ML112070426

Columbia Generating Station - Updated Draft Request for Additional Information Emergency Action Level Upgrade (TAC No. ME4589)

ML112070426
Person / Time
Site:	Columbia
Issue date:	04/26/2011
From:	Johnson D A Office of Nuclear Security and Incident Response
To:	Williams L L Energy Northwest
Thadani, M C, NRR/DORL/LPL4, 415-1476
Shared Package
ML112070405	List: ML112070415 ML112070426 ML112070459
References
TAC ME4589
Download: ML112070426 (2)

Text

Enclosure DRAFT REQUEST FOR ADDITIONAL INFORMATION COLUMBIA GENERATING STATION EMERGENCY ACTION LEVEL SCHEME CHANGE TO NEI 99-01, REVISION 5 DOCKET NO. 50-397 By letter dated August 25, 2010, Energy Northwest - Columbia Generating Station (CGS), (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102430334) requested prior approval for a revised emergency action level (EAL) scheme for Columbia Generating Station. CGS's letter stated that the current EAL scheme is based on generic development guidance from NUMARC/NESP-007, "Methodology for Development of Emergency Action Levels,"

Revision 2, dated January 1992, (ADAMS Accession No. ML041120174). Since 1992, numerous enhancements and clarification efforts have been made to the generic EAL development guidance resulting in the most latest document, Nuclear Energy Institute (NEI) 99-01, Revision 5, "Methodology for Development of Emergency Action Levels," (ADAMS Accession No. ML080450149), which was found to be acceptable for use as generic EAL development guidance by the Nuclear Regulatory Commission (NRC) staff by letter dated February 22, 2008 (ADAMS Accession No. ML080430535). The proposed EAL scheme was developed using the generic development guidance from NEI 99-01, Revision 5 with numerous differences and deviations based upon design criteria applicable to CGS as well as licensee preferences for terminology, format, and other licensee desired modifications to the generic EAL scheme provided in NEI 99-01 Revision 5. Attached are the draft requests for additional information (RAIs) to facilitate the technical review being conducted by the Operating Reactor Licensing and Outreach Branch staff. Timely and accurate response to these draft RAIs is requested. 1. Section 2.0, "Discussion." This section does not contain information on the treatment of multiple events and classification upgrading as outlined in the endorsed guidance. Please provide justification for this inconsistency, or revise accordingly. 2. Step 2.13, "Validation of Indications, Reports and Conditions," step 2.13.2, states, in part, that "If a meter is broke, compensatory measures should be established to monitor the affected parameter." Please explain why this implies an option versus being a requirement as stated in 10 CFR 50.54(q), or revise to state "-shall- ." 3. The use of the following abbreviations is considered unadvisable from a human factors perspective as their use could cause significant confusion. Please explain why the staff should consider allowing these abbreviations to be implemented, or revise to use generally accepted nomenclature.

a. GE: Numerous EALs use this as an abbreviation for "greater than or equal to." Please explain, in detail, why the use of "" or spelling out the words will not suffice, or revise accordingly wherever used. b. GT: Numerous EALs use this as an abbreviation for "greater than." Please explain, in detail, why the use of ">" or spelling out the words will not suffice, or revise accordingly wherever used. c. LE: Numerous EALs use this as an abbreviation for "less than or equal to." Please explain, in detail, why the use of "" or spelling out the words will not suffice, or revise accordingly wherever used. d. LT: Numerous EALs use this as an abbreviation for "less than." Please explain, in detail, why the use of "<" or spelling out the words will not suffice, or revise accordingly wherever used. 4. EAL RS1.1 and RG1.1: Please explain why the CGS basis information contains information about the Radwaste Building Exhaust (WEA-RIS-14(A)) being applicable when Table R-1 shows these to not be applicable to these EALs. 5. EAL RG1.3: Please explain why the note related to EAL declaration timing was not incorporated in this EAL, or revise accordingly. 6. EAL RA3.1: Please explain, in more detail, why the Central Alarm Station (CAS) is not applicable to this EAL or revise accordingly. 7. EAL CU5.1 and SU6.1: Please explain how the State/County Notification (CRASH) System will notify the NRC of a declared event at CGS or revise accordingly. 8. Fission Barrier Matrix: Please explain why no "other" site specific indicators have not been developed for this matrix, particularly when the current EAL scheme (based upon NUMARC/NESP-007) has several indicators not carried over into this proposed matrix considering that the matrix from NEI 99-01 Revision 5 is very similar. 9. The staff approved License Amendment No. 218 for CGS in response to the licensee's application dated April 28, 2010. However, the staff finds no evidence that this amendment has been carried over into this request to revise the CGS EAL scheme. Please explain, in detail, why this license amendment has not been carried over into this EAL scheme change request, or revise accordingly. 10. EAL EU1.1: The EAL states, "Multi Purpose Container (MPC) CONFINEMENT BOUNDARY breach". As worded this EAL would require an actual breach of the boundary versus damage to the confinement boundary for EAL declaration. Please provide justification for this inconsistency, or revise accordingly.