IR 05000344/1991016
| ML20198C473 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 06/04/1991 |
| From: | Good G, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20198C466 | List: |
| References | |
| 50-344-91-16, NUDOCS 9107030033 | |
| Download: ML20198C473 (15) | |
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l U. S. NUCLEAR REGULATORY COMMISSION
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REGION V
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Report No.
50-344/91-16 Docket No.
50-344 License No.
NPF-1 l
Licensee:
Portland General Electric 121 S. W. Salmon Street l
Portland, Oregon 97204 i
Facility Name:
Trojan l
Inspection at:
USNRC Region V, Walnut Creek, California Inspection Conducted.
iay 6-16, 9
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M /)1 M / W ) s w G[+/4/
Inspector:
.ydod, Enierg ~ ~c
' eparedness Analyst Dat'e 5igned-Approved by:
MM W G/f/41 e
JarflesMiteese, Chief /
Date Signed SafeguM'ds, Emergency Pre aredness, and Non-Power Reactor Branca SUMMARY:
Inspection on May 6-16, 1991 (Report No. 50-344/91-16)
Areas Inspected:
In-office inspection of proposed Revision 6 to emergency procedure (EP)-001, " Emergency Classification."
Inspection procedure 82701 was used as guidance.
Results:
No deviations or violations of NRC requirements were identified within the scope of this inspection.
During the review, the inspector identified several proposed changes that were not consistent with NUREG-0654 and were not conservative when compared.
These proposed changes are described in Section 2 of this report (see Items 8, 9, 20, and 39).
Implementation of these changes would constitute an unacceptable decrease in the effectiveness of the emergency plan; therefore, the proposed Revision 6 to EP-001 was not approved.
The inspector also identified several existing emergency action levels (EALs) that were not consistent (in a non-conservative direction) with NUREG-0654 (see Items 21, 38, and 40).
Some internal inconsistencies and editorial issues were also identified during the review (see Items 1, 14, 15, l
19,37,43,and45).
l The results of this inspection indicate a need for increased management l
attention in this area to ensure that a conservative approach to event I
classifications is maintained.
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DETAILS 1.
Persons Contacted D. Pearson, Complian.e Specialist J. Thale, Supervisor, Emergency Preparedness T. Walt, General Manager, Technical Functions 2.
Operational Status of the Emergency Preparedness Program (Inspection Procedure 82/01)
Proposed Revision 6 to emergency procedure (EP)-001, " Emergency Classification" was submitted for approval on March 21, 1991, in accordance with 10 CFR 50, Appendix E, Paragraph IV.B.
This submittal was also considered to be a request for prior approval of the proposed changes under 10 CFR 50.54(q).
The licensee's letter stated that the proposed Revision 6 had been reviewed and approved by the States of Oregon and Washington, and Columbia and Cowlitz Counties.
Regional emergency preparedness staff conducted an in-office evaluation of the procedure and the emergency action levels (EALs) contained therein.
The evaluation was conducted to determine whether the proposed changes would represent a decrease in the effectiveness of the Trojan Radiological Emergency Response Plan (RERP), and whether the changes would continue to meet the standards in 50.47(b) and the requirements of 10 CFR 50, Appendix E.
The example initiating conditions in Appendix 1 of NUREG-0654 were used to evaluate the EALs.
The results of our evaluation are described below.
For clarity, wherever appropriate, responses obtained from the licensee during the May 16, 1991, exit interview (see Section 3 below) have been included for each item.
Some information was also provided during a May 17, 1991, telephone conversation between the licensee's EP Supervisor and the inspector.
1.
Change:
(Page 4, Section 1.0, 3rd paragraph) The paragraph was changt to indicate that "further evaluation" (or assessment) is not necess % for "most" EALs.
The previous wording imolied that most EALs needed further assessment, but that there were "some" that did not.
NRC comment:
The entire paragraph appeared to invalidate the licensee's EAL scheme since it implied that EALs could be met, but further assessment might be necessary prior to event-declaration.
The paragraph also appeared to be in conflict with the note which stated that " Implicit in the identification of the indicator is the concept of a valid instrument reading, or a confirmed or verified report or observation." The wording in the paragraph (not the note)
could cause confusion and contribute to unnecessary delays in event declaration.
The note appeared acceptable.
Licensee Response:
The licensee stated that this was a valid comment.
The licensee proposed to delete this paragraph in the next revision to EP-001.
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l At this time, this proposed action was considered acceptable and did not appear to decrease the effectiveness of the RERP.
2.
Change:
(Page 6, Section 3.1.1) The last sentence in this Section has been deleted.
The sentence identified examples of the types of assessments that might be performed to " verify the validitv of an indicator." Examples included comparison to redundant instrument channels, comparison to other related plant parameters, physical observations and field measurements.
NRC Comment:
Deletion of this sentence was considered an improvement since many of the assessments would be unnecessary and could delay event declaration.
This proposed change was considered acceptable.
3.
Change:
(Page 6, Section 3.1.2) The assessment time period of 15 minutes has been changed to "in a timely manner."
NRC Comment:
As indicated in the licensee's summary of changes (the Attachment to the March 21 1991 submittal), this change was made in responsetoNRCOpenItem$0-344/90-04-01. One of the elements in Open Item 90-04-01 involved the inclusion of a 15 minute time limit for event classification.
The addition of the 15 minutes was a concern since it could delay classification due to unnecessary, redundant assessment of.iALs.
This proposed change was considered acceptable and sufficient to address the open item; however, Open Item 90-04-01 will remain open until all of the elements identified in the item are verified in a formally issued version of EP-001.
4.
Change:
(Module 1, Step 1) This step has been changed to indicate that release rates are to be averaged over one hour.
The words
"actually or anticipated" were added to eliminate the need to exceed the time period before event declaration. The word " limits" was replaced with " release rates." The wording in the note was changed to require the user to examine the next step if the release rates were exceeded, as opposed to waiting for the time limit to be exceeded.
'JRC Comment: The wording used in this EAL was consistent with the h chnical Specifications (TS) and the RERP.
These proposed changes weie considered acceptable since they were consistent with NURJG-0654 Unusual Event (UE) No. 2.
5.
Charae:
(Module 1, Step 2) The word " limits" was replaced with
"re d "e rates."
NRC Comment: This proposed change was considered acceptable since it was consistent with the wording used in Step 1.
6.
Change:
(Module 1, Step 4) Substep 4.3, which required an Alert declaration if area radiation monitor (AR/)-22 (north site boundary)
or ARM-23 (south site boundary) indicated @ se rates greater than 1 mr/hr (milliroentgen per hour), was deleted.
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NRC Comment:
This substep was eliminated as a result of an event that occurred in 1989.
A description of this event can be found in Section 3.B of NRC Inspection Report No. 50-344/89-28, dated December 22, 1989 (see Open Item 89-28-02).
Followup on 89-28-02 was addressed in NRC Inspection Report No. 50-344/91-05, dated April 23, 1991.
The item remained open pending further action, including the revision of EP-001.
The event involved anomalous ARM-22 readings of greater than 1 mr/hr.
The operability / accuracy of the monitor at the low levels was determined to be questionable.
To prevent false readings from causing an Alert declaration, which would prompt full activation of onsite and offsite emergency res]onse facilities (ERFs), the licensee eliminated the use of tie two ARMS as an Alert initiating condition, but kept the monitors for the Site Area Emergency (SAE)
classification level.
The initiating condition for the SAE was a reading greater than or equal to 50 mr/hr.
This proposed change was considered acceptable, because NUREG-0654 does not specifically refer to the use of perimeter monitors, and the licensee's EALs provided for an Alert declaration based on field team measurements. TS instantaneous limits, and calculated dose rates carresponding to greater than or equal to 1 mr/hr at the exclusion area boundary (EAB).
This change addressed part of the pending action for Open Item 89-28-02; however, the item will remain open until all action is completed and verified in a formally issued version of EP-001.
7.
Change:
(Module 2, Step 3) The term " clad damage" was changed to
" equivalent clad damage."
NRC Comment:
The licensee's summary indicated that this term was changed to be consistent with post-accident sampling system (PASS)
procedures.
This proposed change was considered acceptable.
8.
Change:
(Module 2, Step 5) A new entry point from Module 3, Step 3 (steam line break inside containment with primary-to-secondary leakage) was added. The word " estimated" was added to Substep 5.2 to allow estimated leak rates to be used.
The leak rate in Substep 5.2 was changed from greater than 50 gpm (callons per minute) to greater than or equal to 50 gpm.
Substep B.3 (Loss of containment)
was expanded to include containment bypass and imminent containment failure.
A Containment Failura Definition Table (Table 2-1) was added to define the containment fcilures.
A time threshold of greater than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> was added to the failure of the equipment haten.
The time threshold for failure of both inner and outer doors or seals was reduced from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to greater than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
NRC Comment:
The new entry point from Module 3, Step"3 was added for internal consistency.
Adding the word " estimated was considered conservative since the event declaration could be made
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before exact calculations were completed to determine exact leak rates.
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This SAE EAL addressed the loss of two fission product barriers o?
the loss of one with the imminent loss of the second barrier.
The time periods associated with the loss of containment integrity in Table 2-1, referrea to in Subste) 5.3, should not be applied during an emergency if either of the other two barriers were lost (fuel cladding or reactor coolant system (RCS)).
This part of the proposed change was not considered acceptable, because it could allow for a loss of either the fuel cladding or the RCS with a concurrent loss of containment for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
This proposed change was not approved.
Licensee Response:
The licensee stated that this was a valid comment and proposed to delete the time periods associated with the loss of containment.
In addition, the licensee also proposed to add an additional statement (in the Table) to capture any other potential loss of containment (e.g., failed electrical penetrations).
At this time, this proposed action was considered acceptable and did not appear to decrease the effectiveness of the RERP.
9.
Chang:
(Module 2, Step 6) Reference to the Containment Definition Table (Table 2-1) referred to in Substep 5.3 was incorporated into General Emergency (GE) Substeps 6.lc and 6.2b.
A new entry point fromModule3, Step 4wasaddedtoaddressasteamg)eneratortube rupture (SGTR) in an unisolabie steam generator (SG,
Substep 6.3b was reworded to indicate that the SGTR was in a SG that has an unisolable leak resulting in a release pathway.
j NRC Comment:
This GE EAL addressed a loss of three fission product barriers or a loss of two fissior product barriers with the imminent loss of the third.
This EAL corresponded to NUREG-0654 GE No. 2.
The proposed changes in Substeps 6.lc and 6.2b, which involved the use of Table 2-1, were not considered acceptable, because it would allow for a loss of containment for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during a core melt or imminent core melt accident.
The latter two changes were considered acceptable since they provided additional guidance.
Licensee Response:
The licensee stated that this was a valid comment and proposed to delete the time periods associated with the loss of containment.
In addition, the licensee also proposed to add an additional statement (in the Table) to capture any other potential loss of containment (e.g., failed electrical penetrations).
At this time, this proposed action was considered acceptable and did not appear to decrease the effectiveness of the RERP.
10.
Change:
(Module 3, Step 1) The three previous substeps were incorporated into one.
As revised, the step required a UE declaration for a valid entry into Emergency Operating Procedure (EOP) El-2 " Faulted Steam Generator."
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NRC Comment:
This proposed change was considered acceptable because the EAL criteria was more specific and easily recognized by operators.
11.
Change:
(Module 3, Step 2)
Substep 2.lb was added to clarify that
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the UE declaration was based on the failure of the valve to reseat after pressure reduction.
NRC Comment:
Thisproposedchangewasconsideredacceptablesince it was consistent with NUREG-0659 UE No. 6.
12.
Change: (Module 3, Step 3) The previous Step 3 was separated into two steps (3 and 4).
Step 3 covered steam line breaks inside containment and Step 4 covered steam line breaks outside containment.
New Step 3 - Valid entry into El-2 was incorporated into the step, as Substep 3.la, to be consistent with Item 10 above.
Substep 3.1c was changed to eliminate refeience to high alarms on Process Radiation Monitor (PRM)-1 and ARM 15 as the s >ecific inc'icator for increased radiation levels in containment.
Tie new Substep 3.1c referred to " Indications of increasing radiation levels in containment." A new exit point to Module 2 was added to continue the assessment of fission product barriers.
New Step 4 - Valid entry into El-2 wat incorporated into the step, as Substep 4.la, to be consistent with Item 10 above.
Substep 4.lb was modified to clarify that the valves failed to shut or isolate the faulted SG.
Step 2 led directly into Step 4, since the failure of the valve to reseat caused the breach of containment.
A new exit point to Module 2, Step 6 was added to continue the assessment of fission product barriers.
The previous Step 4 was deleted because the assessment will be conducted in Module 2.
NRC Comment:
The proposed changes were considered acceptable since
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the changes were not substantive.
However, the licensee was questioned about the deletion of the two monitors.
Licensee Res)onse:
The licensee stated that it vanted this event to be declared )efore a high alarm was received on 'whese monitors.
l This response verified that the licensee's intent was to make the
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EAL more conservative.
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Change:
(Module 4, Step 2) The previous substeps were consolidated into one that used valid entry into E0P El-3, "SGTR" as the basis l
for the declaration.
A new entry point from Module 7, Step 3 was added.
t NRC Comment:
This proposed change was considered acceptable because the LAL criteria was more specific and easily recognized by operators.
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14.
Change:
(Module 4, Step 3) Substep 3.la now refers to valid entry into LI-3 rather than " symptoms" of a SGTR, Substep 3.2a was added (as an "and" statement) to cover any release to the atmosphere from the SGTR. The loss of offsite power aspect of this EAL was now contained in Substep 3.2b as entry' into Emergency Contingency Action (ECA)-0.0, " Loss of All AC Power.
A new entry point from Modale 2, Step 5 was added.
NRC Comment:
These proposed changes were considered acceptable because tiiey were consistent with NUREG-0654 SAE No. 3.
U:,e of the E0Ps made the EAL criteria more specific and easily recognized by operators. There was, however, no "To Module 4, Step 3" ar row on Module 2, Step 5 as indicated by the new entry point.
Licensee Response:
The licensee stated that his was a typographical error; the new entry point arron should have been from Module 5, Step 2, instead of Module 2, Step 5.
The licensee stated that this would be corrected in the next revis. a.
15.
Change:
(Module 4, Step 4) The wording in Step 4 was modified to delete reference to the pressurizer relief and safety valves.
The corresponding Substeps (4.2a and b) were also deleted.
The licensee's summary of changes stated that the reference to the pressurizer relief and safety valves was celeted because any release would be from the SG power operated relief valves (PORVs) and safety valves, not the pressurizer relief and safety valves.
NRC Comment:
These nroposed changes were considered acceptable; however, the licens. was questioned about the wording in the existing 4.lb.
This Substep referred to, " Symptoms for a SGTR per proposed change (i.e.p was not modified to be consistent with the Step 2.
This subste, valid entry into El-3).
The procedure was not internally consistent, and users were forced to return to Step 2 before proceeding through the remainder of Step 4.
Licensee Response:
The licensee stated that this was a valid comment and that the substep would be corrected in the next
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16.
Change:
(Module 4, Step 6) Suostep 6 lb and c were added to clarity that the UE declaration would not be warranted unless the pressurizer safety or relief valve failed to rescat after pressure was reduced to 2000 psig (pounds per square inch gauge) and the leak rate exceeded the primary system leak rates in Step 5.
NRC Response:
This pro)osed change was considered acceptable since it was consistent with 4UREG-0654 UE No. 5.
17.
Change:
(Module 4, Step 7) Entry into Off-Normal Instruction (ONI)-6, " Excessive Reactor Coolant Leakage" replaced the previous EAL that referred to uncontrolled RCS inventory loss or imminent loss resulting in leakage greater than 50 gpm.
A second substep (7.lb) was added to, capture the magnitude of the leakage.
The new
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substep stated that the leakage was " quantified or estimated as being greater than 50 gpm."
NRC Response:
This proposed change was considered acceptable since it was consistent with NUREG-0654 Alert No. 5.
18.
Change:
(Module 4, Step 8) The term " makeup pump capacity" was replaced with " charging pump capacity." The entire step was rewritten.
There are now two substeps; one for a loss of coolant accident (LOCA) inside containment and one for a LOCA outside containment.
The previous revision only addressed a LOCA inside containment and used terms "high" containment, pressure, sump level, and humidity.
The new Substep 8.1 used valid entry into El-1, " Loss of Reactor or Secondary Coolant," required by El-0, " Reactor Trip, Safety Injection and Diagnosis," to require declaration of the SAE based on a LOCA inside containment.
The new Substep 8.2 used valid entry into ECA 1.2, "LOCA Outside Containment," to require the SAE declaration.
NRC Comment:
The proposed change involving the term " charging pump capacity" was considered acceptable since it was consistent with NUREG-0654 SAE No. 1.
It should be noted that NUREG-0654 did not specifically address a LOCA outside containment.
This addition was considered an improvement.
Previous use of the term "high" caused confusion during the 1989 exercise.
This issue was incorporated into open item 50-344/90-04-01.
This proposed change sufficiently addressed the issue from the open item; however, the item will remain open until all of the elements in the item are verified in a formally issued version of EP-001.
Use of the E0Ps was acceptable because the EAL criteria was more specific and easily recognized by operators.
19.
Change:
(Module 4, Step 9) Modules 9 and 10 were reversed from the previous revision.
The licensee's summary indicated that the change was made so that the user would first review the step involving the faster developing scenario (loss of Emergency Core Cooling System (ECCS) versus initially successful ECCS).
\\ new exit point was added between steps 8 and 9 to continue fission product barrier assessment.
NRC Comment:
The change in the order of steps appeared acceptable.
The licensee was questioned about the language used in Substep 9.1.
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The substep referred the user to Step 8 rathe) than restating the El entry conditions used elsewhere in the module.
Licensee Response:
The licensee stated that this was a valid comment and that the substep would be corrected in the next revision.
20.
Change:
(Module 4, Step 10) This step was the previous Step 9.
Instead of referring the user to Step 8, the first Substep 10.la
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referred to wG in L1-1 (required by El-0) with initially successful ELG i mis combined the previous two substeps.
The second substep now referred to the failure to establish or maintain Residual Heat Removal (RHR) recirculation mode when required.
According to the licensee's summary of changes, the inability to establish RHR recirculation phase would eventually result from the loss of the containment cooling.
The substep that addressed the loss of containment now referred to the Table first referenced in Module 2.
NRC Comment:
This change was not acceptable because it was not conservative when compared to the previous revision and it was not consistent with NUREG-0654 GE No. Se.
This initiating condition required a GE declaration based on a LOCA with initially successful ECCS and the subsequent loss of containment cooling.
The licensee's orevious wording was consistent with the criteria.
As changed, Revision 6 would not provide for a GE until the loss of containment cooling (or some other problem) resulted in the failure of the RHR recirculation mode.
Since the loss of RHR recirculation r.ade, due to a loss of containment cooling, may not occur for some time, the GE declaration using Revision 6 could occur much later than the GE declaration using Revision 5.
In addition to the above, this proposed change included another non-conservative aspect; the reference to the status of containment.
Aside from the issue that the time limits were incorporated into the table,ince this scenario already represents a core mest sequencethe status of con step s where containment was already threatened.
The corresponding initiating condition in NUREG-0654 did not state that the status of containment should be considered for this scenario.
Licensee Response:
The licensee stated that this was a valid comment.
The licensee proposed to delete the present wording in Substep 10.lb and replace it with " Loss of containment cooling."
The licensee also proposed to delete Substep 10.lc, which referenced the loss of containment table.
At this time, this proposed action was considered acceptable and did not appear to decrease the effectiveness of the RERP.
21.
Change:
(Module 5, Step 1) Theundervoltagealarmwasdeletedfrom Substeps 1.1, 1.3a, and 1.4a.
The licensee s summary of changes stated that power could be lost for other reasons.
NRC Comment:
The proposed channes were considered acceptable.
However,someoftheexistingEXLswerenotconsistentwith NUREG-0654 (see below).
This module also required revision to incorporate the lessons learned from the Vogtle event (loss of offsite power in Modes 5 and 6).
This issue was being tracked as part of Open Item 50-344/90-04-01.
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The following items were not part of the Revision 6 proposed change, but were not acce) table because they were not conservative or consistent with NJREG-0654 UE No. 7:
a.
The Subste) 1.1 time limit of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before declaration of the UE 3ased on a loss of offsite power was not appropriate.
NUREG-0654 does not allow a time limit for this condition.
b.
The Substep 1.2 time limit of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> before declaration of a UE based on a loss of onsite AC power (loss of both emergency diesel generators (EDGs)) was not appropriate.
NUREG-0654 does not allow a time limit for this condition.
Licensee Response:
The licensee stated that these were valid comments and proposed to delete the reference to the TS in the step statement and delete the references to the time limits in Substeps 1.1 and 1.2.
At this time, this proposed action was considered acceptable and did not appear to decrease the effectiveness of the RERP.
22.
Change:
(Module 5, Step 2) Two substeps, sustained undervoltage alarms on both 12.47 kilovolt (KV) buses (greater than 5 minutes),
and inability)to energi.e at least one 4.16 KV Engineered Safety tunction (ESF bus from EDGs, were combined into one substep based on valid entry into ECA 0.0, " Loss of All AC Power." A new exit point to Module 4, step 3 was added.
NRC Comment:
These proposed changes were considered acceptable; however, there was no entry point at Module 4, Step 3 as indicated in Revision 6.
This typographical error was addressed in Item 14 above.
23.
Change:
(Module 5, Step 3) The time limit mentioned in this step was changed from 30 minutes to 15 minutes.
NRC Comment:
This proposed change was considered acceptable since it was consistent with NUREG-0654 SAE No. 6.
The discrepancy (i.e.,
not consistent with NUREG-0654) involving the Module 5, Step 3 time limit was an element in Open Item 50-344/90-04-01.
This proposed change sufficiently addressed the open item element; however, the item will remain open until all of the issues are verified in a formally issued version of EP-001.
24.
Change:
(Module 5, Step 5) The time period of 5 minutes was deleted from this step.
NRC Comment:
This proposed change was considered acceptable since it was conservative and made the step consistent with NUREG-0654 UE No. 8.
The change implemented a commitment made to NRC in 1984.
25.
Change:
(Module 5, Step 7) This step addressed the loss of control room (CR) annunciators and computer alarms for greater than 5
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The previous revision required an Alert declaration when all the CR annunciators were lost for greater than 5 minutes and when the computer alarms were lost for greater than 5 minutes.
The proposed change substituted " computer alarms" with the "SER computer" (Sequence of Events Recorder computer) to reflect the installation of the new system.
NRC Comment:
This change was considered acceptable since the SER is actually part of the annunciatur system. initiating condition from NUREG-065 The corres does not identify a time limit; however, this existing EAL was considered acceptable even though it contained a short time limit.
26.
Change:
(Module 5, Step 8) The term " computer alarms" was change to "5ER computer" as discussed in Item 25 above.
NRC Comment:
This change was considered acceptable for the same reasons discussed in Item 25 above.
steprequ(iredaUE,tobedeclaredifall3Auxiliaryfeedwater(AFW)
27.
Change:
Module 6 Step 1) The previous Step 1 was deleted.
The pumps were lost in Modes 1, 2, and 3, or when AFW flow indicators indicated zero flow 2 minutes after a reactor trip.
The licensee's summary of changes stated that this step was deleted because: 1) the event was not addressed by NUREG-0654, and 2) the AFW pumps were covered by TS, so a UE would be declared based on Module 7, Step 2 if a shutdown were initiated due to a loss of AFW.
The previous Substep 1.2 was equivalent to the previous Step 2.
NRC Comment:
This proposed change was considered acceptable since the Ut for this condition was covered by another module.
28.
Change:
(Module 6, New Ste) 1) The new Step 1 required the declaration of a SAE when t1ere was a valid entry into Functional Recovery Procedure (FRP) FR-H.1, " Response to a Loss of Secondary Heat Sink." The corresponding step in the previous revision required this condition to exist for 30 minutes before requiring a declaration.
NRC Comment:
This proposed change was considered acceptable since it deleted the time limit.
Use of the FRP raade the EAL criteria more specific and easily recognized by operators.
29.
Change:
(Module 6, Steps 2 and 3) Steps 2 and 3 were deleted.
The events were combined and incorporated into the new Step 1 discussed
in Item 28 above.
NRC Comment:
This proposed change was considered acceptable since the changes were not substantive.
This step required a GE declaration if the' sym(Module 6, New Step 2)ptoms of Step I were met (valid entry into 30.
Change:
charging flow lost).
The step was also expanded to include E E if the symptoms of Step I were met and charging flow was available, but
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theRCScouldnotbedepressurizedandSafetyinjection(51)orRHR flow established within 30 minutes or when ATW flow could not be restored within 30 minutes.
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NRC Comment:
This change was considered acceptable '.ince it was consistent with NUREG-0654 GE No. Sb.
Expanding the scope of the EAL was considered acceptable.
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31.
Change:
The Substep time limits were changed to be consistent with the 15.
The time limit for the failure of the containment isolation valves was changed from one hour to four hours.
One hour was added for failure of an equipment hatch or seal (Substep 1.2).
The time limit for both inner and outer doors on either of the two airlocks was decreased from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to one hour.
NRC Comment:
This EAL corresponded to NUREG-0654 UE No. 8.
The time limits used in the proposed change were consistent with the 15; therefore, this change was considered acceptable.
32.
Change:
(Module 7, Step 3) New exit points were added to Modules 3
and 4.
NRC Comment:
This propased change was considered acceptable since it corrected an internal inconsistency.
33.
Change:
(Module 7, Step 6) This step was reworded to indicate that the step applied to all moaes, not just mode 5.
Substep 6.1 was changed to indicate that the loss of both RHR and the inability to sustain natural or forced circulation was required for an Alert declaration.
The "and" in the proposed change was an "or" in the previous revision.
The words "and rising" were added to the Substep 6.2 statement regarding the temperature of the RCS; RCS temperature increases to greater than 200 degrees Fahrenheit and rising.
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NRC Comment:
This proposed change was considered acceptable since it was consistent with NUREG-0654 Alert No. 10.
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34.
Change:
(Module 7, Step 7) The step was reworded to clarify that it applied to reaching or maintaining hot shutdown.
Substep 7.lb was changed from " inability to establish high pressure injection" to
" inability to establish charging flow." Substep 7.2a was modified to refer to entry into FR-H.1 as in Module 6.
Substep 7.3c was modified to cover the situation where AFW was available, but its use would not control heatup.
A flow path from Step 6 to Step 7 was added to show a progression.
.
NRC Comment:
All of the proposed changes were considered acceptable.
The matter of tie high pressure injection versus charging flow was one of the elements in Open Item 50-344/90-04-01.
During the licensee's 1989 exercise, there was some confusion regarding the previous wording, "high oressure injection " which led to a delay in event classification.
Personnelresponsibleforevent classification did not know whether "high pressure injection" included the centrifugal charging pumps.
This proposed change
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appeared to sufficiently address the issue from the open item; however, the item will remain open until all of the elements are verifi?d in a formally issued version of EP-001.
35.
Change:
(Module 8 Step 1) This step required an Alert declaration for a reactor trip where subtriticality was not achieved or where the reactor returned to criticality after the trip.
Substep 1.lc, which required an Alert declaration if this situation occurred during a manual trip, as opposed to ar, automatic trip, was deleted from this step.
NRC Comment:
This EAL corresponded to NUREG-0654 Alert No.11.
This proposed change was considered acceptable since operator initiation of a manual trip, with failure to achieve subcriticality, would require entry into Functional Recovery Procedure FR-5.1,
" Anticipated Transient Without Scram" (ATWS) and declaration of a SAE in accordance with Module 8, Step 2.
A manual trip, where subtriticality was achieved, would not require an Alert declaration.
Example initiating condition No. 11 in NUREG-0654 required both failure to initiate and complete a scram and failure to bring the reactor subcritical for the Alert condition.
If subtriticality was achieved, even though there was a malfunction of the Reactor Pre?.ection System (RPS), manual or automatic components, an Alert declaration would not be required.
36.
Change:
(Module 8, Step 2) The wording in the substep has been changed to refer to valid entry into FR-S.1, "ATWS."
NRC Comment:
This proposed change was considered acceptable since it made the EAL criteria more specific and easily recognized by operators.
37.
Change:
(Module 9, Step 1) There was no change associated with the Revision 6 change bar for this step.
NRC Comment:
The change bar in this step appeared to be held-over from the previous revision.
Licensee Response:
The licensee concurred with the comment and stated that the change bar would be deleted in the next revision.
38.
Change:
(Module 11, Step-1) The step was modified to delete reference to specific areas of the plant.
The step now applied to a fireanphereintheprotectedarea.
Substep 1.2 was modified such that a valid" alarm on a fire protection device, indicating a fire lasting greater than 10 minutes, would require an UE.
The previous wording required confirmation by observation.
This qualifier was deleted in Revision 6.
l NRC Comment:
This proposed change was considered acceptable since it was consistent with NUREG-0654 UE No. 10.
However, the module l
revision number still indicated that it was Revic'on 4, rather than Revision 6.
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Substep 1.3 was not considered acceptable, even though it was not changed, because it was not consistent with NUREG-0654.
Substep 1.3 required a UE declaration if the " fire could affect safety systems in the judgement of the Shift Supervisor." The NUREG-0654 example initiating condition at the Alert classification level (No. 13)
stated that an Alert was warranted if a fire was "potentially affecting safety systems."
Licensee Response: The licensee stated that these were valid comments and proposed to move Substep 1.3 to Step 2 (the step for the Alert level) as a new Subste) 2.2 in the next revision.
The licensee proposed to add this su) step as an "and" statement.
The licensee also stated that the revision number would be corrected in the next revision.
At this time, this proposed action was considered acceptable and did not appear to decrease the effectiveness of the RERP.
39.
Chanc e:
(Module 11, Step 2) The words "potentially affecting" were addec to the step.
located in specific areas of the plant (ged to refer to a fire Substep 2.1 was chan areas where safe shutdown equipment was located).
A list of these areas was included as Table 11.1.
A qualifier was added to indicate that the fire must last for
" greater than 10 minutes from initiating fire fighting activities."
NRC Comment:
The time limit referred to in the substep was not acceptable because any fire, regardless of length of time, should be sufficient to prompt an Alert declaration, if safety systems are potentially affected.
Delaying the start of the clock until fire fighting activities were initiated was not considered acceptable since the response time could vary and be subject to delay.
Licensee Response:
The licensee stated that this was a valid comment and proposed to delete the time limit and the response qualifier from Substep 2.1 in the next revision.
At this time, this proposed action was considered acceptable and did not appear to decrease the effectiveness of the RERP.
40.
Change:
(Module 11, Step 3) Comments applied to this step even though there were no changes.
NRC Comment:
This step addressed a " fire defeating redundant safety system trains or functions concurrent with plant conditions that may require their use in accident mitigation," and required the declaration of an SAE.
The SAE example initiating condition in NUREG-0654 (No. 11) stated that an SAE was warranted for a fire
" compromising the functions of safety systems." The event described by the licensee was not consistent with NUREG-0654 and was not conservative, because it stated that the safety systems have to be defeated and plant conditions have to exist such that the safety systems "may" be needed.
If a fire rendered redundant safety system trains inoperable, and the safety systems were needed, the control of the plant would be in question and a GE should be considered.
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A Licensee Response:
The licensee stated that this was a valid comment and 3roposed to delete the statement, dent mitigation," plant
" concurrent with conditions t1at may reguire their use in acci from Step 3 in the next revision.
At this time, this proposed action was considered acceptable and did not appear to decrease the effectiveness of the HERP.
41.
Change:
(Module 14 Ste) 4) Substep 4.1 was changed to clarify that the toxic or f,lamman a gas release could be onsite or offsite.
Substep 4.2, which required a UE declaration if a toxic F 'lammable gas release warning was received from offsite sources was deleted.
Thelicensee'ssummaryofchangesstatedthatanoffsitewarning alone should not be the basis for the UE.
NRC Comment:
This change was considered acceptable since it was consistent with NUREG-0654 UE No. 14.d.
Chang:ind(ication"inregardtotheexistenceofaturbinecasingThe word " o 42.
Module 15, Step 2)
with penetration.
NRC Comment:
This proposed change was considered acceptable since it was more conservative.
43.
Change:
(Module 16, Module 1, Step 1) Editorial changes were made to make the summary module consistent with the actual module.
NRC Comment:
The wording used in the summary module was not exactly consistent with that used in the actual module.
Module 1, Step 1 stated " exceeded on the average over a 1 hr period." Module 16 stated "when averaged over a 1 hr period."
Licensee Response:
The licensee concurred with this comment and stated that the words used in the summary module would be made consistent with the actual module in the next revision.
This proposed action was considered acceptable.
44.
Change:
(Module 16, Module 3, Steps 2, 3, and 4) Editorial changes were made to make the summary module consistent with the actual module.
NRC Comment:
This proposed change was considered acceptable.
45.
Change:
(Module 16, Module 4) Editorial changes were made to make the summary module consistent with the actual module.
NRC Comment:
This proposed change was considered acceptable except That the new Step 2 entry point from Module 7, Step 3 was not added.
Licensee Response:
The licensee concurred with this comment and stated that the entry point would be added in the next revision.
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This proposed action was considered acceptable.
46.
Change:
(Module 16, Module 5) Editorial changes were made to make the summary module consistent with the actual module.
The 30 minute threshold in Step 3 was changed to 15 minutes.
NRC Comment:
This proposed change was considered acceptable.
The need to correct the time period in this module was one of the elements in Open Item 50-344/90-04-01.
This proposed action was sufficient to address the issue in the open item; however, this item will remain open until all of the elements are verified in a formally issued version of EP-001.
47.
Change:
(Module 16, Module 6) Editorial changes were made to make the summary module consistent with the actual module.
NRC Comment:
This proposed change was considered acceptable.
48.
Change:
(Module 16, Module 7) Editorial changes were made to make the summary module consistent with the actual module.
NRC Comment:
This proposed change was considered acceptable.
50.
Change:
(Module 16, Module 11) Editorial changes were made to make the summary module consistent with the actual module.
NRC Comment:
This proposed change was considered acceptable.
3.
Exit Interview An exit inte,w: ;, via telephone conference call, was held on May 16, 1991, to discuss the preliminary findings of this in-office inspection.
The licensee personnel who participated in the conference call are identified in Section 1 of this report.
The licensee was informed that some of the proposed changes were not considered acceptable and were not approved, because they were not consistent with NUREG-0654 and were not conservative when compared. These proposed changes are described in Items 8, 9, 20, and 39.
The licensee was informed that some of the existing EAls were not considered acceptable, because they were not consistent with NUREG-0654 and were not conservative when compared.
These EALs are described in Items 21, 38, and 40.
The licensee was also informed that some of the modules / steps contained internal inconsistencies (editorial issues).
These issues are described in Items 1, 14, 15, 19, 37, 43, and 45.
All of these items were discussed with the licensee during the conference call.
The licensee's response to each of the above items is described in Section 2 of this report (refer to individual item numbers).
The licensee's proposed action, captured in the response to Items 1, 8, 9, 14, 15, 19, 20, 21, 37, 38, 39, 40, 43, and 45, will be tracked as Open Item 50-344/91-16-01.
During the conference call, the licensee stated that all of the comments were valid and would be corrected.
The licensee also stated that it would attempt to issue Revision 7 by July 1, 1991.
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