ML11263A002

Calvert Cliff'S Nuclear Power Plant, Unit No. 1 & 2 - Response to Request for Additional Information Request to Adopt Revised Emergency Action Levels

ML11263A002
Person / Time
Site:	Calvert Cliffs
Issue date:	09/15/2011
From:	Fick M J Constellation Energy Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME5424, TAC ME5425
Download: ML11263A002 (11)

Text

Calvert Cliffs Nuclear Power PlantCENGa joint venture ofOCmnsteliaton 4.9. eDFCALVERT CLIFFSNUCLEAR POWER PLANT1650 Calvert Cliffs ParkwayLusby, Maryland 20657September 15, 2011U. S. Nuclear Regulatory CommissionWashington, DC 20555ATTENTION:

SUBJECT:

Document Control DeskCalvert Cliffs Nuclear Power Plant; Unit Nos. 1 & 2; Docket Nos. 50-317 & 50-318Independent Spent Fuel Storage Installation; Docket No. 72-8Response to Request for Additional Information Re: Request to Adopt RevisedEmergency Action Levels(a) Letter from Mr. M. J. Fick (CCNPP) to Document Control Desk (NRC), datedFebruary 1, 2011, Emergency Action Level Changes(b) Letter from Mr. D. V. Pickett (NRC) to Mr. G. H. Gellrich (CCNPP), datedJuly 14, 2011, Request for Additional Information Re: Request to AdoptRevised Emergency Action Levels -Calvert Cliffs Nuclear Power Plant, UnitNos. 1 and 2 -(TAC Nos. ME5424 and ME5425)

REFERENCES:

In reference (a), Calvert Cliffs Nuclear Power Plant requested Nuclear Regulatory Commission (NRC)approval for the adoption of revised Emergency Action Levels (EALs) for use at Calvert Cliffs NuclearPower Plant in accordance with 10 CFR Part 50, Appendix E. The revised EALs are based on NuclearEnergy Institute (NEI) 99-01, Revision 5. In Reference (b), the NRC requested additional informationconcerning the information submitted in Reference (a). Attachment (1) contains the requested additionalinformation.In addition to the changes described in Attachment (1), another change to the EAL scheme has beenidentified. For EALs HU 1.1 and HA 1.1 the plant-specific bases has been revised to correct the describedseismic instrument actuation setpoint from 0.01 g to 0.02g and note that data evaluation is required.In Reference (a), approval of the EAL scheme change was requested by February 1, 2012 withimplementation within 180 days. We wish to revise the implementation timeframe. Due to scheduledoperator training, we would like to implement the revised EALs no sooner than August 30, 2012.

Document Control DeskSeptember 15, 2011Page 2Therefore, we request an implementation timeframe consistent with implementation after August 30,2012.Should you have questions regarding this matter, please contact me at (410) 495-5216 orMr. Douglas E. Lauver at (410) 495-5219.Very truly yours,Micael J.ckýDirector-Emergency PreparednessMJF/PSF/bjd

Attachment:

(1) Response to Request for Additional Information Re: Request to Adopt RevisedEmergency Action Levelscc: D. V. Pickett, NRC Resident Inspector, NRCW. M. Dean, NRC S. Gray, DNR ATTACHMENT (1)RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RE:REQUEST TO ADOPT REVISED EMERGENCY ACTION LEVELSCalvert Cliffs Nuclear Power Plant, LLCSeptember 15, 2011 ATTACHMENT (1)RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RE: REQUEST TO ADOPTREVISED EMERGENCY ACTION LEVELSBy letter dated February 1, 2011, Constellation Energy Nuclear Group, LLC, (CENG), requested priorapproval of a revised emergency action level (EAL) scheme for Calvert Cliffs Nuclear Power Plant, UnitNos. 1 and 2 (CCNPP).CENG's letter stated that the current CCNPP EAL scheme is based on generic development guidancefrom NEI 99-01, "Methodology for Development of Emergency Action Levels, "Revision 4, dated January2003 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML041470143).Since 1992, numerous enhancements and clarification efforts have been made to the generic EALdevelopment 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 theNuclear Regulatory Commission (NRC) staff by letter dated February 22, 200B (ADAMS Accession No.MLOB0430535).The proposed EAL schemes were developed using the generic development guidance from NEI 99-01,Revision 5 with numerous differences and deviations based upon design criteria applicable to the site aswell as licensee preferences for terminology, format, and other licensee desired modifications to thegeneric EAL scheme provided in NEI 99-01 Revision 5.The NRC staff has determined that the following request for additional information (RAI) is necessary tofacilitate the staff review.NRC RAI 1:Section 1.0, "Purpose," needs to clearly state that the EAL Technical Bases Document is intended toprovide clarification and understanding of how the EALs were developed for CCNPP as well as the intentof each EAL. While the EAL Technical Bases Document supports the technical review of the CCNPPEAL scheme, the document is actually intended to ensure consistent understanding of the EAL scheme forEAL decision makers at CCNPP. The document states that it "may" be usefid in training: however, thisdocument "shall" be used for training purposes. Please ensure this section accurately captures this point.CCNPP Response RAI 1:Section 1.0 of the EAL Technical Bases document has been revised to read:"This document provides an explanation and rationale for each Emergency Action Level (EAL) includedin the EAL Upgrade Project for Calvert Cliffs Nuclear Power Plant (CCNPP). The EAL Technical BasesDocument is intended to provide clarification and understanding of how the EALs were developed forCCNPP as well as the intent of each EAL. This document ensures consistent understanding of the EALscheme for decision makers. It should be used to facilitate review of the CCNPP EALs and providehistorical documentation for future reference. Decision-makers responsible for implementation ofERPLP-3.0 "Immediate Actions Attachment 1, Emergency Action Levels" and the Emergency ActionLevel Matrix, may use this document as a technical reference in support of EAL interpretation. Thisinformation may assist the Emergency Director in making classifications, particularly those involvingjudgment or multiple events. The basis information shall also be used in training, for explaining eventclassifications to off-site officials, and facilitates regulatory review and approval of the classificationscheme."NRC RAI 2:Section 4.0, "Definitions," has the words "... from the Control Room panels" added to the definition for"unisolable" without any justification as to why. Please explain why this was added to the definition orI ATTACHMENT (1)RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RE: REQUEST TO ADOPTREVISED EMERGENCY ACTION LEVELSreturn the definition to the accepted industry standard verbiage as reflected in the latest NRC approvedEAL scheme development guidance.CCNPP Response RAI 2:The definition of "Unisolable" has been revised to be consistent with the generic guidance:"A breach or leak that cannot be promptly isolated."NRC RAI 3:EAL RUI.] and RUI.2: For the site specific EAL development method chosen by CCNPP, pleaseconsider combining these EALs to aid in reducing reader burden and possibly improve the timeliness ofthe declaration. Each EAL refers to the exact same table, for the exact same time duration, and with thesame Note being applicable. The only difference would be the incorporation of the basis information foreach EAL.CCNPP Response RAI 3:Emergency Action Levels RULI.1 and RU1.2 have been combined into a single EAL (RUI.1) thataddresses both gaseous and liquid releases.NRC RAI 4:EAL RAI.] and RA1.2." For the site specific EAL development method chosen by CCNPP, pleaseconsider combining these EALs to aid in reducing reader burden and possibly improve the timeliness ofthe declaration. Each EAL refers to the exact same table, for the exact same time duration, and with thesame Note being applicable. The only difference would be the incorporation of the basis information foreach EAL.CCNPP Response RAI 4:Emergency Action Level RA1.2, addressing liquid effluent monitor indications, has been deleted. Theupper range of the Liquid Discharge Radiation Monitor (RE-2201) is 1.OE+06 cpm. The effluent readingcorresponding to 200 times the Offsite Dose Calculation Manual limit is 8.42E+07 cpm. Therefore, theLiquid Discharge Radiation Monitor is not capable of reading the intended Alert threshold for liquideffluents. Therefore, Emergency Action Level RA1.2 has been deleted and "N/A" has been placed in theAlert column for RE-2201.NRC RAI 5:EAL RA 1.2." Please explain how "off-scale hi" will be differentiatedfrom instrument error and howtimely this determination would be.CCNPP Response RAI 5:The upper range of the Liquid Discharge Radiation Monitor (RE-2201) is 1.OE+06 cpm. The effluentreading corresponding to 200 times the Offsite Dose Calculation Manual limit is 8.42E+07 cpm.Therefore, the Liquid Discharge Radiation Monitor is not capable of reading the intended Alert thresholdfor liquid effluents. Therefore, Emergency Action Level RAI.2 has been deleted and "N/A" has beenplaced in the Alert column for RE-2201.2 ATTACHMENT (1)RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RE: REQUEST TO ADOPTREVISED EMERGENCY ACTION LEVELSNRC RAI 6:EAL RA3.1:a. Please explain why CAS and SAS both need to be on this list. If the site can function adequately withonly CAS (which is the typical industry response) then only CAS needs to be reflected in this EAL.Please explain why both facilities are needed, or revise to reflect CAS or SAS, not both.b. Please explain why you stated "There is no radiation monitoring system at CCNPP for the ControlRoom .... "A review of the Updated Final Safety Analysis Report and previous versions of theCCNPP EAL scheme (ADAMS Accession No. ML021350540) show that instrument O-RI-5350(67),"Control Room Vent," is available for the CCNPP Control Room. Please explain why the ControlRoom does not have radiation monitoring, or correct this EAL. In addition, please explain howCCNPP satisfies General Design Criteria 19, Control Room, from Appendix A of 10 CFR Part 50. Ifthis error is due to an oversight, assuming there is an error, please document in your response tothis RAI that you reviewed and confirmed that no similar oversights exist in this submittal.CCNPP Response RAI 6:a. The SAS was deleted from Emergency Action Level RA3.1.b. Calvert Cliffs does not have installed area radiation monitoring for the Control Room. Thereferenced radiation monitor [0-RI-5350(67)] is the Control Room Ventilation Supply Monitor anddetects particulate and gaseous activity in the Control Room ventilation supply. As described in theCalvert Cliffs UFSAR, this monitor provides a signal to isolate the Control Room ventilation andinitiate the filtration system. This ventilation system response has been evaluated and ensures thatGeneral Design Criteria 19 is satisfied. The referenced radiation monitor does not detect arearadiation levels as specified in the Emergency Action Level threshold. Emergency Action LevelRA3.1 plant-specific bases have been revised to clarify this configuration.NRC RAI 7:EAL CUJ. 1: Please explain why you added "Defueled" as an Operating Mode for this EAL or correct thediscrepancy. You stated that this was an omission from the generic EAL scheme development guidancebut provided nojustification as to why you believe that to be correct.CCNPP Response RAI 7:Emergency Action Level CUI. is anticipatory to a complete loss of vital AC power (CA I.1). TheDefueled mode is already included in Emergency Action Level CA I.I to address loss of Spent Fuel PoolCooling upon a complete loss of vital AC power. In the Defueled mode (which is a complete core off-load during refueling), the decay heat load in the Spent Fuel Pool is at its highest level. We havetherefore included the Defueled mode as an applicable mode for Emergency Action Level CU 1.1.NRC RAI 8:EAL CA 1.1: Please explain why you stated all the exclusion criteria for declaration of this EAL. Thesestatements are not supported in the justification section(s) of this submittal, and as a result, the staff hasno basis for effectively evaluating the acceptability of these claims.3 ATTACHMENT (1)RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RE: REQUEST TO ADOPTREVISED EMERGENCY ACTION LEVELSCCNPP Response RAI 8:The five bulleted exclusionary criteria were deleted from the site-specific bases for Emergency ActionLevel CAI.1.NRC RAI 9:EALs CU5. 1 and SU6. 1. Please explain how the "Dedicated offsite agency telephone system" and the"CCNPP Radio System" are acceptable for contacting the NRC in the required timeframe or correct thetable.CCNPP Response RAI 9:The dedicated offsite agency telephone system was deleted from Tables C-5 and S-3. The applicability ofthe CCNPP Radio System as an offsite (external) communications system was also deleted from TablesC-5 and S-3.NRC RAI 10:EALs HUI. 2 and HA 1.2.: Please explain if 100 mph is within the calibrated range of the instrumentationavailable in the Control Room.CCNPP Response RAI 10:Calvert Cliffs uses a Met One Instruments wind speed transmitter (Model 1564D) with an anemometercup assembly (Model 170-41). They are a matched pair and come from Met One Instruments with acertificate of calibration. Calvert Cliffs also uses a Model 21.11 wind speed processor to process theinput from the transmitter.The wind speed assembly and processor are capable of detecting up to 50 m/s (111.8 mph) wind speedand providing the data to the MIDAS computer. This data is displayed on the Control Room MIDAScomputer terminal as a 15 minute average.The meteorological tower where the wind speed instrumentation is installed is designed to withstand a110 mph wind gust.NRC RAI 11:EAL HU2. 1. The proposed revision to the start time of this EAL determination is unacceptable and notsupported by the justification provided The start time for this EAL begins when the alarm/annunciator isreceived, or when the report of afire is received, whichever is earlier.CCNPP Response RAI 11:The following Emergency Action Level HU2.1 bases statement has been deleted:"If the alarm cannot be verified by redundant Control Room or nearby Fire Panel indications, notificationfrom the field that a fire exists would be required to start the 15-minute classification and fireextinguishment clocks."NRC RAI 12:EAL HA3. 1: Please confirm that the areas listed in Table H-i are the areas CCNPP will use for thisparticular EAL. The intent of this EAL is to declare an Alert when access to an area is impeded due to a4 ATTACHMENT (1)RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RE: REQUEST TO ADOPTREVISED EMERGENCY ACTION LEVELSgaseous event. The areas of concern are limited to those that must be entered for safe operation or safeshutdown/cooldown. If access to the area is unnecessary to operate said equipment, then the table doesnot need the area listedCCNPP Response RAI 12:Table H-i lists structures and areas containing safe shutdown structures and equipment. EmergencyAction Level HA3.1 is worded to require classification when access to one or more Table H-I areas isprohibited. If the area is not required to be accessed for safe operation or shutdown/cooldown under plantconditions existing at the time, then emergency action level classification would not be required.NRC RAI 13:EAL HA4.1." Please reflect applicability of this EAL for security events at your independent spent fuelstorage installation.CCNPP Response RAI 13:The site-specific basis for this Emergency Action Level has been revised to read:"Note that this condition is applicable for any hostile action occurring, or that has occurred, in the OwnerControlled Area including the Independent Spent Fuel Storage Installation (ISFSI)."NRC RAI 14:EAL SA3.1." The final sentence from your plant-specific bases section does not document that escalationto the site area emergency EAL SS3. 1, which can also be due to actions away from the control roompanels, are successful in shutting down the reactor. Please explain why, or correct the discrepancy.CCNPP Response RAI 14:The last sentence of the plant-specific bases for Emergency Action Level SA3.1 states:"If manual reactor trip actions at the Control Room panels (following an unsuccessful automatic reactortrip) fail to reduce reactor power to or below 5%, the event escalates to the Site Area Emergency underEAL SS3.1 ."No credit is taken for manual trip actions away from the Control Room panels in Emergency ActionLevel SS3.1. If an automatic trip fails, manual trip actions taken from the Control Room panels will beinitiated prior to taking remote manual trip actions. Remote manual trip actions are credited, however, inEmergency Action Level SG3. 1.NRC RAI 15:EALs SU5. 1, SA5. 1, and SS5. P These EALs require more detail on which annunciators and indicatorsare applicable. The generic EAL scheme development requires more guidance for these EALs. Leavingthis open for subjective judgment determination by a Control Room Shift Manager is unacceptable andcontrary to consistent EAL decision-making within the time considerations required by regulation.Please provide more detail as to what annunciators and indicators are applicable (for example, panelnumbers, specific instruments, etc.).CCNPP Response RAI 15:As stated in the generic bases for SU5.1, SA5.1 and SS5. 1:5 ATTACHMENT (1)RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RE: REQUEST TO ADOPTREVISED EMERGENCY ACTION LEVELSQuantification is arbitrary, however, it is estimated that if approximately 75% of the safety systemannunciators or indicators are lost, there is an increased risk that a degraded plant condition could goundetected. It is not intended that plant personnel perform a detailed count of the instrumentationlost but use the value as a judgment threshold for determining the severity of the plant conditions.Annunciators or indicators for this EAL include those identified in the Abnormal OperatingProcedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/oreffluent rad monitors, etc.).The quantification of safety system indications and annunciation cannot be specified by specific panels,annunciators, or indicators because the Emergency Action Level must address significant losses in theaggregate and also for specific control parameters. Specifying specific control room panels or specificcontrol room indicators would unduly limit the possible combinations and magnitude ofindication/annunciation losses.NRC RAI 16:Fission Barrier Matrix:a. Please explain why CCNPP did not carryover the critical safety function status tree equivalentsdeveloped by the Combustion Engineering Owners Group (CEOG) and as reflected in revision 10 ofthe CCNPP EAL Technical Basis Document, i.e., Safety Function Status Checks. Develop theequivalent thresholds using CEOG guidance and the existing CCNPP EALs.b. Document and justify why all the other fission barrier thresholds from the existing CCNPP fissionbarrier matrix are not addressed in this submittal and why the NRC should consider them to nolonger be applicable, or revise accordingly.CCNPP Response RAI 16:a. The Combustion Engineering Owners Group did not generically develop critical safety functionstatus tree equivalents for use with Combustion Engineering designed plants. However, the site-specific equivalents developed and reflected in the current revision of the Calvert Cliffs NEI 99-01Rev. 4-based Emergency Action Level Fission Product Barrier Matrix and associated TechnicalBases Document were incorporated into the proposed Calvert Cliffs NEI 99-01 Rev. 5-basedEmergency Action Level scheme (see Table A below).b. All existing fission product barrier thresholds are addressed in the proposed NEI 99-01 Rev. 5-basedFission Product Barrier matrix (Reference 1, Attachment 2, Table F-I). The existing CNMT Loss #5and #6 thresholds are subsumed into the new CNMT Loss #5.The process used to generate the fission product barrier thresholds included collection of sitespecific input data with consideration for other potential fission product barrier indicators notspecifically identified within the generic NEI 99-01 Revision 5 guidance. Multiple drafts and sitetechnical inter-disciplinary reviews were conducted. A formal verification and validation wasperformed using actual operating crews and a formal review by the Plant Operation ReviewCommittee was completed. These activities identified one additional plant design specificapplicable barrier potential loss threshold (RCS Potential Loss #1: OTCC flow established) thatwas included in Table F-I.6 ATTACHMENT (1)RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RE: REQUEST TO ADOPTREVISED EMERGENCY ACTION LEVELSTable A -Fission Product Barrier Critical Safety Function Threshold Equivalent ComparisonCurrent Calvert Cliffs Thresholds (NEI 99-01 Proposed Calvert Cliffs Thresholds (NEI 99-01Rev. 4) Rev. 5)Fuel FuelClad CET readings > 1,200'F Clad CET readings > 1,200'FLoss 1 Loss IFuel FuelClad Pot. CET readings indicate superheat Clad Pot. CET readings > 700'FLoss 1 Loss 1Fuel FuelClad Pot. RVLMS level < 10 in. (last light) Clad Pot. RVLMS level < 10 in. alarmLoss 2 Loss 3RCS heat removal cannot beRCS heat removal cannot be establishedestablishedFuel AND EITHER: Fuel AND EITHER:Clad Pot. RCS pressure > PORV setpoint Clad Pot. RCS pressure > PORVLoss 3 pR Loss 2 setpointORRCS subcooling < 25'F RCS subcooling < 25'FN/A N/A RCS Pot OTCC flow establishedLoss IUncontrolled RCS cooldown and to Uncontrolled RCS cooldown and toRCS Pot left of Max Operating Pressure Curve RCS Pot left of Max Operating Pressure CurveLoss 1 (EOP Attachment 1, RCS Pressure Loss 2 (EOP Attachment 1, RCS PressureTemperature Limits) Temperature Limits)RCS heat removal cannot beRCS heat removal cannot be establishedestablished AND EITHER:RCS Pot AND EITHER: RCS Pot RCS pressure> PORVLoss 2 RCS pressure > PORV setpoint Loss 3 setpointOR ORRCS subcooling < 25'F RCS subcooling < 25'FCNMT CNMT Cotimnprsue50pgadPot Loss Containment pressure > 50 psig and Pot Containment pressure > 50 psig and1 increasing 3 risingCNMT Containment hydrogen concentration Pot Containment hydrogen concentration2 > 4% Pot Loss 4%2 4CNMT CET readings cannot be restored CNMT CET readings cannot be restoredPot Loss Pot Loss4 < 1,2000F within 15 min. 1 < 1,200'F within 15 min.7 ATTACHMENT (1)RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RE: REQUEST TO ADOPTREVISED EMERGENCY ACTION LEVELSTable A -Fission Product Barrier Critical Safety Function Threshold Equivalent ComparisonCurrent Calvert Cliffs Thresholds (NEI 99-01 Proposed Calvert Cliffs Thresholds (NEI 99-01Rev. 4) Rev. 5)CET readings > 700°FCNMT GET readingsD > 700F CNMT ANDPot Loss AND Pot Loss Reactor vessel water level cannot be5 Reactor vessel water level cannot be 2 restored > RVLMS 10 in. alarmrestored > top of core within 15 min. within 15 m.8