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MONTHYEARML16298A2792016-10-24024 October 2016 NRR E-mail Capture - Wolf Creek Request to Adopt Emergency Action Level (EAL) Scheme Pursuant to Nuclear Energy Institute (NEI) 99-01, Revision 6 Project stage: Acceptance Review ML17052A0282017-02-15015 February 2017 NRR E-mail Capture - Wolf Creek Generating Station - Official EAL RAIs Project stage: Other ML17166A4092017-08-28028 August 2017 Issuance of Amendment No. 218, Request to Adopt Emergency Action Level (EAL) Scheme Pursuant to Nuclear Energy Institute (NEI) 99-01, Revision 6 Project stage: Approval 2017-02-15
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Category:E-Mail
MONTHYEARML23360A1562023-12-26026 December 2023 NRR E-mail Capture - Acceptance Review Wolf Creek Request to Revise the Ventilation Filter Testing Program in Technical Specifications ML23166A0622023-06-15015 June 2023 NRR E-mail Capture - Acceptance Review - Wolf Creek Third Containment Inservice Inspection Program Interval for Proposed Alternative Frequency to Containment Unbonded post-tensioning System Components ML23090A1042023-03-31031 March 2023 NRR E-mail Capture - Acceptance Review Wolf Creek Request for Removal of the Power Range Neutron Flux Rate - High Negative Rate Trip Function from Technical Specifications ML23090A0072023-03-31031 March 2023 NRR E-mail Capture - Acceptance Review Wolf Creek Request for Relief for Follow-Up Examination Requirements for Reactor Pressure Vessel Head Penetration Nozzles with Peened Surface ML23080A0652023-03-21021 March 2023 NRR E-mail Capture - Wolf Creek Generating Station Evacuation Time Estimate Analysis Review ML23026A0222023-01-25025 January 2023 NRR E-mail Capture - Acceptance Review Wolf Creek Request to Revise Technical Specifications to Adopt Technical Specification Task Force (TSTF)-554-A, Revision 1, Revise Reactor Coolant Leakage Requirements ML23009A4082023-01-0909 January 2023 NRR E-mail Capture - Acceptance Review Wolf Creek Request to Revise TS to Adopt Technical Specification Task Force (TSTF)-577-A, Revision 1, Revised Frequencies for Steam Generator Tube Inspections ML22361A0052022-12-27027 December 2022 NRR E-mail Capture - Request for Additional Information Wolf Creek Request for Deviation from Fire Protection Program Requirements ML22321A2662022-11-16016 November 2022 January 2023 Emergency Preparedness Program Inspection - Request for Information ML22307A1372022-11-0202 November 2022 August 2022 Emergency Preparedness Exercise Inspection Unresolved Item - Request for Information ML22251A1312022-09-0808 September 2022 NRR E-mail Capture - Acceptance Review - Wolf Creek Request for Deviation from Fire Protection Program Requirements to Allow Use of Portable Lighting ML22215A2742022-08-0202 August 2022 Inservice Inspection Request for Information ML22208A1322022-07-27027 July 2022 NRR E-mail Capture - Wolf Creek Table of Contents LAR ML22166A3222022-06-14014 June 2022 August 2022 Emergency Preparedness Exercise Inspection - Request for Information ML22131A0522022-05-11011 May 2022 NRR E-mail Capture - Draft Supplemental Information Needed for Acceptance - Wolf Creek Inservice Inspection Relief Request for Reactor Pressure Vessel Head Penetration Nozzles with Peened Surface ML22055A1142022-02-23023 February 2022 NRR E-mail Capture - Request for Additional Information - Wolf Creek Request to Revise Diesel Generator Completion Time ML22045A4512022-02-14014 February 2022 NRR E-mail Capture - Request for Additional Information - Wolf Creek Steam Generator Inspection Report 24th Refueling ML22026A4392022-01-26026 January 2022 NRR E-mail Capture - Wolf Creek Acceptance Review Results - Removal of TS Table of Contents (L-2022-LLA-0008) ML22025A3612022-01-21021 January 2022 PI&R RFI Final ML21327A2602021-11-23023 November 2021 NRR E-mail Capture - Request for Additional Information - Wolf Creek Revision of Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation ML21309A0332021-11-0505 November 2021 NRR E-mail Capture - Acceptance Review - Wolf Creek Revision of Technical Specification 3.8.1, AC Sources - Operating ML21307A4202021-11-0303 November 2021 NRR E-mail Capture - Acceptance Review - Wolf Creek Revision of Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation ML21271A1952021-09-28028 September 2021 E-mail 9-28-21 RFI for Wc EP Inspection Nov 2021 ML21259A0652021-09-16016 September 2021 NRR E-mail Capture - Draft Supplemental Information Needed for Acceptance - Wolf Creek License Amendment and Exemption Requests Regarding GSI-191 (EPIDs L-2021-LLA-0152 and L-2021-LLE-0039) ML21221A1282021-08-0505 August 2021 NRR E-mail Capture - Urgent: Draft Request for Additional Information - Wolf Creek one-time Request for Exemption from the Biennial Emergency Preparedness Exercise ML21189A0252021-07-0101 July 2021 NRR E-mail Capture - Acceptance Review - Wolf Creek Request Revision to the Emergency Plan Related to on-shift Staffing ML21230A3922021-05-19019 May 2021 May 19, 2021 Dricks Response to Gurdziel Letter Dated May 13, 2021 - August 17, 2021 ML21102A3342021-04-12012 April 2021 Email 4-12-21 RFI for In-Office Rvw of Recent RERP and a Related EPIP Change ML21064A0342021-03-0404 March 2021 NRR E-mail Capture - Wolf Creek Generating Station Upcoming Steam Generator Tube Inservice Inspection ML20353A2712020-12-18018 December 2020 NRR E-mail Capture - Acceptance Review - Wolf Creek Request to Revise Technical Specification 3.6.3 and Surveillance Requirement 3.6.3.1 to Allow Use of a Blind Flange ML20349A3092020-12-14014 December 2020 NRR E-mail Capture - Acceptance Review - Wolf Creek License Amendment Request for Change to Owner Licensee Names ML20297A3022020-10-22022 October 2020 NRR E-mail Capture - Acceptance Review - Wolf Creek Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI ML20262A7512020-09-17017 September 2020 NRR E-mail Capture - Requests for Additional Information: Wolf Creek Amendment Request to Modify Technical Specification Surveillance Frequency Consistent with TSTF-425 ML20191A0222020-07-0606 July 2020 NRR E-mail Capture - Acceptance Review - Wolf Creek Request in Support of Replacement Engineered Safety Features Transformers with Load Tap Changers ML20162A1642020-06-0909 June 2020 Email June 9, 2020 - RFI in Preparation for Wolf Creek EP Program Inspection ML20149K4272020-05-22022 May 2020 NRR E-mail Capture - Acceptance Review - Wolf Creek License Amendment Request Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TSTF-425) ML20133J8972020-05-12012 May 2020 12 May 2020 E-mail - RFI for NRC In-Office Inspection of Recent Wcngs Eplan_Eal Changes ML20132A3442020-05-11011 May 2020 NRR E-mail Capture - Acceptance Review - Wolf Creek Generating Station License Amendment Request to Revise Technical Specification 5.5.16 for Permanent Extension of Type a and Type C Leak Rate Test Frequencies ML20009E4802020-01-0909 January 2020 Relief Request to Utilize Code Case N-666-1 for Wolf Creek Generating Station - Request for Additional Information ML19273A0232019-09-30030 September 2019 NRR E-mail Capture - Acceptance Review - License Amendment Request to Revise Technical Specification 3.7.5, Auxiliary Feedwater (AFW) System, ML19268B7172019-09-25025 September 2019 NRR E-mail Capture - Acceptance Review - Inservice Inspection (ISI) Program Relief Request to Use Code Case N-666-1 ML19261A2272019-09-18018 September 2019 NRR E-mail Capture - Regulatory Audit Plan - Wolf Creek Generating Station License Amendment Request to Revise Technical Specification 3.3.5 ML19255H3032019-09-12012 September 2019 NRR E-mail Capture - Acceptance Review - Relief Request I4R-07 to Utilize Code Case N-513-4 ML19224A5242019-08-12012 August 2019 NRR E-mail Capture - Request for Additional Information - License Amendment Request to Revise Wolf Creek Generating Station Technical Specification 3.3.5 ML19274D2752019-07-31031 July 2019 Request for Information-IR 05000482 2019-004, Dated 7/31/2019 ML19203A2362019-07-19019 July 2019 LTR-19-0291 Tom Gurdziel, E-mail July 18, 2019, Confirmatory Order on Wolf Creek ML19112A1772019-04-22022 April 2019 NRR E-mail Capture - Acceptance Review - License Amendment Request to Revise Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation ML19091A0362019-03-29029 March 2019 NRR E-mail Capture - Acceptance Review - License Amendment Request to Revise Technical Specification 3.6.3 and Surveillance Requirement 3.6.3.1 to Remove Use of a Blind Flange ML19065A0982019-03-0606 March 2019 NRR E-mail Capture - Acceptance Review - Wolf Creek License Amendment Request for Revision to Technical Specifications to Adopt TSTF-529 ML19036A6832019-02-0505 February 2019 LTR-18-0498 - Email Response - Sheryl Sweet, Licensing Engineer, Wolf Creek Nuclear, E-mail Acronyms for NRC Personnel 2023-06-15
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML22361A0052022-12-27027 December 2022 NRR E-mail Capture - Request for Additional Information Wolf Creek Request for Deviation from Fire Protection Program Requirements ML22321A2662022-11-16016 November 2022 January 2023 Emergency Preparedness Program Inspection - Request for Information ML22307A1372022-11-0202 November 2022 August 2022 Emergency Preparedness Exercise Inspection Unresolved Item - Request for Information ML22249A2552022-06-29029 June 2022 Request for Information for an NRC Post-Approval Site Inspection for License Renewal 05000482/2022012 ML22165A0882022-06-14014 June 2022 Information Request, Security IR 2022403 ML22166A3222022-06-14014 June 2022 August 2022 Emergency Preparedness Exercise Inspection - Request for Information ML22055A1142022-02-23023 February 2022 NRR E-mail Capture - Request for Additional Information - Wolf Creek Request to Revise Diesel Generator Completion Time ML22045A4512022-02-14014 February 2022 NRR E-mail Capture - Request for Additional Information - Wolf Creek Steam Generator Inspection Report 24th Refueling ML22025A3612022-01-21021 January 2022 PI&R RFI Final ML21327A2602021-11-23023 November 2021 NRR E-mail Capture - Request for Additional Information - Wolf Creek Revision of Technical Specification 3.3.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation ML21271A1952021-09-28028 September 2021 E-mail 9-28-21 RFI for Wc EP Inspection Nov 2021 ML21253A0902021-09-23023 September 2021 Supplemental Information Needed for Acceptance of Requested Licensing Actions License Amendment and Regulatory Exemption for a Risk-Informed Approach to Address GSI-191 (EPIDs L-2021-LLA- 0152 and L-2021-LLE-0039) ML21221A1282021-08-0505 August 2021 NRR E-mail Capture - Urgent: Draft Request for Additional Information - Wolf Creek one-time Request for Exemption from the Biennial Emergency Preparedness Exercise ML21132A1032021-05-12012 May 2021 Document Request List, Paperwork Reduction Act Statement ML20302A4782020-10-28028 October 2020 OPC R1 Request for Information ML20262A7512020-09-17017 September 2020 NRR E-mail Capture - Requests for Additional Information: Wolf Creek Amendment Request to Modify Technical Specification Surveillance Frequency Consistent with TSTF-425 ML20195A2712020-07-13013 July 2020 Generation Station - Notification of an NRC Fire Protection Baseline Inspection (NRC Inspection Report 05000482/2020012) and Request for Information ML20133J8972020-05-12012 May 2020 12 May 2020 E-mail - RFI for NRC In-Office Inspection of Recent Wcngs Eplan_Eal Changes ML20009E4802020-01-0909 January 2020 Relief Request to Utilize Code Case N-666-1 for Wolf Creek Generating Station - Request for Additional Information ML19346E6052019-11-0404 November 2019 Target Set Request for Information for Week of November 4, 2019 ML19224A5242019-08-12012 August 2019 NRR E-mail Capture - Request for Additional Information - License Amendment Request to Revise Wolf Creek Generating Station Technical Specification 3.3.5 ML18304A1052018-11-0505 November 2018 Request for Additional Information License Amendment Request for Transition to Westinghouse Core Design and Safety Analyses and Alternative Source Term (CAC No. MF9307; EPID L-2017-LLA-0211) ML18282A6402018-10-0909 October 2018 NRR E-mail Capture - Request for Additional Information - Wolf Creek Generating Station License Amendment Request for Revision to the Emergency Plan ML18270A0942018-10-0404 October 2018 Request for Additional Information License Amendment Request for Transition to Westinghouse Methodology for Selected Accident and Transient Analyses ML18207A4332018-07-24024 July 2018 NRR E-mail Capture - (External_Sender) Draft Request for Additional Information Relief Request from ASME Code N-666-1 Alternate Repair of Essential Service Water Piping Wolf Creek Generating Station, Unit 1 EPID No.:L-2018-LLR-0101 ML18116A6132018-04-25025 April 2018 Operating Corporation - Notification of Inspection (NRC Inspection Report 05000482/2018002) and Request for Information ML17331A1782017-12-0404 December 2017 Request for Additional Information License Amendment Request for Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternate Source Term (CAC No. MF9307; EPID L-2017-LLA-0211) ML17291A7102017-10-17017 October 2017 NRR E-mail Capture - Request for Additional Information - License Amendment Request (LAR) for Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternative Source Term ML17265A0142017-09-21021 September 2017 NRR E-mail Capture - Request for Additional Information - License Amendment Request for Transition to Westinghouse Core Design and Safety Analyses ML17170A3152017-06-19019 June 2017 Notification of an NRC Triennial Fire Protection Baseline Inspection (NRC Inspection Report 05000482/2017008) and Request for Information ML17166A0382017-06-14014 June 2017 NRR E-mail Capture - Request for Additional Information - License Amendment Request for Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternative Source Term ML17052A0282017-02-15015 February 2017 NRR E-mail Capture - Wolf Creek Generating Station - Official EAL RAIs ML16319A4282016-11-14014 November 2016 NRR E-mail Capture - Request for Additional Information (RAI) - Relief Requests 13R-14 and 13R-15 ML16300A2662016-10-21021 October 2016 Request for Additional Information - Relief Request I3R-13 Regarding Weld Examination Coverage IR 05000482/20160022016-08-0303 August 2016 NRC Integrated Inspection Report 05000482/2016002 ML16110A3722016-04-25025 April 2016 Request for Additional Information, License Amendment Request to Revise Technical Specification (TS) 4.2.1 and TS 5.6.5 to Allow Use of Optimized Zirlo as Approved Fuel Rod Cladding ML16020A1392016-01-15015 January 2016 Notification of NRC Component Design Bases Inspection (05000482/2016007) and Initial Request for Information ML15135A4862015-05-14014 May 2015 Wc 2015007 17T RFI ML15082A0052015-03-27027 March 2015 Request for Additional Information, Round 2, Request to Revise Technical Specifications to Adopt TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process ML15079A0762015-03-23023 March 2015 Request for Additional Information, Round 2, Flood Hazard Reevaluation Report for Recommendation 2.1 of the Near-Term Task Force Review of the Insights from the Fukushima Dai-Ichi Accident ML15040A6252015-02-10010 February 2015 Request for Additional Information, License Amendment Request to Revise Technical Specifications to Adopt TSTF-523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process ML14323A5742014-12-0404 December 2014 Request for Additional Information, License Amendment Request to Revise Fire Protection Program Related to Alternative Shutdown Capability as Described in USAR ML14230A7572014-08-21021 August 2014 Request for Additional Information, Relief Request I3R-10, Alternative from Pressure Test Requirements of ASME Code Section XI, IWC-5220, Third 10-Year Inservice Inspection Interval ML14206A0122014-08-0101 August 2014 Request for Additional Information, Relief Requests I3R-08, RPV Interior Attachments and I3R-09, RPV Pressure-Retaining Welds, Exam Interval Extensions, Third 10-year Inservice Inspection Interval ML14197A3362014-07-25025 July 2014 Request for Additional Information, Relief Request I3R-11, Alternative from Pressure Test Requirements of ASME Code Section XI IWC-5220, Third 10-Year Inservice Inspection Interval ML14148A3872014-06-0202 June 2014 Request for Additional Information Related to Flood Hazard Reevaluation Report for Recommendation 2.1 of the Near-Term Task Force Review of the Insights from the Fukushima Dai-Ichi Accident ML14111A1002014-04-30030 April 2014 Request for Additional Information, Nrr/Dss/Srxb, License Amendment Request to Approve Transition to Westinghouse Core Design and Safety Analysis and Adoption of Full Scope Alternate Source Term ML14083A4002014-04-0303 April 2014 Request for Additional Information, Nrr/Dra/Arcb, License Amendment Request to Approve Transition to Westinghouse Core Design and Safety Analysis and Adoption of Full Scope Alternate Source Term ML14058A0882014-03-0505 March 2014 Request for Additional Information, Nrr/De/Eeeb, License Amendment Request to Approve Transition to Westinghouse Core Design and Safety Analysis and Adoption of Full Scope Alternate Source Term ML14027A1622014-01-28028 January 2014 Redacted, Request for Additional Information, Round 2, License Amendment Request to Approve Transition to Westinghouse Core Design and Safety Analysis and Adoption of Full Scope Alternate Source Term 2022-06-29
[Table view] |
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1 NRR-PMDAPEm Resource From:Lingam, Siva Sent: Wednesday, February 15, 2017 2:58 PM To: wimuile@wcnoc.com Cc:Pascarelli, Robert; Singal, Balwant; Wasem, Michael; Hoffman, Raymond; Norris, Michael; cyhafen@wcnoc.com
Subject:
Wolf Creek Generating Station - Official EAL RAIs (CAC No. MF8450)REQUESTS FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST EMERGENCY ACTION LEVEL SCHEME CHANGE WOLF CREEK GENERATING STATION DOCKET NO. 50-482 (CAC NO. MF8450)
By letter dated September 30, 2016, Wolf Creek Nuclear Operating Corporation (the licensee) requested approval for an emergency action level (EAL) scheme change for Wolf Creek Generating Station (WCGS),
(Agencywide Documents Access and Management System (ADAMS) Accession Number ML16279A377).
The requirements of Section 50.47(b)(4) to Title 10 of the Code of Federal Regulations (10 CFR) state, in part, that:
A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.
The most recent industry EAL scheme development guidance is provided in the Nuclear Energy Institute (NEI) document NEI 99-01, "Development of Emergency Ac tion Levels for Non-Passive Reactors" (ADAMS Accession No. ML12326A805). By letter dated March28, 2013, the U.S. Nuclear Regulatory Commission (NRC) endorsed NEI 99-01, Revision 6, as acceptable generic (i.e., non-plant-specific) EAL
scheme development guidance (ADA MS Accession No. ML12346A463).
WCGS proposes to revise their current EAL scheme to one based upon NEI 99-01, Revision 6 (hereafter referred to as "endorsed guidance").
The requests for additional information (RAI) listed below are necessary to facilitate the technical review being conducted by the NRC staff. Please provide your responses to these official RAIs within 30 days from the date of this e-mail. A timely and thorough response to these RAIs is requested in order to meet the proposed deadline requested by the licensee. Please note that we transmitted the draft RAIs to you by e-mail on February 9, 2017, requesting a clarification conference call. Per your telephone call today, you mentioned that no clarification call is required. You also agreed to provide the RAI responses within 30 days from the date of this e-mail.
RAI-WCGS-1 The definitions contained in NEI 99-01, Revision 6, for a General Emergency, Site Area Emergency, Alert and Notification of Unusual Event classification levels begin with "Events are in progress..." The WCGS definitions in Section 5.0 of Alert, General Emergency, Site Area Emergency and Unusual Event begin with "Events are in pro c ess." [emphasis added]
Please revise these definitions to reflect the definitions in the endorsed guidance or provide a justification for
the difference.
2 RAI-WCGS-2 Section 4.3, "Instrumentation Used for EALs," to NEI 99-01, Revision 6, states: "Scheme developers should ensure that specific values used as EAL setpoints are within the calibrated range of the referenced
instrumentation."
Please confirm that all setpoints and indications used in the proposed WCGS EAL scheme are within the calibrated range(s) of the stated instrumentation and that the resolution of the instrumentation is appropriate fo r the setpoint/indication.
RAI-WCGS-3 WCGS EAL RA2.1 Basis states:
This IC [Initiating Condition]
applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the Confinement Boundary is classified in accordance with IC EU1.
WCGS is not currently licensed for an independent spent fuel storage installation and the proposed EAL scheme does not include IC EU1. As such, this paragraph is not applicable to WCGS. Please remove this statement from the basis or provide justification including statement.
RAI-WCGS-4 WCGS EALs CA2.1, SS1.1, SG1.1 and SG1.2 state:
Loss of all offsite and all onsite AC [alternating current] power capability
-.
Additionally, the WCGS Basis for EALs CA2.1, SS1.1, SG1.1 and SG1.2 state:
For emergency classification purposes, "capability" means that an AC power source is available to the emergency buses, whether or not the buses are powered from it.
The term "capability" is used in the EALs listed above and a clarification for the meaning of "capability" in their respective bases is not consistent with the endorsed guidance; nor is it identified as a "difference" in Enclosure III, "EAL Comparison Matrix."
The intent of these EALs is to ensure that an EAL is declared upon a total loss of AC power that compromises the performance of all systems requiring electric power for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal, and the ultimate heat sink. This additional criteria could prevent the EAL from being declared in a condition where the AC power sources are available, but not able to be connected to the emergency buses. The NRC staff considers the addition of this criteria to the EALs, and the definition in the basis, to be a deviation from endorsed guidance.
Please remove the term "capability" in the EALs listed above and the clarification for the meaning of "capability" in the respective bases, or explain how the addition of this condition could not potentially delay or prevent classification of a loss of AC power to emergency buses.
RAI-WCGS-5 WCGS Basis for EALs CU2.1and SA1.1 state:
For emergency classification purposes, "capability" means that an AC power source is available to the emergency buses, whether or not the buses are powered from it.
3 The clarification for the meaning of "capability" in their respective bases is not consistent with the endorsed guidance; nor is it identified as a "difference" in Enclosure III, "EAL Comparison Matrix."
Please remove the clarification for the meaning of "capability" in the respective bases, or explain how the addition of this condition could not potentially delay or prevent classification of a loss of AC power to emergency buses.
RAI-WCGS-6 WCGS EALs CU2.1, SU1.1 and SA1.1 bases state, in part, that:
An additional source of power are the SBO [Station Blackout] diesel generators [DGs]
SBO DGs (ref. 3, 4). Credit can be taken for this source only if they are already aligned because they cannot be aligned within 15 minutes.
Please consider adding a statement or note to Tables C-3, "AC Power Sources," and S-1, "AC Power Sources," that the SBO DGs may be credited if they are already aligned. This will ensure that the decision maker has this information available on a wall board and not just in the basis document.
RAI-WCGS-7 Table C-2, "Containment Challenge Indication," to the WCGS EAL CG1.1 references a "Note 6;" however, there is no Note 6 in the EAL. It should be noted that the WCGS CG1.2 does provide this information in a Note 6 in its EAL.
EAL CG1 of the endorsed guidance provides the following clarifying information:
If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declaration of a General Emergency is not required.
Please revise CG1.1 to include the information as provided in the endorsed guidance, or provide justification for its omission.
RAI-WCGS-8 The 2 nd bullet in WCGS EAL HU4.1 includes the phrase: "in the same fire area." This is inconsistent with the endorsed guidance and could result in inconsistent emergency declarations. More than one indication or alarm may be indicative of a higher likelihood of fire, whether it is one area or not (e.g. a single alarm with a lowering of fire main pressure, as described in endorsed guidance).
Please revise this EAL and basis to be consistent with the endorsed guidance, or provide further justification for the difference.
RAI-WCGS-9 The 2 nd threshold in the WCGS EAL HA1.1 Basis states:
This EAL is met when the threat-related information has been validated in accordance with site-specific procedures.
The endorse guidance provides: "-information has been validated in accordance with (site-specific procedures)." It is expected that during the development of the site-specific EAL scheme using the generic endorsed guidance, the licensee would identify the site-specific procedure.
4Please revise the EAL to reflect the site-specific procedure to be used to validate the security threat (e.g., WCGS EAL HU1.1 Basis states that validation of the threat is performed in accordance with the "Wolf Creek
Generating Station Security Plan").
RAI-WCGS-10 For WCGS EALs SU6.1, SU6.2, SA6.1 and SS6.1, a power level (greater than or equal to 5%) was added to the EALs. The intent of the endorsed guidance is to align the above EAL classifications with site-specific emergency operating procedure (EOP) criteria for a successful reactor shutdown, which would benefit the decision makers by providing consistent criteria. The power level provided in the developer notes in the endorsed guidance is an example that represents a typical EOP indication for a generic power plant.
Please revise to reflect the EOP reactor shutdown criteria in the EOPs, or using wording similar to endorsed guidance.
RAI-WCGS-11 Table S-3, "Significant Transients," under WCGS EAL SA3.1, lists (3 rd bullet): "Electrical load rejection 25% electrical load." This is inconsistent with the endorsed guidance that states: "Electrical load rejection 25% full electrical load." [emphasis added] Additionally, the WCGS basis for this EAL lists load rejections of greater than 25% full electrical load as a significant transient.
Please revise per endorsed guidance, or justify this difference.
RAI-WCGS-12 WCGS EAL SA9.1 Basis states:
With respect to hazards caused by an equipment failure (e.g., an electrical breaker failure leading to an explosion), no emergency declaration is warranted if the hazard did not cause any damage to another safety system, or another train of the affected safety system. If the hazard resulting from an equipment failure causes damage to another safety system, or another train of the affected safety system (i.e., a system or train that was not the source of the initia ting equipment failure), then an emergency declaration is required per this EAL.
This information is not consistent with the endorsed guidance as it provides additional information that may affect the classification of this type of event. Please revise the basis to reflect the endorsed guidance, or consider the following additional guidance.
RAI-WCGS-13 Table 9-F-3 (Pressurized Water Reactor EAL Fission Product Barrier Table) in NEI 99-01, Revision 6, list the following criteria for a potential loss of the Reactor Coolant System (RCS) Barrier based on the following RCS or Steam Generator Tube Leakage criteria:
A. Operation of a standby charging (makeup) pump is required by EITHER of the following:
- 1. UNISOLABLE RCS leakage OR 2. SG tube leakage.
However, the WCGS EAL scheme does not include a similar potential loss. Given the capacity of the charging pumps and procedural direction to isolate letdown, WCGS has a condition that is similar to the leak conditions referenced in guidance.
5Please revise to address endorsed guidance, or provide additional justification for the deviation.
RAI-WCGS-14 The CMT [Primary Containment]
Radiation/RCS Activity, Loss 2, in the WCGS Fuel Clad Fission Barrier, contains a sample analysis component. However, it does not address the RCS Activity/Containment Radiation, Loss 3.B Basis, under the Fuel Clad Fission Barrier in the endorsed guidance, which includes the statement to add the following paragraph (or similar wording) to the basis if the threshold includes a sample analysis component:
It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete. Nonetheless, a sample-related threshold is included as a backup to other indications.
Please provide the associated paragraph from endorsed guidance, or justify this difference.
RAI-WCGS-15 The RCS or SG Tube Leakage, Potential Loss Threshold 1, in the WCGS Fuel Clad Fission Barrier, states:
"CFST [Critical Safety Function Tree] Integrity-Red Path conditions met," under the WCGS RCS Barrier. This is not consistent with the WCGS bases, which states: "CSFT RCS Integrity-Red Path." [emphasis added]
Please add "RCS" to the RCS or SG Tube Leakage, Potential Loss Threshold 1, or provide a justification for the difference.
RAI-WCGS-16 The Fission Product Barrier Potential Loss bases for Emergency Director Judgement in the endorsed guidance states:
The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored
. All WCGS Fission Product Barriers Loss bases for Emergency Director Judgement include the following bulleted statement:
Barrier monitoring capability is decreased if there is a loss or lack of reliable indicators. This assessment should include instrumentation operability concerns, readings from portable instrumentation and consideration of offsite monitoring results.
The statement in the WCGS fission product barrier loss bases may cause a delay in classification due to confusion as to application of the loss or potential loss of the barrier in question. In addition, the three bulleted items appearing in the WCGS bases for the loss or potential loss are identical and may confuse the decision maker in differentiating between a loss and a potential loss.
Please revise the proposed Fission Product Barrier Emergency Director Judgement, Loss and/or Potential Loss bases to remove any wording that could either bound and/or modify the judgement of the Emergency Director concerning a loss, or potential loss, of a fission product barrier, or explain how this wording will not potentially inhibit the judgement of the Emergency Director.
Siva P. Lingam U.S. Nuclear Regulatory Commission Project Manager (NRR/DORL/LPL4-1)
Palo Verde Nuclear Generating Station, Units 1, 2, and 3 Grand Gulf Nuclear Station, Unit 1 6Location: O8-D5; Mail Stop: O8-B3 Telephone: 301-415-1564; Fax: 301-415-1222 E-mail address: siva.lingam@nrc.gov
Hearing Identifier: NRR_PMDA Email Number: 3346 Mail Envelope Properties (Siva.Lingam@nrc.gov20170215145800)
Subject:
Wolf Creek Generating Station - Official EAL RAIs (CAC No. MF8450) Sent Date: 2/15/2017 2:58:28 PM Received Date: 2/15/2017 2:58:00 PM From: Lingam, Siva Created By: Siva.Lingam@nrc.gov Recipients: "Pascarelli, Robert" <Robert.Pascarelli@nrc.gov> Tracking Status: None "Singal, Balwant" <Balwant.Singal@nrc.gov>
Tracking Status: None "Wasem, Michael" <Michael.Wasem@nrc.gov> Tracking Status: None "Hoffman, Raymond" <Raymond.Hoffman@nrc.gov> Tracking Status: None "Norris, Michael" <Michael.Norris@nrc.gov>
Tracking Status: None "cyhafen@wcnoc.com" <cyhafen@wcnoc.com> Tracking Status: None "wimuile@wcnoc.com" <wimuile@wcnoc.com> Tracking Status: None Post Office: Files Size Date & Time MESSAGE 14817 2/15/2017 2:58:00 PM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received: