05000387/FIN-2012002-03
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Finding | |
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| Title | Installed Instrumentation Necessary for EAL Declaration |
| Description | During a review of Operating Experience (OE) related to inadequate instrumentation to support EAL declarations, inspectors questioned whether installed instrumentation to measure RB temperatures was required to support entry into the fission product barrier EAL. Specifically, 9 of the 21 areas that need to be considered, per PPL EALs, for Potential Loss of RCS Barrier and Loss of Primary Containment Barrier if they exceed maximum normal and maximum safe temperature limits, respectively, do not have installed temperature indication and would require operator action to measure temperature locally. The Fission Product Barrier EAL, as presented in EP-TP-001, Emergency Classification Levels Manual, Revision 5, includes the use of room temperatures for identification of a Potential Loss of RCS Barrier and Loss of Primary Containment Barrier. Both criteria reference tables of applicable areas with the corresponding Max Normal Reactor Building Temperature and Max Safe Reactor Building Temperature limits. Exceeding the Max Normal Reactor Building Temperature limit indicates a potential loss of the RCS barrier and exceeding the Max Safe Reactor Building Temperature limit indicates a loss of the primary containment barrier. During review of this issue, the inspectors determined that 9 of the 21 areas listed do not have installed temperature indication. This criterion is ORd with the area radiation readings in excess of Maximum Normal or Safe Radiation limit for the RCS barrier or Containment barrier, respectively. However, several of the 9 areas, which do not have a temperature monitor, also do not have a corresponding area radiation monitor. For example, the CS rooms are listed on the table for temperature limits, but have no installed temperature monitor and also do not have a radiation monitor. Therefore, there would be no installed instrumentation to declare the appropriate EAL for a break that was not isolated in those rooms. This has the potential to impact declaration of all four classifications (up to and including a General Emergency). This question has been entered into PPLs CAP as CR 1541912. Initially, PPLs evaluation has determined that this is consistent with industry practice and consistent with assumptions made during transition to the NEI 99-02 scheme. Specifically, the table is taken directly from EOPs and it is recognized that not all EOP criteria have installed instrumentation. This issue will be tracked as a URI pending further NRC review of the issue to include consultation with the Office of Nuclear Security and Incident Response (NSIR). |
| Site: | Susquehanna  |
|---|---|
| Report | IR 05000387/2012002 Section 1EP6 |
| Date counted | Mar 31, 2012 (2012Q1) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71114.06 |
| Inspectors (proximate) | A Bolger J Greives P Finney P Krohn R Rolph T O'Haraj Nicholsonr Rolph S Barr T Daun T Hedigan A Turilin D Kern F Bower J D'Antonio J Grieves |
| INPO aspect | |
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Finding - Susquehanna - IR 05000387/2012002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Susquehanna) @ 2012Q1
Self-Identified List (Susquehanna)
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