALs be an area applicable to these EALs, or revise accordingly.

HU4.3 and HU4.4 for fires within the plant Protected Area.HU4.3 15 HU4.4 For EAL HA5.1, please note in the MNS Basis that this EAL The following note was added to the HA5.1 bases to ensure is typically applicable in all operating modes, but is limited HA5.1 mode applicability remains in alignment with to operating modes 3 and 4 based upon a review of Table H-2 Room/Area mode applicability:

applicable areas of concern. However, if the plant is "NOTE:/IC HA5 mode applicability has been limited to the modified such that additional areas and/or operating modes applicable modes identified in Table H-2 Safe Operation

&become applicable, this EAL must be revised accordingly.

Shutdown Rooms/Areas./If due to plant operating Please explain what process is in place which ensures that poeueo ln ofgrto hneteapial futue plnt hangs ar cosideed fr oher hanplant modes specified in Table H-2 are changed,a 16 HAS.1I operating modes 3 and 4 under EAL HAS. 1. corresponding change to Attachment 3 'Safe Operation

&Shutdown Areas Tables R-2 & H-2 Bases' and to IC HA5 mode applicability is required." AD-LS-ALL-0007, Applicability Determination Process and AD-EG-ALL-1 132, Preparation and Control of Design Change and Engineering Changes provide for review of changes that could affect the emergency plan and or Station Emergency______________

________________________________________Preparedness Page 7 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGE MCGU IRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 RAI # SECTION/QusinMSRpoe MNS- EALQusinMSRpoe For EAL HS6.1, please explain why the operating mode Revised HS6.1 mode applicability from ALL to Modes 1 -6.specificity to the key safety functions listed in the EAL was Revised HS6.1 based upon an assessment of applicable not incorporated, or revise accordingly.

modes for each of the listed safety function as follows: 'An event has resulted in plant control being transferred from the Control Room to the Auxiliary Shutdown Panels or 17 HS6.1 Standby Shutdown Facility (SSF)AND Control of any of the following key safety functions is not reestablished within 15 min. (Note 1):* Reactivity (Modes 1, 2 and 3 only)* Core Cooling* NCS heat removal" SU3.1 For EALs SU3.1 and SA3.1, please correct the Corrected typographical errors related to specifying the 18 typographical errors related to specifying the wrong tables wrong tables to be referenced.

SA3.1 to be referenced.

Under Category E -Independent Spent Fuel Storage Deleted the following cited statement from the Category E Installation (ISFSI) guidance, the statement: "Formal offsite introduction planning is not required because the postulated worst-case "Formal offsite planning is not required because the accident involving an ISFSI has insignificant consequences postulated worst-case accident involving an ISFSI has to the public health and safety," is not applicable to this 19 EUI .1 proposed EAL scheme. Please provide further justification insignificant consequences to the public health and safety." for this statement or revise accordingly to remove. Revised the ISESI category introduction to read: In addition, please incorporate guidance related to the fact "The MNS ISFSI is contained wholly within the plant that EALs HU1 and HA1 are also considered for events that Protected Area. Therefore a security event related to the occur at the ISFSI, or explain basis for not including.

ISFSI would be applicable to EALs HUI. 1, HAl. land HSI. 1." Page 8 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL (EAL) SCHEME CHANGE MCGUIRE NUCLEAR STATION. UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 RAI # SECTIONI/usinMSRsos MNS- EALQusinNSRpoe Under the Fission Product Barrier (FPB) Matrix, the cited As per response to RAI-2, the MNS site specific and NEI 99-NEI 99-0 1 Basis sections for several of the FPB criteria are 01 Revision 6 bases have been unified.FPB not from the NRC-endorsed NEI 99-01, Revision 6. Please 20 Bases either revise to what has actually been endorsed, or (depending on the response to RAI-03), unify the basis sections into one.For Fuel Clad Barrier Potential Loss 2 and Reactor Coolant The plant-specific bases was added to support interpretation System Potential Loss 1, please provide further justification of the words "...and heat sink is required" added to the FPB as to why the Heat Sink Red language was added to the potential loss thresholds related to Heat Sink CSFST red Plant-Specific Basis section, as no documentation was path. This is consistent with the generic bases which states: provided to justify its inclusion, and it appears to provide a "In accordance with EOPs, there may be unusual accident FC caveat to declaration, or revise accordingly.

conditions during which operators intentionally reduce the Potential heat removal capability of the steam generators; during Loss 2 these conditions, classification using threshold is not 21 RSwarranted" Potential The added bases also supports the condition where, due to a Loss 1 large break LOCA with RCS pressure less than SG pressure, heat sink is not required even though heat sink red path conditions exist.In both instances the determination is quickly made that heat sink is not required upon entry into FR-H.1 Response to Loss of Secondary Heat Sink.Page 9 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL ('EAL') SCHEME CHANGE MCGU IRE NUCLEAR STATION, UNITS 1 AND 2 DOCKET NO'S. 50-396 AND 50-370 Attachment A Summary of EAL Changes NOT Associated with RAI Responses The table below summarizes changes that have been introduced to the EAL submittal documentation for reasons other than the responses to the NRC RAIs.EAL Tech Basis#Change? Description SA9.1 Yes MNS Reference

1. 7 NEI source IC corrected to read SA9 vs. CA6.HU1.1 Yes Split EAL HUI.1 into three separate EALs: HU1.1, HU1.2 and HU1.3 to better support the offsite notification process.HA1.1 Yes Split EAL HA1.1 into two separate EALs: HA1.1 and HA1.2 to better support the offsite notification process.SU8.1 Yes Added new Note 10 consistent with response to Catawba Nuclear Station RAI #20 related to re-enforcement of the VX-CARF actuation time delay bases discussion.

CMT Potential Yes Added new Note 10 consistent with response to Catawba Nuclear Station RAI #20 related to re-Loss D.3 enforcement of the VX-CARF actuation time delay bases discussion.

SU4.1 Yes Revised SU4.1 and related bases to accurately reflect Technical Specification 3.4.16 NCS activity limits: NCS activity > any of the following Technical Specification 3.4.16 limits:-Dose Equivalent 1-131 > 1.0 IpCi/gm for > 48 hrs.-Dose Equivalent 1-131 > 60 pCi/gm-Dose Equivalent Xe-i133 > 280 pCi/gm Page 10 of 10