IR 05000397/1987012
| ML17279A819 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/04/1988 |
| From: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| NUDOCS 8802120244 | |
| Download: ML17279A819 (10) | |
Text
REGULATORY INFOPMATION DISTRIBUTION SYSTEM (RIDS)
B ACCESSION NDR: 8802120244 DOC. DATE: 88/02/04 NOTARIZED:
NO DOCKET
FACIL: 50-397 WPPSS Nuc I ear Pro J ecti Unit 2 Washington Pub I ic Powe 05000397 AUTH. NAME AUTHOR AFFI LIATION SC*R*NOI R. A.
Region
Ofc of the Director REC IP. NAI'1E RECIPIENT AFFILIATION SORENSENi G. C.
Washington Public Poeer Su'pplg System SUBJECT:
Foreards Emergency Preparedness Branch analysis of emergency action levels identified in event classification PT ocedure EPIP 13. 1.
1.
~ during Insp Rept 50-397/87-12 on 870518-22.
DIBTRIBUTION CODE:
IEOID COPIEB RECEIVED: LTR l
ENCL I
SIZE:
TITLE: General (50 DI:t)-Insp Rept/Notice of Violation Response NOTES:
RECIPIENT ID CODE/NAIIE PD5 PD INTERNAL:
ACRS DEDRQ NRR/DLPG/PEB NRR/DOEA DIR NRR/DREP/RPB NR R /P MI AS /
ILR 8 OGC/HDS2 RES/DRPS DIR COP IES LTTR ENCL
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1 RECIPIENT ID CODE/NAME.
S*i'1WORTHi R AEOD NRR MQRISSEAUi D NRR/DLPG/GAB NRR/DREP/EPB NRR/DRIS DIR OE L MANiJ I
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COPIES LTTR ENCL
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DOCKET NO. 50-397
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4198S Washington Public Power Supply System P. 0. Box 968 3000 George Washington Way Richland, Washington 99352 Attention:
Mr. G. C. Sorensen, Manager Regulatory Programs Gentlemen:
Our May 18-22, 1987, inspection identified some concerns with certain Emergency Action Levels (EALs) in your event classification procedure No. EPIP 13.1.1.
These 'concerns were documented in Detail Sections 6 and 7 of Inspection Report No. 50-397/87-12.
With respect to these concerns, we had comnitted to submitting them to our Emergency Preparedness Branch in Bethesda, Maryland, for their review and evaluation.
We have received the Emergency Preparedness Branch's evaluation and have enclosed their analysis for your information.
This analysis was discussed on February 2, 1988, during a telephone conversation between Mr. Ray Fish of my staff and your Mr. G. D. Bouchey.
Based on the February 2 discussion, it is our understanding that you will review the enclosed analysis and take corrective action you deem appropriate.
We would be willing to hold an additional telephone discussion or arrange for a meeting, if you believe it necessary, to finally resolve this matter.
Sincerely, Enclosure as stated Ross A. Scarano, Director Division of Radiation Safety
Safeguar ds ggQggggP4P 8802~
PDR ADOCK 0 pDR Q
p
cc w/encl osure G. D. Bouchey, WPPSS C. H. Powers, WNP-2 Plant Manager P. L. Powell, MNP2 Licensing Manager R. B. Glasscock, Director, Assurance
&
Licensing G. E. Doupe, Esq.,
MPPSS A. Lee Oxsen, Asst.
Managing Director for Operations, MD/1023 State of Mashington (Curtis Eschels)
N. S. Reynolds, Esq.
(202) 857-9800 Bishop, Cook, Purcell
& Reynolds 1200 Seventeenth Street, N.M.
Suite 700 Washington, D.C.
20036 bcc: Terry Strong DSHS, Office of Radiation Protection Mail Stop LE-13 Olympia, Washington 98504 ST C
PY ES NO RV/gmd~+
2/Ij /88 EQU ST COPY REQUEST OP YES NO YES
FWenslawski RSc no 2/ ~/88 2/ / 8 REQUEST COPY REQUEST C
PY YES NO YES NO R
NO
Analysfs of NP-2 Elergencl Actfon Levels (EALI)
Conclusfon 1:
The lfcensee's ffre EALs are deffcfent Ken compared to NURE6-0654.
~Ana1 sIs:
The fo11owtng Is a compartson between the NNEE-06Q exwseI ~ tntttatIaN condftfons for ffre and the lfcensee's ffre EALs (EPIP )3.),) dated 4/13/87).
Event KUREG-0654 Ffre sfthfn the plant lastfng more than 10 mfnutes.
Lfcensee's EAL A ffre fn a safety-related portfon of the Protected Area requfr fng actfvatfon of the Plant Emergency Teaa (ffre brfgade).
A1ert Ffre potentfally affectfng safety systems.
A ffre affectfng a safety SySCOOe SAE 6E Ffre compromfsfng the functfons of safety systems.
Any a+or fnternal or external events (e.g., ffres, earthquakes, substan-tfally beyond desfgn basfs) ehfch could cause massfve co+non damage to plant systems resultfng 5n any of the above.
Ffre affectfng safety systems to the pofnt of fnadequate control of the plant.
Any condftfons that warrants the act5vatfon of the Technfcal Support 'Center, the ratfons Support Center.
and Eaer-genty'peratfons Facf1 5ty for accMent assessment, 5n-plant response, and offsfte ceergency response to afd fn the fap)e-aentatfon of protectfve actfons.
Exaaples fnclude the following:
A secur fty compreefse resultfng 5n the total loss of control of the plant.
W0TE:
A summary of spaptoeatfc and sftuatfon based fnftfatfng condftfons can be found fn Attachments B and C, respectfvely,'n NUREG-0654 the example of an Unusual Event for a f5re fs crfsp, non-gudgemental and unequfvocal.
The 15censee's unusual event classfffcatfon fs based, on a
secondary action 5.e.,
response to the fire by the fire brigade. lt requires Judgement 5.e.,
5s the f5re 5n a safety related port5on of the protected area2 F5nally, 5t has a threshold that 5s too h5gh f.t.> safety-related port5on of the protected area.
10 CFR Part 50 Append5x R contemplates the adverse 5epact of fir to equipment that 5s:
(1) safety-related (2) 5aportant to safety but not safety-related, and (3) non-safety related.
lJnless the des5gn of the plant 5s such that fires in areas housing equipment in categories f2 and t3 w511 not impact the safety-related equipment, the threshold in the EAL 5s too high.
The words "potentially affecting a safety systea'n the example of an Alert for a fire in NUREG-0654 are aore conservative than 'affecting a safety systea'hfch is the licensee's Alert for a fire.
As pointed out by the region, the licensee's Alert for a fire is close to the exaiple of a Site Area Emergency 5n NUREG-0654.
The words "compromising the functions of safety systeas'n the example of a $5te Area Emergency in NVREG-0654 are more conservative than the licensee's Site Area Emergency for a fire.
The licensee's words 'to the point of inadequate control of the plant's philosoph5cally closer to a general emergency.
More 5aportantly, 5t is ambiguous and requires sore Judgement than the NUREG-06S4 example.
The licensee's General Emergency for a fire 5s not explic5t.
The EAL cited would
,
seem to encompass a fire but 5t 5s apparently redundant with both the NUREG-0654 example for a Site Area due to staff augmentation and the 75c'ensee's EAL for a Site Area Emergency due to staff augmentatio Conclusfon 2:
The lfcensee's EAL for the Unusual Kveli QL relatfng to tochnfcal specfffcatfons fs deffcfent when compared to NRE64554.
~nna1 s5s:
The exanpIe fnttlatfng condft5on in NNM-0654 for the Ilnosaal Event related to technfcal specfffcatfons fs "other plant condftfons exfst that...requfre plant shutdown under technfcal specf ffcatfon requfreaents or fnvolve other than normal contro11ed shutdown..."
Some 15censee's EALs requfre reportfng when shut-down commences, others requfre reportfng ffcold shutdown fs reached before the fnftfatfng event fs resolved (Ve have accepted both).
The lfcensee's EAR for the Unusual Event related to technfcal spec5f5catfons fs:
Any plant condftfon requfrfng plant shutdown as a result of exceedfng the 15mftfng condftfons for operatfon and assocfated actfon fteas, (as deffned fn the NfP-2 Technfcal Specfffcatfons} and fs of fieedfate safety concern or where other than a norlal controAR shutdown takes place... (emphasrs fn orfgfnal)
The 15censee's EAL fs less conservatfve than the NURM-0654 example.
The qvalfffer 'and fs of faeedfate safety concern,'hfch fs also fncluded 5n the 75censee's deffnftfon of an Unusual Event, requfres Judgea.nt that could take extra t5me and could result fn varfatfons 5n classfffcatfon.
It could also undermfne lfcensee or lNC efforts to control the qua)ftI of reportfng.
In 5ts own revfew of emergency procedures dated September 1), 1987, SubJect:
Bnergency Actfon Level Incfdent Classfffcatfon Assessment,'he lfcensee pofnts to three lfcensee Event Reports that would have been classfffed as Unusual Events
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under HNM-0654 crfterfa but the EPIP gufdeIfne )udgment would peraf t the event from not befng ciassfffed.
Specfffca11y they were:
LER 87-002 LER 85-004 LER 84-008 RFM<LoLo Level Actfon ECCS Igectfon to Reactor Turbfne Valve Fast Closure ECCS Ingectfon Low Supp Pool Level 4 3/4" None of these events were classfffed by the lfcensee as an Unusua)
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i5 Conclusfon 3:
The licensee's entire EAL scheme is undermined by the super-
'pPPtl big tt I
f'ddg t'
f f Hgd which fs to be applied by the decfsfoeeker after a technfca)
assessaen$
has been sade.
~Anal sos:
The ltcensees EAL scheme has symptomattc fn$tfat1ng condtttons backed by situation (or event) based fnftfatfng condftfons.
Thfs fs the kind of EAL scheme that we encourage.
However, all of the EAL crfterfa are undermfned by the introduction of an additional step after the technfcal assessment has been sade.
Specifically, the followfng statement appears fn a box on the first page of EPlP 13.1.1:
Caution:
This procedure fs only a guide to emergency classification.
Tfie Anal consideration fn all classifications is one of Judgement on the part of the Plant Emergency Ofrector.
Additionally, another warning appears fn a box on the first page of Attachment A
'Guidance For Classifying Baergencfes':
Cautfon:
Thfs procedure fs only a guide.
Proper Judgement based on
~asa ety first'rfnctple must be used as the ftna1 consSderatton for all classifications.
I Addftfonally, each Action Level fs introduced with the sentence: 'lf any of the folloufng conditions extst, consider dec1artng an All of the above results fn the crfterfa not befng sufffcfent fn themselves for a declaration of an event.
Further, the term "safety first" fs not defined fn the EPIP.
Additionally, the Plant Emergency Director and the Operations Manager are instructed fn the EPlP to use "professfonal Judgement'long with the crfter ia for classf ffcatio C
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In its own review of emergency procedures dated September )). )987, SubJect:
"Emergency Action Level Inc5dent Class5ficat5on Assessment>'he licensee states:
A a or difference between the Emergency Plan and the KPIP states tha oth sywptons and s5tuat5ons are guidelines only and subJect to the judgement of the responsible Emergency D5rector.
The Emer-gency Plan indicates only situations are guidelines subJect to Judgement calls. It iwplies that symptoms cause automatic emer-gency classifications.
lfRR/tlRC have reviewed both documents without coamenting on the difference; hwver, the Plant should resolve the differences between the EPIP and Emergency Plan.
(emphasis in original)
The staff believes that the introduction of "Judgement'r
'professional Judgement'nto the EAL scheme on top of the basic determination of whether a technical criteria is met, undere5nes the purpose of hav5ng predetermined cri-teria for EALs.
Some technical Judgement may be required to detereine if tech-nical criteria have been Net but the addition of Judgement'r
'professional Judgement" after the techn5cal criteria have been deemed to be act could be a disservice to the person responsible for classifying the emergency.
After determining that technical cr5teria have been set, the person must apply sowe additional, 511 defined, subJective Judgement before eak5ng the ult5aate classi-ficatfon.
The opportunity for others to second guess this additional. subJective
'Judgement'ay delay or prevent a proper classif5cation.
Applicat5on of this
"Judgement" by different persons could result 5n different classifications, wh5ch 5s of safety concern.
This additional subJective criteria could also thwart the licensee's or NRC's efforts to achieve reproduceable, high quality classifica-tions.
Finally, the staff believes that the EPIP "guidance'r
'guide'lines'or classffying an emergency should be based on f5rm criteria for classifying an emergenc '