ML16056A242

McGuire, Units 1 and 2 - 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. CappsVice PresidentENERGY McGuire Nuclear StationMG01VP 1 12700 Hagers Ferry RoadHuntersville, NC 28078o: 980.875.4805f- 980.875.4809Steven.Capps@duke-energy.com10 CFR 50.9010 CFR 50 Appendix EFebruary 18, 2016MNS-1 6-016U.S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, D.C. 20555-0001Duke Energy Carolinas, LLC (Duke Energy)McGuire Nuclear Station Units 1 and 2Docket Nos. 50-369, 50-370Renewed License Nos. NPF-9 and NPF-17

Subject:

Response to Request for Additional Information Regarding the License AmendmentRequest (LAR) to Change the McGuire Nuclear Station (MNS) Emergency Plan toUpgrade MNS Emergency Action Levels Based on NEI 99-01, Revision 6By letter dated May 7, 2015 (Agencywide Documents Access and Management System(ADAMS) Accession No. ML1 5141 A047), Duke Energy requested approval of a proposedchange to the Emergency Action Levels (EALs) used at McGuire Nuclear Station (MNS). DukeEnergy proposes to revise their current MNS EAL scheme to one based upon Nuclear EnergyInstitute (NEI) document NEI 99-01, "Development of Emergency Action Levels for Non-PassiveReactors," Revision 6 (ADAMS Accession No. ML12326A805).The NRC staff reviewed the request and determined that additional information is needed tocomplete 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 informationand additional changes identified during the RAl process which were deemed necessary.Enclosure 2 provides the MNS redline version of the revised Emergency Action Level TechnicalBases Document. Enclosure 3 provides the MNS final (clean) version of the Emergency ActionLevel 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 providedto the designated North Carolina State Officials.

United States Nuclear Regulatory CommissionFebruary 18, 2016Page 2If 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 onFebruary 18, 2016.Steven D. Capps

Enclosures:

Enclosure 1 -Response to Request for Additional InformationEnclosure 2 -MNS Emergency Action Level Technical Bases Document RedlineEnclosure 3 -MNS Emergency Action Level Technical Bases Document Final United States Nuclear Regulatory CommissionFebruary 18, 2016Page 3xc:C. Haney, Region II AdministratorU.S. Nuclear Regulatory CommissionMarquis One Tower245 Peachtree Center Avenue NE, Suite 1200Atlanta, Georgia 30303-1257G. E. Miller, Project ManagerU.S. Nuclear Regulatory Commission11555 Rockville PikeMail Stop 8 G9ARockville, MD 20852-2738J. ZeilerNRC Senior Resident InspectorMcGuire Nuclear StationW.L. Cox Ill, Section ChiefNorth Carolina Department of Environment and Natural ResourcesDivision of Environmental HealthRadiation Protection Section1645 Mail Service CenterRaleigh. NC 27699-1 645 ENCLOSURE 1MNS RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGEMCGUIRE NUCLEAR STATION, UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370RAI # SECTION/ usinMSRsosMNS- EALQesinNSepoeSection 4.3, "Instrumentation Used for EALs," to NEI 99-01, MNS has confirmed that all setpoints and indications usedRevision 6, states (in part): "Scheme developers should in the proposed EAL scheme are within the calibratedensure that specific values used as EAL setpoints are range(s) of the stated instrumentation and that thewithin the calibrated range of the referenced resolution of the instrumentation is appropriate for the4.3 instrumentation." Please confirm that all setpoints and setpoint/indication.indications used in the proposed EAL scheme are withinthe calibrated range(s) of the stated instrumentation andthat the resolution of the instrumentation is appropriate forthe setpoint/indication.Section 2.5, "Technical Bases Information, "states: "A The MNS site specific and NEI 99-01 generic bases sectionsPlant-specific basis section that provides MNS-relevant have been combined into a single bases section for eachinformation concerning the EAL. This is followed by a EAL. Section 2.5 "Technical Bases Information" has beenGeneric 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 informationappears to be inconsistent, please justify why the rational2 GENERALfor two sections when it is acceptable to just have onebasis section that is specific to the plant, or reviseaccordingly to eliminate potential confusion by user.Page 2 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ('RAI)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGEMCGUIRE NUCLEAR STATION, UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370RAI # SECTION!/usinMSRsosMNS- EALQusinMSRpoeSection 5.0, "Definitions," does not include definitions for The following definitions have been added to Section 5.1the 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, orrevise to incorporate these definitions consistent with NEI99-01, 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-3RGI.2 RG1.2-NOTE-3For 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 dry5 A22 NEI 99-01, as it is germane to this particular EAL. Please storage up to the point that the loaded storage cask isRA2.2 explain why this information was omitted, or revise sae.Oc eld aaet oddcs asnaccordingly. 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 CHANGEMCGUIRE NUCLEAR STATION, UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370RAI # SECTION/ usinMSRsosMNS- EALQusinMSRpoeFor EAL RU1 .2 and PAl .3, please explain why RU1 .2 uses The MNS Selected License Commitments (SLC) specifyRUI1.2 the term "Selected Licensee Commitment (SLC)," while release rate limits per license commitments. The Offsite6 RA1 .3 uses "Offsite Dose Calculation Manual (ODCM)." Dose Calculation Manual (ODCM) provides the methodologyRAl .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 inC~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 TankCS 1.1* PRT -Pressurizer Relief TankCG1.1

• CFAE -Containment Floor and Equipment sump7* ND/NS -RHR/Containment Spray Sump* RHT -Recycle Holdup Tank* WDT- Waste Drain Tank* WEFT -Waste Evaporator Feed Tank* SRST -Spent Resin Storage TankPlease provide further detail as to why CS1 .1 and CSI1.2 Although the current NUMARC/NESP-007 Rev. 2 basedfrom NEI 99-01, Revision 6, cannot be adequately EALs provide thresholds utilizing NCS narrow range waterdeveloped. A review of the current MNS EAL scheme level below the bottom of the hot leg, the design andshows that, while limited, MNS does have NCS water level operation of the MNS water level instrumentation is such that8 CS 1 monitoring capability. Please justify the removal of these the "site-specific level" (6" below the bottom ID of the NCSCS1 .2 EALs from the proposed MNS EAL scheme, or revise loop and top of fuel) cannot be determined at any time duringaccordingly. Cold Shutdown or Refueling modes because the RVLISinstrumentation is not available at all times during thesemodes. 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 CHANGEMCGUIRE NUCLEAR STATION, UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370RAI #* SECTION!/usinMSRsosMNS- EALQusinMSRpoeFor EALs CA2.1, SS1.1 and SGI1.2, please explain Deleted reference to Table C-2/S-1 AC power source tablesC21 inclusion of the table and basis language related to the from CA2.1, SSI.1 and SG1.2. Revised associated bases to10 S51.1 Standby Shutdown Diesel Generator, or revise accordingly, credit the Standby Shutdown Diesel Generator only if alignedSI2 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 indicationtemperature indication is absent. If this is an accurate cue ytels fdcyha eoa aaiiy11 CA3.1 statement, then please explain why this is not provided as a classification should be based on the NCS pressureNOTE for the EAL, or revise accordingly. increase criteria when in Mode 5 or based on time to boildata when in Mode 6"For EAL HU2.1, please explain in further detail the process Immediate control room alarm indication of an earthquake ofused to determine if the seismic activity has exceeded the either 0.08 g horizontal or 0.053 g vertical or greater isOperating Basis Earthquake (OBE) threshold and its annunciated through the system's network control centerclassification timeliness. If the OBE threshold (vertical) is (NCC), following seismic trigger actuation by at least twonot recognized in a timely fashion from indications in, or accelerographs (vertical switch settings are 2/3 of thenear, the Control Room, then explain why the alternative respective horizontal switch settings). Therefore exceeding12 HU2.1 EAL was not developed in accordance with NEI 99-01, either the horizontal or vertical OBE thresholds actuates theRevision 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 OBEalarm is received based on exceeding either acceleration.Page 5 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGEMCGU IRE NUCLEAR STATION. UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370RAI # SECTION!/usinMSRsosMNS- EALQusinMSRpoePlease explain why there was no EAL developed, possibly There is no site-specific lake level threat that is notas HU3.5, for ultimate heat sink (i.e., lake level) level adequately addressed through other Hazard and/or Systemissues, or revise accordingly. Malfunction EALs. High lake level is adequately addressedby HU3.4. Loss of heat sink is adequately addressed byCU3.I.13 HU3.5For EALs HU4.1 and HU4.2, the areas listed in Table H-I Table H-I Fire Areas are based on MCS-1465.00-00-0022seem to be vague or too all-encompassing. Please explain Design Basis Specification for the Appendix R Safeif 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 functionsdown, and if these areas can be fine-tuned to limit and systems required for safe operation, shutdown andconsideration for these EALs, or revise accordingly. cooldown of the plant (SAFETY SYSTEMS).A balance must be established between defining major plant14 HU4.1 structures containing safe shutdown equipment as fire areasHU4.2 versus a detailed list of areas for every safety systemcomponent location. The Table H-i list of fire areas achievesthat balance in support of timely and accurate emergencyclassification 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 CHANGEMCGU IRE NUCLEAR STATION. UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370RAI # SECTIONI/usinMSRsosMNS- EALQusinMSRpoeFor EALs HU4.3 and HU4.4, please confirm that the The MNS ISESI is contained wholly within the plant ProtectedIndependent Spent Fuel Storage Installation (ISESI) would Area. Therefore the ISFSI would be applicable to EALsbe an area applicable to these EALs, or revise accordingly. HU4.3 and HU4.4 for fires within the plant Protected Area.HU4.315HU4.4For EAL HA5.1, please note in the MNS Basis that this EAL The following note was added to the HA5.1 bases to ensureis typically applicable in all operating modes, but is limited HA5.1 mode applicability remains in alignment withto 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 themodified 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 operatingPlease explain what process is in place which ensures that poeueo ln ofgrto hneteapialfutue plnt hangs ar cosideed fr oher hanplant modes specified in Table H-2 are changed,a16 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 HA5mode applicability is required."AD-LS-ALL-0007, Applicability Determination Process andAD-EG-ALL-1 132, Preparation and Control of Design Changeand Engineering Changes provide for review of changes thatcould affect the emergency plan and or Station Emergency______________ ________________________________________PreparednessPage 7 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGEMCGU IRE NUCLEAR STATION, UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370RAI # SECTION/QusinMSRpoeMNS- EALQusinMSRpoeFor 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 applicablenot incorporated, or revise accordingly. modes for each of the listed safety function as follows:'An event has resulted in plant control being transferredfrom the Control Room to the Auxiliary Shutdown Panels or17 HS6.1 Standby Shutdown Facility (SSF)ANDControl of any of the following key safety functions is notreestablished 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 the18 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 EInstallation (ISFSI) guidance, the statement: "Formal offsite introductionplanning is not required because the postulated worst-case "Formal offsite planning is not required because theaccident involving an ISFSI has insignificant consequences postulated worst-case accident involving an ISFSI hasto the public health and safety," is not applicable to this19 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 plantthat EALs HU1 and HA1 are also considered for events that Protected Area. Therefore a security event related to theoccur 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 CHANGEMCGUIRE NUCLEAR STATION. UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370RAI # SECTIONI/usinMSRsosMNS- EALQusinNSRpoeUnder 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. Please20 Bases either revise to what has actually been endorsed, or(depending on the response to RAI-03), unify the basissections into one.For Fuel Clad Barrier Potential Loss 2 and Reactor Coolant The plant-specific bases was added to support interpretationSystem Potential Loss 1, please provide further justification of the words "...and heat sink is required" added to the FPBas to why the Heat Sink Red language was added to the potential loss thresholds related to Heat Sink CSFST redPlant-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 accidentFC caveat to declaration, or revise accordingly. conditions during which operators intentionally reduce thePotential heat removal capability of the steam generators; duringLoss 2 these conditions, classification using threshold is not21 RSwarranted"Potential The added bases also supports the condition where, due to aLoss 1 large break LOCA with RCS pressure less than SG pressure,heat sink is not required even though heat sink red pathconditions exist.In both instances the determination is quickly made that heatsink is not required upon entry into FR-H.1 Response to Lossof Secondary Heat Sink.Page 9 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL ('EAL') SCHEME CHANGEMCGU IRE NUCLEAR STATION, UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370Attachment ASummary of EAL Changes NOT Associated with RAI ResponsesThe table below summarizes changes that have been introduced to the EAL submittal documentation for reasons other than the responses to theNRC RAIs.EAL Tech Basis#Change? DescriptionSA9.1 Yes MNS Reference #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 offsitenotification process.HA1.1 Yes Split EAL HA1.1 into two separate EALs: HA1.1 and HA1.2 to better support the offsite notificationprocess.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/gmPage 10 of 10 S DUKESteven D. CappsVice PresidentENERGY McGuire Nuclear StationMG01VP 1 12700 Hagers Ferry RoadHuntersville, NC 28078o: 980.875.4805f- 980.875.4809Steven.Capps@duke-energy.com10 CFR 50.9010 CFR 50 Appendix EFebruary 18, 2016MNS-1 6-016U.S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, D.C. 20555-0001Duke Energy Carolinas, LLC (Duke Energy)McGuire Nuclear Station Units 1 and 2Docket Nos. 50-369, 50-370Renewed License Nos. NPF-9 and NPF-17

Subject:

Response to Request for Additional Information Regarding the License AmendmentRequest (LAR) to Change the McGuire Nuclear Station (MNS) Emergency Plan toUpgrade MNS Emergency Action Levels Based on NEI 99-01, Revision 6By letter dated May 7, 2015 (Agencywide Documents Access and Management System(ADAMS) Accession No. ML1 5141 A047), Duke Energy requested approval of a proposedchange to the Emergency Action Levels (EALs) used at McGuire Nuclear Station (MNS). DukeEnergy proposes to revise their current MNS EAL scheme to one based upon Nuclear EnergyInstitute (NEI) document NEI 99-01, "Development of Emergency Action Levels for Non-PassiveReactors," Revision 6 (ADAMS Accession No. ML12326A805).The NRC staff reviewed the request and determined that additional information is needed tocomplete 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 informationand additional changes identified during the RAl process which were deemed necessary.Enclosure 2 provides the MNS redline version of the revised Emergency Action Level TechnicalBases Document. Enclosure 3 provides the MNS final (clean) version of the Emergency ActionLevel 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 providedto the designated North Carolina State Officials.

United States Nuclear Regulatory CommissionFebruary 18, 2016Page 2If 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 onFebruary 18, 2016.Steven D. Capps

Enclosures:

Enclosure 1 -Response to Request for Additional InformationEnclosure 2 -MNS Emergency Action Level Technical Bases Document RedlineEnclosure 3 -MNS Emergency Action Level Technical Bases Document Final United States Nuclear Regulatory CommissionFebruary 18, 2016Page 3xc:C. Haney, Region II AdministratorU.S. Nuclear Regulatory CommissionMarquis One Tower245 Peachtree Center Avenue NE, Suite 1200Atlanta, Georgia 30303-1257G. E. Miller, Project ManagerU.S. Nuclear Regulatory Commission11555 Rockville PikeMail Stop 8 G9ARockville, MD 20852-2738J. ZeilerNRC Senior Resident InspectorMcGuire Nuclear StationW.L. Cox Ill, Section ChiefNorth Carolina Department of Environment and Natural ResourcesDivision of Environmental HealthRadiation Protection Section1645 Mail Service CenterRaleigh. NC 27699-1 645 ENCLOSURE 1MNS RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGEMCGUIRE NUCLEAR STATION, UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370RAI # SECTION/ usinMSRsosMNS- EALQesinNSepoeSection 4.3, "Instrumentation Used for EALs," to NEI 99-01, MNS has confirmed that all setpoints and indications usedRevision 6, states (in part): "Scheme developers should in the proposed EAL scheme are within the calibratedensure that specific values used as EAL setpoints are range(s) of the stated instrumentation and that thewithin the calibrated range of the referenced resolution of the instrumentation is appropriate for the4.3 instrumentation." Please confirm that all setpoints and setpoint/indication.indications used in the proposed EAL scheme are withinthe calibrated range(s) of the stated instrumentation andthat the resolution of the instrumentation is appropriate forthe setpoint/indication.Section 2.5, "Technical Bases Information, "states: "A The MNS site specific and NEI 99-01 generic bases sectionsPlant-specific basis section that provides MNS-relevant have been combined into a single bases section for eachinformation concerning the EAL. This is followed by a EAL. Section 2.5 "Technical Bases Information" has beenGeneric 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 informationappears to be inconsistent, please justify why the rational2 GENERALfor two sections when it is acceptable to just have onebasis section that is specific to the plant, or reviseaccordingly to eliminate potential confusion by user.Page 2 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ('RAI)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGEMCGUIRE NUCLEAR STATION, UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370RAI # SECTION!/usinMSRsosMNS- EALQusinMSRpoeSection 5.0, "Definitions," does not include definitions for The following definitions have been added to Section 5.1the 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, orrevise to incorporate these definitions consistent with NEI99-01, 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-3RGI.2 RG1.2-NOTE-3For 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 dry5 A22 NEI 99-01, as it is germane to this particular EAL. Please storage up to the point that the loaded storage cask isRA2.2 explain why this information was omitted, or revise sae.Oc eld aaet oddcs asnaccordingly. 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 CHANGEMCGUIRE NUCLEAR STATION, UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370RAI # SECTION/ usinMSRsosMNS- EALQusinMSRpoeFor EAL RU1 .2 and PAl .3, please explain why RU1 .2 uses The MNS Selected License Commitments (SLC) specifyRUI1.2 the term "Selected Licensee Commitment (SLC)," while release rate limits per license commitments. The Offsite6 RA1 .3 uses "Offsite Dose Calculation Manual (ODCM)." Dose Calculation Manual (ODCM) provides the methodologyRAl .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 inC~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 TankCS 1.1* PRT -Pressurizer Relief TankCG1.1

• CFAE -Containment Floor and Equipment sump7* ND/NS -RHR/Containment Spray Sump* RHT -Recycle Holdup Tank* WDT- Waste Drain Tank* WEFT -Waste Evaporator Feed Tank* SRST -Spent Resin Storage TankPlease provide further detail as to why CS1 .1 and CSI1.2 Although the current NUMARC/NESP-007 Rev. 2 basedfrom NEI 99-01, Revision 6, cannot be adequately EALs provide thresholds utilizing NCS narrow range waterdeveloped. A review of the current MNS EAL scheme level below the bottom of the hot leg, the design andshows that, while limited, MNS does have NCS water level operation of the MNS water level instrumentation is such that8 CS 1 monitoring capability. Please justify the removal of these the "site-specific level" (6" below the bottom ID of the NCSCS1 .2 EALs from the proposed MNS EAL scheme, or revise loop and top of fuel) cannot be determined at any time duringaccordingly. Cold Shutdown or Refueling modes because the RVLISinstrumentation is not available at all times during thesemodes. 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 CHANGEMCGUIRE NUCLEAR STATION, UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370RAI #* SECTION!/usinMSRsosMNS- EALQusinMSRpoeFor EALs CA2.1, SS1.1 and SGI1.2, please explain Deleted reference to Table C-2/S-1 AC power source tablesC21 inclusion of the table and basis language related to the from CA2.1, SSI.1 and SG1.2. Revised associated bases to10 S51.1 Standby Shutdown Diesel Generator, or revise accordingly, credit the Standby Shutdown Diesel Generator only if alignedSI2 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 indicationtemperature indication is absent. If this is an accurate cue ytels fdcyha eoa aaiiy11 CA3.1 statement, then please explain why this is not provided as a classification should be based on the NCS pressureNOTE for the EAL, or revise accordingly. increase criteria when in Mode 5 or based on time to boildata when in Mode 6"For EAL HU2.1, please explain in further detail the process Immediate control room alarm indication of an earthquake ofused to determine if the seismic activity has exceeded the either 0.08 g horizontal or 0.053 g vertical or greater isOperating Basis Earthquake (OBE) threshold and its annunciated through the system's network control centerclassification timeliness. If the OBE threshold (vertical) is (NCC), following seismic trigger actuation by at least twonot recognized in a timely fashion from indications in, or accelerographs (vertical switch settings are 2/3 of thenear, the Control Room, then explain why the alternative respective horizontal switch settings). Therefore exceeding12 HU2.1 EAL was not developed in accordance with NEI 99-01, either the horizontal or vertical OBE thresholds actuates theRevision 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 OBEalarm is received based on exceeding either acceleration.Page 5 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGEMCGU IRE NUCLEAR STATION. UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370RAI # SECTION!/usinMSRsosMNS- EALQusinMSRpoePlease explain why there was no EAL developed, possibly There is no site-specific lake level threat that is notas HU3.5, for ultimate heat sink (i.e., lake level) level adequately addressed through other Hazard and/or Systemissues, or revise accordingly. Malfunction EALs. High lake level is adequately addressedby HU3.4. Loss of heat sink is adequately addressed byCU3.I.13 HU3.5For EALs HU4.1 and HU4.2, the areas listed in Table H-I Table H-I Fire Areas are based on MCS-1465.00-00-0022seem to be vague or too all-encompassing. Please explain Design Basis Specification for the Appendix R Safeif 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 functionsdown, and if these areas can be fine-tuned to limit and systems required for safe operation, shutdown andconsideration for these EALs, or revise accordingly. cooldown of the plant (SAFETY SYSTEMS).A balance must be established between defining major plant14 HU4.1 structures containing safe shutdown equipment as fire areasHU4.2 versus a detailed list of areas for every safety systemcomponent location. The Table H-i list of fire areas achievesthat balance in support of timely and accurate emergencyclassification 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 CHANGEMCGU IRE NUCLEAR STATION. UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370RAI # SECTIONI/usinMSRsosMNS- EALQusinMSRpoeFor EALs HU4.3 and HU4.4, please confirm that the The MNS ISESI is contained wholly within the plant ProtectedIndependent Spent Fuel Storage Installation (ISESI) would Area. Therefore the ISFSI would be applicable to EALsbe an area applicable to these EALs, or revise accordingly. HU4.3 and HU4.4 for fires within the plant Protected Area.HU4.315HU4.4For EAL HA5.1, please note in the MNS Basis that this EAL The following note was added to the HA5.1 bases to ensureis typically applicable in all operating modes, but is limited HA5.1 mode applicability remains in alignment withto 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 themodified 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 operatingPlease explain what process is in place which ensures that poeueo ln ofgrto hneteapialfutue plnt hangs ar cosideed fr oher hanplant modes specified in Table H-2 are changed,a16 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 HA5mode applicability is required."AD-LS-ALL-0007, Applicability Determination Process andAD-EG-ALL-1 132, Preparation and Control of Design Changeand Engineering Changes provide for review of changes thatcould affect the emergency plan and or Station Emergency______________ ________________________________________PreparednessPage 7 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL ('EAL) SCHEME CHANGEMCGU IRE NUCLEAR STATION, UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370RAI # SECTION/QusinMSRpoeMNS- EALQusinMSRpoeFor 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 applicablenot incorporated, or revise accordingly. modes for each of the listed safety function as follows:'An event has resulted in plant control being transferredfrom the Control Room to the Auxiliary Shutdown Panels or17 HS6.1 Standby Shutdown Facility (SSF)ANDControl of any of the following key safety functions is notreestablished 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 the18 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 EInstallation (ISFSI) guidance, the statement: "Formal offsite introductionplanning is not required because the postulated worst-case "Formal offsite planning is not required because theaccident involving an ISFSI has insignificant consequences postulated worst-case accident involving an ISFSI hasto the public health and safety," is not applicable to this19 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 plantthat EALs HU1 and HA1 are also considered for events that Protected Area. Therefore a security event related to theoccur 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 CHANGEMCGUIRE NUCLEAR STATION. UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370RAI # SECTIONI/usinMSRsosMNS- EALQusinNSRpoeUnder 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. Please20 Bases either revise to what has actually been endorsed, or(depending on the response to RAI-03), unify the basissections into one.For Fuel Clad Barrier Potential Loss 2 and Reactor Coolant The plant-specific bases was added to support interpretationSystem Potential Loss 1, please provide further justification of the words "...and heat sink is required" added to the FPBas to why the Heat Sink Red language was added to the potential loss thresholds related to Heat Sink CSFST redPlant-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 accidentFC caveat to declaration, or revise accordingly. conditions during which operators intentionally reduce thePotential heat removal capability of the steam generators; duringLoss 2 these conditions, classification using threshold is not21 RSwarranted"Potential The added bases also supports the condition where, due to aLoss 1 large break LOCA with RCS pressure less than SG pressure,heat sink is not required even though heat sink red pathconditions exist.In both instances the determination is quickly made that heatsink is not required upon entry into FR-H.1 Response to Lossof Secondary Heat Sink.Page 9 of 10 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)EMERGENCY ACTION LEVEL ('EAL') SCHEME CHANGEMCGU IRE NUCLEAR STATION, UNITS 1 AND 2DOCKET NO'S. 50-396 AND 50-370Attachment ASummary of EAL Changes NOT Associated with RAI ResponsesThe table below summarizes changes that have been introduced to the EAL submittal documentation for reasons other than the responses to theNRC RAIs.EAL Tech Basis#Change? DescriptionSA9.1 Yes MNS Reference #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 offsitenotification process.HA1.1 Yes Split EAL HA1.1 into two separate EALs: HA1.1 and HA1.2 to better support the offsite notificationprocess.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/gmPage 10 of 10