IR 05000397/1993042
| ML17290A845 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/14/1993 |
| From: | Good G, Pate R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17290A844 | List: |
| References | |
| 50-397-93-42, NUDOCS 9312300056 | |
| Download: ML17290A845 (7) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION REGION V
Report No.
Docket No.
License No.
Licensee:
Facility Name:
Inspection at:
50-397/93-42 50-,397 NPF-21 Washington Public Power Supply System 3000 George Washington May P. 0.
Box 968, HD 1023 Richland, Mashington 99352 Washington Nuclear Project No.
(WNP-2)
Walnut Creek, California Inspection Dates:
September 29 through November 24, 1993 Inspector:
oo
,
rgency repare ness na yst ate sgne Approved by:
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.
a e, se Safeguards, Emergency Preparedness, and Non-Power Reactor Branch Fz gp p~
ae age SUMMARY:
In-.Office Ins ection on Se tember 29 throu h November
1993 Re ort No.
~7-4 Areas Ins ected:
In-office inspection to review Revision 18 to emergency plan implementing procedure (EPIP)
13. 1. 1, "Classifying the Emergency."
Inspection procedures 82701 and 92701 were used.
Results:
Host of the changes in Revision 18 were considered acceptable.
Many of the changes addressed an open item identified'during the review of Revision 17.
The open item, which consisted of seven elements, was closed during this inspection (see Section 3).
One new open item was identified (see Section 4).
With the exception of emergency action level (EAL) A-32, the changes in Revision 18 to EPIP 13. 1. 1 continued to meet the standards in 10 CFR 50.47(b)
and the requirements in 10 CFR 50, Appendix E.
No violations of NRC requirements were identified.
9312300056 9312l4 PDR
'ADOCK 05000397 PDR
DETAILS 1.
Persons Contacted
- p
'*D
- K.
G.
- R.
Bagan, Emergency Planner Larson, Hanager, Emergency Preparedness Lewis, Technical Specialist, Licensing Ray, Principal Emergency Planner Utter, Supervisor, Emergency Preparedness Operations
- Denotes participation in the November 24, 1993, telephone exit interview.
2.
0 erational Status of the Emer enc Pre aredness Pro ram Ins ection Procedure 82701 a 0 b.
Back round Revision 18 to emergency plan implementing procedure (EPIP) 13.1. 1,
"Classifying the Emergency,"
dated September 7,
1993, was submitted on September 8,
1993, in, accordance with 10 CFR 50, Appendix E, Paragraph V.
The licensee implemented Revision 18, without prior approval, under the provisions of 10 CFR 50.54(q).
This in-office inspection was conducted to satisfy
CFR 50, Appendix E, Paragraph IV.B, which specifically requires that emergency action levels (EALs) be approved by the NRC.
Regional emergency preparedness staff evaluated the changes to the procedure text and EALs to determine whether the changes decreased the effectiveness of the WNP-2 Emergency Plan, and whether the changes continued to meet the standards in 50.47(b)
and the requirements of 10 CFR 50, Appendix E.
Evaluation Host of the changes in Revision 18 addressed the seven elements of an open item identified during the review of Revision 17.
The changes associated with that open item are discussed separately in Section 3, below.
The licensee initiated the remaining changes to address administrative matters and internal comments identified during training.
The inspector conducted conference calls with the licensee on November 2 and 19, 1993, to discuss the details of the review and to obtain additional clarification.
All of the inspector's comments/questions required for NRC approval were satisfactorily resolved during the conference calls; however, there were two comments that prompted further licensee attention.
These two comments, and the licensee's response to each, are discussed below:
(1)
Comment:
Terminology used in S-16, G-10, and the spade footnote was not consistent and could be confusing.
The EALs and footnote referred to "hydrogen burn," "hydrogen deflagration,"
and "explosive levels."
Hydrogen and oxygen concentrations were given for "hydrogen burn" and "hydrogen deflagration" but not for "explosive levels."
f
~Res onse:
During the November 19, 1993, conference call, the licensee proposed to substitute the term "combustible limits" for "hydrogen deflagration" in G-10 (consistent with the emergency operating procedures (EOPs)
and substitute the S-16 hydrogen and oxygen concentrations for the term "explosive levels" in the spade footnote.
The licensee stated that these changes were planned for Revision 19 to 13.1. 1.
(2)
Comment:
G-12, the general emergency (GE) fire EAL, appeared out-of-place in the U-43 sequence (external range fire no alert or site area emergency (SAE)).
The U-52/A-31/S-27 sequence (internal fire affecting safety systems)
appeared to be a more logical location for the EAL.
The need to hunt for the EAL could delay event classification (poor human factors).
It should be noted'that this EAL was not changed in Revision 18.
~Res onse:
During the November 19, 1993, conference call, the licensee proposed to relocate G-12 to the internal fire sequence.
The licensee stated that this change was planned for Revision 19 to 13.1.1.
Although correction of the two items above was not required for procedure approval, the licensee's proposed actions were considered appropriate.
3.
Action on Previous Ins ection Findin s
Ins ection Procedure 92701 Closed 0 en Item 397 9305-02
- The licensee committed to address seven comments in Revision 18 to 13. 1. 1.
The seven comments, along with the licensee's original response and the current status (based on a review of Revision 18),
are discussed below:
'a ~
Comment: Specific criteria to define the loss/potential loss of fission product.barriers has not been included in the EALs.
~Res onse:
The licensee. committed to address this comment in Revision 18 to 13. l.l.
The licensee proposed to add a footnote which would identify specific loss criteria (plant parameters, instrument readings) for each barrier and define the concept of potential loss.
Some examples of potential loss criteria would also be included in the footnote.
Current Status:
A definition of potential loss, with examples for each fission product barrier, was included in Revision 18.
During the November 19, 1993, conference call, the licensee requested to change its previous commitment regarding the incorporation of specific criteria to define the loss of fission product barriers.
The licensee stated that a letter which would provide examples of lost fission product barriers would be issued to senior reactor operators (SROs)
in the near futur Based on the licensee's previous commitment to adopt the NUHARC EAL methodology, and the interim measures, the licensee's actions were considered acceptable.
The issuance of the letter to the SROs will be verified in a future inspection (see Section 4, below).
Comment:
The relationship of A-15 (alert EAL) to S-16 (SAE EAL) was not clear.
~Res onse:
The licensee committed to address this comment in Revision 18 to 13. 1. 1.
The licensee proposed to delete S-16 and broaden the scope of A-15.
Current Status:
The licensee deleted S-16 in Revision 18.
During the November 19, 1993, conference call, the licensee'equested to change its previous commitment regarding A-15.
Based on the deletion of S-16, and.the discussion that occurred during the conference call, the licensee's actions were considered acceptable.
Comment:
Pre-determined effluent/radiation monitor readings, corresponding to threshold site boundary dose rates for the SAE and GE classification levels, have not been incorporated into the EALs.
~Res onse:
The licensee committed to address this comment in Revision 18 to 13. 1. 1.
The licensee proposed to include the calculated threshold effluent/monitor readings as new SAE and GE EALs.
The licensee also proposed to incorporate the use of a 15-minute window to verify'offsite doses by performing an actual dose calculation.
If the. calculations could not be performed within 15 minutes, the event would be classified based on the EAL monitor reading.
Current Status:
This element was satisfactorily addressed in Revision 18.
Comment:
The wording used in A-32 appeared vague.
Specific thresholds or guidance to aid in event classification were not identified.
~Res onse:
The licensee committed to address this comment in Revision 18 to 13. 1. 1.
The licensee proposed to include examples of specific threshold values based on occupancy requirements.
Current Status:
The threshold values provided in A-32 were considered acceptable; however, the two parts of the EAL threshold values for areas requiring continuous occupancy and threshold values for areas requiring infrequent access were incorrectly joined by an "and" (as opposed to an "or").
During the November 19, 1993; conference call, the licensee proposed to change the "and" to an "or."
The licensee committed to correct the EAL in Revision 19 to 13. 1. 1.
This action was considered
necessary for approval of 13.1. 1.
Correction of the EAL will be verified in a future inspection (see Section 4).
Comment:
The basis for the use of the one-.hour time threshold in A-30 was unclear.
~Res onse:
The licensee committed to address this comment in Revision 18 to 13. 1. 1.
The licensee proposed to reword the EAL to require an alert declaration if residual heat removal (RHR) trains A or B were unable to maintain reactor coolant system (RCS) temperature less than 200 degrees Fahrenheit in modes 4 or 5.
The licensee also proposed to delete 0-51 since there was no corresponding unusual event (UE) initiating condition in NUREG-0654.
Current Status:
This element was satisfactorily.addressed in Revision 18.
Comment:
The plant safety equipment referred to in the basis for the UE reactivity control initiating condition on page 19 of 30 (Attachment 4.7)
was unclear.
This comment prompted the licensee to reconsider the symptomatic EALs for reactivity/reactor power (U-l, A-l, and S-l).
~Res onse:
The licensee committed to address this comment in Revision 18 to 13.1.1.
After reconsideration, the licensee proposed to.
modify the wording in U-1 and add a new GE EAL as part of the progression.
The UE would be required if a reactor scram were initiated, and more than one control rod did not insert to position 00, but the reactor was shutdown.
The new GE EAL would be similar to S-1 but would add that core damage was evident.
The licensee also stated that the corresponding portions of Attachment 4.7 would be modified to match the new EALs.
Current Status:
This element was satisfactorily addressed in Revision 18.
Comment:
Revision 17 contained numerous editorial errors.
The following examples were noted: grammatical, inconsistent use of abbreviations, typographical, use of superscript rather than subscript, incorrect use of the term "EAL," and incomplete/
incorrect use of "revision bars."
In addition to the above, there were also numerous inconsistencies noted in Attachment 4.8 (NUREG-0654 cross-reference).
Collectively, the editorial errors described above indicated a need for the licensee to pay closer attention to detail during the review process.
~Res onse:
The licensee committed to correct the editorial errors in Revision 18 to 13.1.1.
Current Status:
Many of the editorial errors were corrected in Revision 18; however, some new ones were introduced.
The editorial
~-
e
comments were discussed with the licensee during the November 2 and 19, 1993, conference calls.
Since the editorial errors would not affect event classifications, no further action was required to address this element.
This item is considered closed.
4.
Summar of New Issues Two new issues were identified during this in-office inspection; As detailed in Sections. 3.a, and 3.d, above, the licensee committed to correct the issues in Revision 19 to 13.1. 1.
For clarity, the two issues and the licensee's proposed actions are summarized below:
a.
Specific criteria to define the loss of fission product barriers has not been included in the EALs.
The licensee proposed to issue a letter to SROs which would provide examples of lost fission product barriers.
b.
The two parts of A-32 threshold values for areas requiring continuous occupancy and threshold values for areas requiring infrequent access were incorrectly joined by an "and" (as opposed to an "or")
The licensee proposed to change the "and" to an "or" in A-32.
The commitments described above will be verified during a future inspection (397/9342-01).
5.
Exit Interview An exit interview, via telephone, was held on November 24, 1993, to discuss the preliminary findings of the in-office inspection.
Section
of this report identifies the licensee personnel who participated in the conference call.
The licensee was informed that no violations of NRC requirements were identified.
The inspector summarized the findings described in Sections 3-4 of the report and reaffirmed all commitment's.
The inspector stated that, with the exception of A-32, -'- and the mode-dependent EALs which are awaiting the completion of NRR's shutdown risk study (see open item 397/9305-01) the incremental changes between Revision 17 and 18 to EPIP 13.1. 1 continued to meet the standards in 10 CFR 50.47(b)
and the requirements of 10 CFR 50, Appendix E.