ML20216J499
| ML20216J499 | |
| Person / Time | |
|---|---|
| Issue date: | 03/13/1998 |
| From: | Zalcman B NRC (Affiliation Not Assigned) |
| To: | Alexis Nelson NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| NUDOCS 9803230464 | |
| Download: ML20216J499 (17) | |
Text
1 March 13, 1998 i '
l Al:n Nelson Nucle r Energy Institut) l 1776 Eye Street, NW, Suite 400 l Washington, DC 20006-3708
Dear Mr. Nelson:
In a letter dated September 16,1997, Nuclear Energy Institute (NEI) requested NRC endorse NEl 97-03, Draft Final Rev. 3, " Methodology for Development of Emergency Action Levels."
NEl 97-03 was developed to enhance the EAL guidance in NUMARC/NESP-007, Rev. 2 by 4 providing additional EALs for classifying emergency initiated in the shutdown mode of j operation. In addition, NEl 97-003 addresses a number of issues which where identified during j
( the industry's use of NUMARC/NESP-007 to develop site-specific EALs. Furthermore, NEl 97- 4 l 03 addresses some of the issues identified during the NRC's review of site-specific EALs developed in accordance with the NUMARC guidance which were forwarded to NEl in a letter '
dated April 4,1996.
We have completed our initial review and have identified a number of issues which need to be !
resolved before we can proceed to endorse this document (attached). We have arranged a meeting with NEl on March 24 and 25,1998 to facilitate resolution of these issues. We recognize NEl's leadership in developing EAL guidance which incorporates lessons learned through experience with actual events, industry implementation of the NUMARC guidance, and, in particular, EALs addressirg the shutdown mode of operation. In light of the industry's effort, we have suspended our efforts to develop shutdown EALs and may terminate them if we endorse the industry guidance.
If you have any questions on these comments, please contact Jim O'Brien at 301-415-2919.
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.Silicereipr Original signed by: -
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Edwin Fox for:
B(ry Zaleman, Acting Chief , I Emergene)rPfe'pafiRmeTs~iind Environmental , (
Health Physics Section i Office of Nuclear Reactor Regulation -
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Attachment : Comments on NEl 97-03, Draft Final Rev. 3, August 1997 DISTRIBUTION -
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Docket File 1OI l PUBLIC EP&EHPS Staff (w/o enclosures)
PERB Reading File V 91/n#)Vdl ;
l CLMiller RHasselberg AMohseni )
l JOBrien PWen BZeleman I SRoudier TEssig g[ph l I
.,. 10 OFFICE PERB:NRR PERB:NRR PERB NRR J NAME JO'Bria[h SRo h h BZaled DATE 03// / /98 03//h /9[ 03/ [f /98 9803230464 980313 #
i March 13, 1998 {
Al;:n N;ison Nuclear Energy Institute 1776 Eye Street, NW, Suite 400 Washinglon, DC 20006-3708
Dear Mr. Nelson:
In a letter dated September 16,1997, Nuclear Energy Institute (NEI) requested NRC endorse i NEl 97-03, Draft Final Rev. 3, " Methodology for Development of Emergency Action Levels." l NEl 97-03 was developed to enhance the EAL guidance in NUMARC/NESP-007, Rev. 2 by l providing additional EALs for classifying emergency initiated in the shutdown mode of operation. In addition, NEl 97-003 addresses a number of issues which where identified during the industry's use of NUMARC/NESP-007 to develop site-specific EALs. Furthermore, NEl 97- 1 03 addresses some of the issues identified during the NRC's review of site-specific EALs developed in accordance with the NUMARC guidance which were forwarded to NEl in a letter dated April 4,1996.
We have completed our initial review and have identified a number of issues which need to be resolved before we can proceed to endorse this document (attached). We have arranged a l meeting with NEl on March 24 and 25,1998 to facilitate resolution of these issues. We l recognize NEl's leadership in developing EAL guidance which incorporates lessons learned l through experience with actual events, industry implementation of the NUMARC guidance, and, l in particular, EALs addressing the shutdown mode of operation. In light of the industry's effort, l we have suspended our efforts to develop shutdown EALs and may terminate them if we endorse the industry guidance.
4 If you have any questions on these comments, please contact Jim O'Brien at 301-415-2919.
1 Sirfcerel9r Original signed by:
Edwin Fox for:
Bh(ry Zalcman, Acting Chief Emergency-PfeparednEs~iind Environmental Health Physics Section Office of Nuclear Reactor Regulation Attachment : Comnients on NEl 97-03, Draft Final Rev. 3, August 1997 l
DISTRIBUTION 1 Doci:et File PUBLIC PERB Reading File j EP&EHPS Staff (w/o enclosures) l CLMiller RHasselberg AMohseni JOBrien PWen BZaleman SRoudier TEssig i OFFICE PERB:NRR PERB:NRR PERB;NRR J NAME JO'Bridh SRo h h BZalctfi[n DATE 03// Y /98 03//h /9[ 03/ /J /98 l I
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,t NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2066H001 I
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% # March 13, 1998 Alan Nelson Nuclear Energy Institute 1776 Eye Street, NW, Suite 400 Washington, DC 20006-3708 l
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Dear Mr. Nelson:
In a letter dated September 16,1997, Nuclear Energy Institute (NEI) requested NRC endorse NEl 97-03, Draft Final Rev. 3, " Methodology for Development of Emergency Action Levels." ;
NEl 97-03 was developed to enhance the EAL guidance in NUMARC/NESP-007, Rev. 2 by ;
providing additional EALs for classifying emergency initiated in the shutdown mode of ,
operation. In addition, NEl 97-003 addresses a number of issues which where identified during l the industry's use of NUMARC/NESP-007 to develop site-specific EALs. Furthermore, NEl 97- l 03 addresses some of the issues identified during the NRC's review of site-specific EALs developed in accordance with the NUMARC guidance which were forwarded to NEl in a letter dated April 4,1996.
l We have completed our initial review and have identified a number of issues which need to be ;
resolved before we can proceed to endorse this document (attached). We have arranged a i meeting with NEl on March 24 and 25,1998 to facilitate resolution of these issues. We !
recognize NEl's leadership in developing EAL guidance which incorporates lessons teamed 4 through experience with actual events, industry implementation of the NUMARC guidance, and, l in particular, EALs addressing the shutdown mode of operation. In light of the industry's effort, j we have suspended our efforts to develop shutdown EALs and may terminate them if we endorse the industry guidance.
If you have any questions on these comments, please contact Jim O'Brien at 301-415-2919.
Sincerely, I
^1 BayZ ma c n Chief Emet repare ness and Environmental i Health Physics Section Office of Nuclear Reactor Regulation Attachment : Comments on NEl 97-03, j Draft Final Rev. 3, August 1997 l
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l REVIEW OF NEl EAL GUIDANCE DOCUMENT NEl 97-03. Draft Final Rev. 3. August 1997 l A number of issues have been identified during the review of NEl 97-03. These issues are grouped in the following categories:
Issues related to emergency action levels (EALs) modified and developed to address classifying events in the shutdown mode of operation- 1
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lssues related to other modifications made to NUMARC/NESP-007; l
+ f lssues related to the current version of NUMARC/NESP-007; {
Although our review has been focused on the changes to NUMARC/NESP-007, we have provided comments on the entire NEl 97-03 document where experience gained since NUMARC/NESP-007 was endorsed has indicated that improvements can be made. The comments on the existing NUMARC document should not be construed as affecting NRC's )
endorsement of the NUMARC document which was provided through Regulatory Guide 1.101, {
Rev. 3. )
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. 1 ISSUES ON NEW AND MODIFIED SHUTDOWN EALE 1.1 General The concept of the combination of the losses of functions adds complexity to the EAL scheme. Currently, the NUMARC guidance contains three basic types of EALs: 1) symptom based,2) event based and 3) fission product barrier based.
In addition, there are two " function" EALs', i.e., loss of cold shutdown function and lo >s of hot shutdown function. These types of EAls are also included in the i NUREG-0654 EAL guidance. The NUMARC EAL guidance refined the concept of the use of combination of the barrier loss or potentiallosses to classify events at the Site Area Emergency or Geraral Emergency classification levels.
(NUREG-0654 had this concept for the General Emergency classification level only).
,' The proposed revision of NUMARC/NESP-007 introduces a new concept of classifying events based upon combinations of the loss of functions. However, two of these functions, i.e., Containment Closure and Reactor Coolant System
'These loss of function EALs can be viewed as event based EALs, i.e., an event caused the lo:s of function.
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(RCS) Integrity can be equated to loss of the Containment and RCS barriers.
l The other two functions, i.e., RCS inventory and Heat Removal can be equated l to the potentialloss of the fuel clad barrier. Therefore an equivalent classification scheme (at the Alert and higher classification levels) to that specified in NEl 97-03 is:
Unusual Event Alert Site Area Emergency General Emergency Potential loss of Potentialloss of fuel clad Potentialloss of Fuel fuel clad barrier and (a or b) clad barrier and (a and b)
- a. Loss of Containment Barrier a. Loss of Containment Barrier
- b. Loss of RCS Barrier
- b. Loss of RCS Barrier This would then be correlated with EALs which are equivalent to the " loss and potential loss of function EALs" specified in the NEl, e.g., the potentialloss of fuel clad would be indicated by:
BWRs: RPV Level below top of active fuel PWRs: RPV Level below top of active fuel Core Exit Thermocouples above (site-specific) value in addition containment radiation alarms could be used as an indication of the loss of fuel clad, in particular in cases when the vessel water level is not available.
These barrier-based EALs can then be supplemented by event type EALs, such as:
UnuiuaLEvaa.L
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Loss of RPV Level (equivalent to RCS potentialloss in NEl 97-03);
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Loss of Heat removal (equivalent to heat removal potential loss in NEl 97-03).
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Significant loss of RPV level (equivalent to RCS loss in NEl 97-03);
Significant loss of heat removal (equivalent to RCS potential loss in NEl fs7-03).,
1.2 Page S-C-1, Note #1 What is intended by the statement "can no longer be reliably performed" under Note #17 2
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1.3 Page 5-C-4, line 4-5 is the statement "the maximum cladding temperature should be at close to the boiling point of water"in the basis document accurate?
1.4 Page 5-C-5, Tabla C-1, RCS Inventory The EAL for the potential loss of RCS is:
RPV Level Continuing to Decrease After Initiation of Avaliable RCS Makeup Capability It is not clear how long a classifier may wait before initiating the makeup. It may be more appropriate to specify a time limit, e.g., " Unplanned RPV Level decrease continuing for greater than 15 minutes."
The EAL for the loss of RCS inventory is:
1 RPV Level Cannot be Restored to Greater than the Top of Active Fuel it seems that the setpoint should be set at a level higher than top of active fuel. Water level below the top of active fuel is more indicative of a loss of heat removal or a potential loss of fuel clad barrier. Setting the water level to a recognizable level above i top of active fuel, for example the low-low ECCS setpoint, will provide for more tirne!y classification of the event. In addition the use of the phrase "cannot be restored . " may rely too much on judgement (and the basis does not prov!de information which would assist in the proper application of judgement in this case).
1.5 Page 5-C-5, Table C-1, Heat Removal The EALs for the loss of heat removal are:
- 2. Functions Needed to Maintain Cold Shutdown Cannot Be restored AND Either(A or B]
A. [ site specific] Indication That RCS Temperature has Increased to Greater Than[200 'F]
B. The Duration of the Function Loss Has Exceeded [ site specific] Time
, to Reach [200 'F) with RCS Temperature Indication Unavailable.
1.5.1 It is not clear how licensees will determine what constitutes " functions needed to maintain cold shutdown." It seems more appropriate to specify the loss of the active heat removal equipment (or function) in conjunction with an ind: cation of the unplanned temperature rise. This will provide less ambiguity.
1.5.2 The first EAL under the heat removal heading and the second EAL do not appear to indicate the same level of threat to the safety of the plant.
1.5.3 It may be appropriate to specify a time to restore cooling to decrease RCS temperature. This may alleviate concerns that increasing temperature above 200 *F is not an appropriate indication of the potential substantial degradation in the level of safety of the plant. l 1.6 Containment Closure: pg 5-C-6, lines 7-11 NEl 97-03 document states:
In the context of these EALs, " containment closure"is the action taken to secure primary containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions.
The secondary containment should not be used to meet containment closure, as used here, since the standbf gas treatment system willnot remove the noble gases released during the event.
The statement that secondary containment should not be considered because standby gas treatment system will not remove the nobla gases is inconsistent with the l considering vent via the suppression pool as adequate. It may be more appropriate to have any release from the containment considered, not just direct release in addition, definition of closure should be provided, i.e., is this to mean containment integrity as defined by technical specification?
1.7 Page 5-C-7,line 49 in the statement under the Loss of Reactor Vessel Level, i.e., "there is not Potential Loss EAL for this furctirsn," it is not clear what function is being referred to.
1.8 Page 5-C-10, Justification of loss of heat removal threshold The LOSS of RCS Inventory in Table C-2 is:
l Reactor Vessel Level Cannot be Restored to Greater than the Bottom (ID) of the RCS Loop i
The LOSS of Heat Removalin Table C-2 is:
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. Loss of Reactor Vessel LevelIndicated by (1 or 2):
l A. [ site specific] Indication That Core WillBe Uncovered.
it is not clear why this loss of heat removal is appropriate. Wou!d a higher level, such as the bottom ID of the RCS loop, be more appropriate?
In addition, consider whether replacing ' UNPLANNED Loss of Function Needed to Maintain Cold Shutdown AND either(A or B)' by ' UNPLANNED Loss of any Function l Needed to Maintain Ccid Shutdown indicated by either (A or B)' in order to adhere to the description given in the basis P. 5-C-13, line 31 through 39.
1.9 !
inconsistent heat removal EALs for PWRs and BWRs EAL 2 under the LOSS of Heat Removalin Table C-2 is:
UNPLANNED Loss of Function Needed to Maintain Cold Shutdown indicated by:
A. [ site specific] Indication That RCS Temperature Has increased More than 10 'F and Exceeds [200 'F]
It is no'. clear why this EAL is different from the EAL for the Loss of Heat Removal under the BWR matrix.
1.10 Page 5-C-12, line 1-3 The basis document includes the following statement:
l NRC analyses show that certain sequences can result in severe com damage within an hour after the Heat Removal function is lost.
Please cite the NRC reference.
1.11 Page 5-C-12, line 15-17 i
The basis document includes the following statement:
This EAL is not applicable to decreases in flooded reactor cavity level until such time as the level decreases to the level of the vessel flange.
It is not clear wnether this caveat is appropriate and how it may be applied.
1.12 Page 5-C-12, line 30-32 The basis document includes the following statement:
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m NRC analyses show that specific event sequences can result in core uncovery in 15 to 20 minutes and severe core damage within an hour following a loss of the Heat Removalfunction.
Please cite the NRC reference.
1.13 Page 5-C-1, Vogtle incident Please describe how the Vogtle incident that occurred March 20, .1990 (Loss of Vital AC Power and Residual Heat Removal System During Mid-Loop Operations at Vogtle Unit 1, NUREG-1410) would be classified using the new shutdown EALs. The Vogtle incident, among other things, triggered NRC's attention toward enhancing appropriate classification of events that can occur during cold shutdown.
1.14 Page 5-C-1,5-C-5, and 5-C-10 Tables C, C-1 and C-2 indicate that Site Area Emergency should be declared if loss of any three of the following four functions occur: Containment Closure, RCS Integrity, RCS Inventory, Heat Removal. General Emergency being declared only if all four functions are lost. However, according to your document, losing the three following functions, Containment Closure, RCS Integrity, and Heat Removal, could lead to severe core damage and release to the environment within one hour (as indicated page 5-C-12 line 1 and 30 of the document), situation that we believe should deserve a General Emergency classification and not a Site Area Emergency.
Please justify your position on this matter.
1.15 Removal of Loss of Power EALs Please justify the removal of the loss of AC and DC power EALs. Please address why these events are not indicative of an Alert and Unusual Event respectively.
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r 2[ ISSUES ON MODIFICATIONS TO NUMARC/NESP-007 2.1 General
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! The Nuclear Energy institute (NEI) did not provide a succinct list of changes (and justification for the change) from the NUMARC/NESP-007, this list would facilitate NRC's review of NEl 97-03.
i Consider providing such a list.
2.2 5-F 4, line 15-17 NEl document states:
Either the dose equivalent for 2% to 5% clad damage can be used or the calculated clad damage for 300 uCi/gm I equivalent should be included.
It is not clear whether calculating the " clad damage for 300 uCi/gm l equivalent" is an appropriate method for setting this EAL.
2.3 Table 3, P.5-F-2 l' The NEl EAL for the Loss of Containment Barrier based upon reactor vessel water level has been changed: )
l From NUMARC/NESP-007:
PotentialLoss: Reactor vessel water level LESS THAN (site-specific) value and the maximum core uncovery time limit is in the UNSAFE region to NEl-97-03:
Loss: Primary containment flooding required insufficient detail is given in the document to determine whether this change is justified.
Please describe the setpoints which result in entry into primary containment flooding.
l The basis statement for this EAL is not consistent with the EAL. For instance, it states that there is no " loss" EAL associated with this item when in fact the EAL is a loss of containment.
2.4 Page 5-F-5 Potentialloss of RCS based on primary system leakage outside the drywellis determined from site-specific temperature or area radiation alarms low setpoint in the areas of the main steam line tunnel, main turbine generator, RCIC, HPCI, etc., which 7
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, indicate a direct path from the RCS to areas outside primary containment it is not clear how the " radiation alarms low setpoint" is applied in developing EALs and the basis for using the low setpoint versus the high setpoint as specified for the Loss of Containment EAL.
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2.5 Page 5-S-12, SA1 Consider the appropriateness of adding ' Cold Shutdown / Refueling Safety Function I Matrix' after ' Abnormal Rads Levels / Radiological Effluent,' line 32.
2.6 Page 5-S-18, SS1 in order to minimize erroneous classification by the operator, consider cross-referencing SA1 IC in SS1 IC basis and underlining the fact that one applies to Cold Shutdown and Refueling modes (SA1) while 'he other (SS1) applies to Power Operation, Startup, Hot Standby, and Hot Shutdown modes.
2.7 Comments on Appendix A, Pages A.1 - A.8 2.7.1 Page A.5, AU1 and AA1 The intent (guidance provided by) the following statement lines 3 - 11 is not clear:
In typicalpractice, the radiological effluent monitor alarms would have been set, on the basis of ODCM requirements, to indicate a release that could exceed the RETS limits. Alarm response procedures call for an assessment of the alarm to determine whether or not RETS have been l exceeded. Utilities typically have methods for rapidly assessing an abnormal release in order to datermine whether or not the situation is l
reportable under 10 CFR 50.72. Since a radioactivity release of a magnitude comparable to the RETS limits will not create a need for offsite protective measures, it would be reasonable to use these abnormal release assessment methods to optionally screen whether or not a dose
! assessment using actual meteorology and projected source term and
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release duration was necessary.
2.7.2 Page A.5, A.3.2, AU1 and AA1 lines 28 - 39 Consider whether there should there be some discussion of the rationale for the 15 minutes for the rad monitor reading, e.g., is it to provide time for dose assessment 2.7.3 Page A.7, Section A.6, line 30 8
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, , lt is not clear what " annual average y/Q" is being referred to (i.e., is it the sector ,
- annual average X/Q normalized by the time that wind blows into that sector?).
In addition it is not clear what is meant by " normalized" (is it (X/ Q)/(frequency) or (X/Q)*freq?).
I 2.7.4. ' Page A.7, Section A.6 l Is it always the case that'the ODCM alarm setpoint is a given fraction of the i
! ODCM limit?
l 2.7.5 Wording in the SAE Rad monitoring implies not using . aval meteorology. Is this
! the intent?
2.7.6 Page A.7, Section A.6 l
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May it be beneficial to provide' a range of acceptable afternatives? (i.e., is using the sector annual average X/Q acceptable?)
2.7.7 Page A.8, Section A.7, lines 30 - 31 Define what "a reasonable, as opposed to conservative, source term" is. Provide -
numerical examples of the differences based upon some actual plant situations I (and for different 1/NG ratios).
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L lSSUES ON CURRENT REVISION OF NUMARCINESP-007 i
3.1 Page 5-A-2, AU1 EAL 5 under this IC is:
- 5. VALID indication on automatic real-time dose assessment capability l greater than (site-specific value) for 60 minutes orlonger[for sites having l such capability].
1 Does this EAL have the potential for classifying events that are within the ODCM limits?
l 3.2 Page 5-A-4, AU2 Unexpected increaue in Plant Radiation l
- 1. VALO (site-specific) indication of uncontrolled waterlevel decrease in ihr reactor refueling cavity, spent fuelpool, or fuel transfer canal with
'stiirradiated fuel assemblies remaining covered by water.
L lt is not clear whether the EAL is based upon a concern for increasing radiation levels or !
due to a failure in the spent fuel pool, etc. which could lead to fuel damage it may be L more appropriate to separate these EALs out. One concerning increases in radiation 3
j levels without an identified cause and another which specifically concems loss of j refueling water type events. j l in the guidance the use of radiation monitors as a site-specific indication for classifying j
this event is discussed. It is not clear what may be appropriate setpoints. Can you provide examples / guidance. :
i l 3.2.2 EAL 2 under this IC is:
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- 2. VALID (site-specific) radiation reading forirradiated spent fuelin dry storage.
The basis does not provide guidance for determining an appropriate " site-l specific" value for this EAL.
t 3.3 Page 5-A-11, AA3 Damage to Irradiated Fuel or Loss of Water Level that Has or l Will Result in the Uncovering of irradiated Fuel Outside the j Reactor Vessel l
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- 1. A VALID (site-specific) alarm or reading on one or more of the following radiation monitors: (sile-specific monitors) l 10 t
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RefuelFloor Area Radiation Monitor t
Fuel Handling Building Ventilation Monitor Refueling Bridge Area Radiation Monitor Can more guidance be provided as to an appropriate method for establishing these radiation monitor setpoints? (e.g., is 1000 above normal acceptable?)
The basis for this EAL states that:
Increased readings on ventilation monitors may be indication of a radioactivity release from the fuel, confirming that damage has occurred. Increased background at the monitor due to waterlevel decrease may mask increased l Ventilation exhaust airbome activity and needs to be considered. While a radiation monitor could detect an increase in dose rate due to a drop in the water level, it might not be a reliable indication of whetherornot the fuelis covered.
For example, the reading on an area radiation monitorlocated on the refueling
[ bridge may increase due to planned evolutions such as head lift, or even a fuel
[ assembly being raised in the manipulator mast. In particular, using radiation monitor readings of different magnitude to distinguish between IC AU2 and AA3, may not be reliable. Generally, increased radiation monitorindications will need 10 be combined with another indicator (orpersonnel repon) of waterloss.
The last statement regarding combining this indication with another may make an EAL which is difficult to implement. Why would using radiation monitors not
! be reliable?
3.3.2 Consider replacing ' Water level less than (site-specific) feet for' line 19 by ' Water l
level, as indicated by (site-specific) indicators less than (site-specific) feet for' and supplement the basis accordingly.
3.3.3 Consider whether there should be a fuel handling accident or severe loss of spent fuel pool water SAE EAL which escalates the existing AA2 IC. Presently,
( NEl document provides escalation of AA2 via AS1 or AG1, both dealing with offsite dose. The specific AS2 IC leading to the declaration of a SAE could be based on a ' valid reading on one or more of the following radiation monitors (site-specific monitors) that exceeds or is expected to exceed (site-specific) value'.
3.4 Pages 5-F-2 and 5-F-9, Fission Product Barrier Reference Table 3.4.1 Provide guidance regarding the number of Core Exit Thermocouples that should indicate high temperatures (5 thermoccupies in Westinghouse's CSFST methodology).
3.4.2 Explain why (site-soecific) temperature threshold is specified in "3. Core Exit Thermocouple Readings" Fuel Clad Barrier EAL while fixed temperature thresholds (of 1200 F and 700 F) are given in Core Exit Thermocouple Readings 11
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. RCS Barrier EAL. Describe how difference NSSS designs should apply this EAL guidance.
3.5 Page 5-F-16, Containment Barrier Example EALs Consider modifying the following phrase 'In conjunction with the core exit thermocouple EALs in the Fuel and RCS barrier columns' lines 2-3, for there is no exit thermocouple EALs in the RCS barrier column. If there is no exit thermocouple EALs in the RCS barrier column, what EAL in the RCS barrier column will be used to escalate to a General Emergency?
3.6 Fire EAL HA2 Both the NRC and industry have recognized the shortcomings of the present EAL. The primary shortcoming is in the potential to classify non-significant events using this EAL.
Have there been any suggestions for improvements from industry experience with this EAL?
3.7 Page 5-H-2, HU1 Explain why for HU1 IC, the site-specific example EAL ' ice ouild-up affecting the operability of one train of the safety-related cooling system intake' has not been added as suggested by NRC letter April 4,1996.
Add the words 'or high winds greater than (site-specific) mph' line 14, after ' Report by !
plant personnel of tornado' to be consistent with EAL 2 of HA1. Supplement the basis i accordingly. !
1 3.8 Page 5-H-5, HU3 )
Please discuss how HU3 escalates. !
3.9 Page 5-H-6, HU4 i
Consider wether HU4 EAL 1 ' BOMB device discovered within plant PROTECTED AREA and outside plant VITAL AREA'line 13, should be classified as an Alert under HA4.
l Justify the discrepancy between the IC for this EAL and the EAL. This comment also applies to HA4.
Consider adding 'or unusual aircraft activity over facility.'
3.10 Page 5-H.1, Hazards and Other Conditions Affecting Plant Safety Initiating Condition Matrix 12 )
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. 3.10.1 Explain why HA2 IC relates to " Systems Required to Establish or Maintain Safe l
Shutdown" while HA3 IC relates to ' Systems Required to Maintain Safe Operations or Establish or Maintain Cold Shutdown " !
3.10.2 consider shifting the ' Explosion' part of HA2 IC to HA1 IC to be consistent with ,
HU1 and HU2 ICs. HU1 includes an EAL related to Explosion events and HU2 only relates to Fire events.
3.11 Page 5-H-12, HA3 Consider de r'aing or discussing in the basis what is 'a concentration that will affect the safe operation of the plant' stated line 17 (is it the flammable concentration?). '
1 3.12 Page 5-S-1 System Malfunction initiating Condition Matrix Consider adding a new IC: SU9 ' Loss of Offsite and Onsite AC Power for Greater Than 15 Minutes'. The corresponding EAL would be: ' Loss of one of the (site-specific) transformers for greater than 15 minutes AND only one emergency generator is operable.
1 If the above suggestion is considered appropriate, supplement SAS IC basis P. 5-S-17 by mentioning that SAS also serves to escalate SU9.
3.13 Page 5-S-7, SU4 Consider providing additional guidance regarding how this EAL is to be applied when in a mode where technical specification limits do not apply (i.e., cold shutdown and refueling) as it was requested in NRC letter April 4,1996.
3.14 Page 5-S-12, SA1 in order to minimize erroneous classification by the operator, consider cross-referencing SS1 IC in SA1 IC basis and underlining the fact that one applies to Cold Shutdown and Refueling modes (SA1) while the other (SS1) applies to Power Operation, Startup, Hot Standby, and Hot Shutdown modes.
I 3.15 Page 5-S-20, SS3 '
Explain why Cold Shutdown and Refueling modes are not considered for this ' Loss of all vital DC power' IC.
l 3.16 Page 5-S-23, SS6
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Consider providing in the IC basis guidance on the meaning of 'most or all (site-specific) annunciators'line 14, akin to the one provided in SU3 and SA4 IC basis ('Quantification of "Most" is arbitrary, however, it is estimated that approximately 75% of the safety 13 1
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