ML112070459

Columbia Generating Station - Draft Request for Additional Information EAL Upgrade

ML112070459
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/DLPM, 415-1476
Shared Package
ML112070405	List: ML112070415 ML112070426 ML112070459
References
TAC ME4589
Download: ML112070459 (2)

Text

Columbia Generating Station U.S. Nuclear Regulatory Commission Request for Additional Information (RAI) Emergency Action Level Scheme Change to NEI 99-01, Revision 5 Format DRAFT RAI # EAL Question 1 General Due to recurring issues within the industry, please confirm that all stated values, set points, and indications provided are within the calibrated range of the applicable instrumentation and that the instrumentation is appropriate for the specific EAL.

2 General Please provide documentation on the two new 618-11 site-specific Emergency Action Levels that were approved for addition to the site emergency plan as outlined in License Amendment No.218 in response to the licensee's application dated April 28, 2010.

3 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 per endorsed guidance.

4 RU2.1 Initiating Condition lists "Unexpected rise in plant radiation" which is inconsistent with the endorsed guidance that lists this Initiating Condition as "Unplanned rise in plant radiation". Please provide justification for this inconsistency, or revise accordingly per endorsed guidance.

5 RU2.2 Initiating Condition in Technical Bases document lists "Unexpected rise in plant radiation" which is inconsistent with the endorsed guidance that lists this Initiating Condition as "Unplanned rise in plant radiation". Please provide justification for this inconsistency, or revise accordingly per endorsed guidance.

6 CG3.2 Emergency Action Level lists "Any unexplained RPV leakage indication, Table C-1 which is inconsistent with the endorsed guidance that lists this EAL as "Unplanned level rise in" (site specific sump or tank). Please provide justification for this inconsistency, or revise accordingly per endorsed guidance.

7 EU1.1 The Emergency Action Level states, "Multi Purpose Container (MPC) CONFINEMENT BOUNDRY 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 per endorsed guidance.

Columbia Generating Station U.S. Nuclear Regulatory Commission Request for Additional Information (RAI) Emergency Action Level Scheme Change to NEI 99-01, Revision 5 Format DRAFT 8 CU5.1 SU6.1 Clarify if Table C-4/S-2, Communications Systems, includes the Health Physics Network, communication systems as required by the endorsed guidance.

9 HU1.4 HU2.1 HA1.2 HA1.4 HA1.3 HA1.5 HA2.1 HA3.1 Table H-1 uses the term "in vicinity of" associated with the referenced structures which is inconsistent with endorsed guidance. Please provide justification for this inconsistency, or revise accordingly per endorsed guidance.

10 SU8.1 Clarify the process / instrumentation used to perform the calculation to subtract reactor building closed cooling water from the unidentified leakage total and the timeliness of this process.

11 IC HA4 EAL HA4.1 The Initiating Condition uses the term "Security Defined Owner Controlled Area" which is inconsistent with the endorsed guidance. Please provide justification for this inconsistency, or revise accordingly per endorsed guidance.

12 Fission Product Barrier Matrix 1. Fuel Clad Barrier L.1 lists "PC flooding required (SAG entry) due to either:" which is inconsistent with the endorsed guidance. Please provide justification for this inconsistency, or revise accordingly per endorsed guidance

2. Containment Barrier PL.1 lists "PC flooding required (SAG entry) due to either:" and lists two entry requirements which is inconsistent with the endorsed guidance. Please provide justification for this inconsistency, or revise accordingly per endorsed guidance.

3. Containment Barrier L.3 removed the endorsed guidance wording "after primary containment isolation signal" which is inconsistent with the endorsed guidance. Please provide justification for this inconsistency, or revise accordingly per endorsed guidance.