Information Notice 2005-19, Effect of Plant Configuration Changes on the Emergency Plan
| ML051530520 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee, Point Beach, Callaway, San Onofre  |
| Issue date: | 07/18/2005 |
| From: | Hiland P NRC/NRR/DIPM/IROB |
| To: | |
| Johnson Don A. EPD/NSIR, 301-415-4040 | |
| References | |
| IN-05-019 | |
| Download: ML051530520 (5) | |
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR SECURITY AND INCIDENT RESPONSE
WASHINGTON, D.C. 20555-0001
July 18, 2005
NRC INFORMATION NOTICE 2005-19:
EFFECT OF PLANT CONFIGURATION
CHANGES ON THE EMERGENCY PLAN
ADDRESSEES
All holders of operating licenses for nuclear power reactors, except those who have
permanently ceased operations and have certified that fuel has been permanently removed
from the reactor vessel.
PURPOSE
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to inform
addressees of inspection findings related to licensees failure to properly evaluate the effect of
plant configuration changes (procedures, equipment, and facilities) on the emergency plan.
This information notice is intended to inform licensees of the importance of properly evaluating
changes to procedures, equipment, and facilities for potential impact on the licensees ability to
maintain an effective emergency plan.
It is expected that recipients will review the information for applicability to their facilities and
consider actions, as appropriate, to avoid similar problems. However, suggestions contained in
this information notice do not constitute NRC requirements; therefore, no specific action or
written response is required.
DESCRIPTION OF CIRCUMSTANCES
Failure to Revise an Emergency Action Level (EAL) Associated with Plant Instrumentation
At the Callaway plant, an effluent radiation monitor is used as an EAL indicator for emergency
classifications. In March 1998, the licensee corrected errors in the calculation for the effluent
monitor indicators used in determining site area and general emergency classifications. The
correction raised the indicator value so that an emergency classification would occur at a
somewhat higher monitor value than was previously required. However, 22 months later NRC
inspectors determined that the licensee had decided not to update the monitor indicator value
to reflect the correct value, as determined by the revised calculation, because the licensee
assumed it would decrease the effectiveness of the emergency plan.
The NRC concluded that a violation of 10 CFR 50.54(q) occurred when the licensee failed to
revise an EAL associated with plant instrumentation to its most accurate known value to ensure
that corresponding protective action recommendations (PARs) were appropriate for the
indicated conditions (ADAMS Accession No. ML003737917).
Failure to Evaluate the Effect of Equipment Deficiency on the Ability to Determine PARs
At the Kewaunee Nuclear Power Plant, meteorological instrumentation is used in the
development of PARs in the event of an emergency. In June 2002, the licensee identified that
the primary 10-meter wind direction instrumentation was indicating an erroneous wind direction.
The control room and emergency preparedness staff were not informed of this malfunction and
compensatory measures were not implemented pending completion of repairs to the
instrument. As a result, the use of primary 10-meter wind direction readings could have
resulted in the wrong downwind sectors reported to the State for determining protective
measures for the public.
The NRC concluded that a violation of 10 CFR 50.54(q) occurred when the licensee failed to
correct a malfunction of the wind direction instrumentation and to maintain the meteorological
system so that it could be used to ensure the capability to provide accurate dose assessments
and PARs under accident conditions (ADAMS Accession No. ML023040516).
Failure to Evaluate the Effect of Equipment Issues on Timely EAL Determination
At the Point Beach Nuclear Plant, seismic instrumentation is used as an EAL indicator for
emergency classification. The licensees 1984 Emergency Plan specified the instrument and
control (I&C) technicians as 30-minute emergency responders and allowed use of the on-shift
auxiliary operators in lieu of on-shift I&C technicians to retrieve seismic data. At that time, the
retrieval of the seismic data did not require specialized training or the use of a laptop computer
so the auxiliary operators could retrieve the data.
The licensee replaced the seismic instrumentation with an instrument that required the use of a
laptop computer to retrieve the seismic data. Only I&C technicians were trained to use the
laptop computer for retrieving seismic data. An I&C technician, or an appropriately trained
alternate, was not assigned to the on-shift staff and was therefore not immediately available
during off-normal working hours to retrieve the data. As a result, the licensee could not have
assessed the seismic activity to support timely declaration of an emergency condition.
The NRC concluded that a violation of 10 CFR 50.47(b) occurred when the licensee failed to
ensure adequate on-shift staffing at all times to support reading of the seismic instrumentation
and timely implementation of the emergency plan (ADAMS Accession No. ML040360104).
Failure to Evaluate Procedure Changes Against the Emergency Plan
At the Point Beach Nuclear Plant, steam generator narrow range level setpoints are used as
EAL indicators for emergency classifications. In November 2001, the licensee revised its
technical specifications and several safety-related procedures associated with steam generator
narrow range level setpoints. The licensees review failed to recognize the impact on the
emergency plan. As a result, the EAL was not updated to reflect the correct narrow range
steam generator water level setpoints which could have led to an incorrect emergency
classification and PAR. The NRC concluded that the licensees failure to identify and evaluate the potential impacts of
the discrepancy between the procedure setpoints and EALs was more than minor in that, if left
uncorrected, it could have prevented or delayed declaration of a general emergency (ADAMS
Accession No. ML041280141).
Failure to Identify the Impact of Equipment Deficiencies on the Emergency Plan
At the San Onofre Nuclear Generating Station, portable radiation detection equipment is used
to evaluate EAL indicators under certain plant conditions. In December 2002, NRC inspectors
identified that emergency procedures require the dispatch of a health physics technician to
monitor radiation conditions outside of containment only when the hi-range in-containment
monitor is inoperable. However, a radiological emergency condition could exist where the
licensee would fail to recognize it because the hi-range in-containment monitor is operable and
the actual radiation condition outside of containment at specific locations exceeded established
levels and was not evaluated. As a result, a potential emergency classification situation could
exist and the licensee staff might not recognize it.
The NRC concluded that a violation of 10 CFR Part 50, Appendix E IV.B occurred when the
licensee failed to provide adequate procedures to ensure that conditions that could require the
declaration of an EAL are recognized and evaluated (ADAMS Accession No. ML030160320).
BACKGROUND
The NRC evaluates the acceptability of a licensees emergency plan against the standards set
forth in 10 CFR 50.47(b), the requirements of Appendix E to 10 CFR Part 50, and the guidance
contained in NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of
Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power
Plants. The NRC requires licensees to comply with 10 CFR 50.54(q) which states, in part, that
a licensee authorized to possess and operate a nuclear power reactor shall follow and maintain
in effect emergency plans which meet the standards in 10 CFR 50.47(b) and the requirements
in Appendix E of 10 CFR Part 50.
DISCUSSION
The ultimate goal of an EAL scheme and an emergency plan is to ensure that emergency
response personnel, emergency procedures, and equipment are in place if it becomes
necessary to implement actions to protect the public health and safety.
Site configuration changes should be evaluated to ensure that the licensee continuously
maintains the ability to implement an effective emergency plan. Configuration changes that
impact the ability of a site to implement its emergency plan need to be evaluated to determine
the impact and, if necessary, to implement compensatory measures. For example, several
licensees have recently modified their seismic instrumentation and failed to properly evaluate
these modifications to ensure that the emergency plan and the ability to declare the appropriate
EAL in a timely fashion were not adversely affected. Other changes, such as training, facility modifications, site egress and ingress, etc., can also
affect the emergency plan and should be properly evaluated. This evaluation should also
consider whether the proposed modification could take advantage of technological
advancements in order to enhance the effectiveness of the emergency plan. For example, when replacing seismic instrumentation, licensees could consider technological advancements
that would provide a seismic annunciator in the control room to ensure timely and accurate
event declaration due to an earthquake.
CONTACT
S
This information notice requires no specific action or written response. Please direct any
questions about this matter to the technical contact listed below or the appropriate Office of
Nuclear Reactor Regulation (NRR) project manger.
/RA/
Patrick L. Hiland, Chief
Reactor Operations Branch
Division of Inspection Program Management
Office of Nuclear Reactor Regulation
Technical Contact:
Don A. Johnson, NSIR/DPR/EPD
301-415-4040
E-mail: daj3@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
OFFICE
NSIR:EPD
TECH EDITOR
TL:NSIR:EPD
TL:NSIR:EPD
SC:NSIR:EPD
NAME
DJohnson
PKleene
RKahler
SRosenburg
EWeiss(DMB for)
DATE
6/6/2005
05/02/2005
6/6/2005
6/9/2005
6/10/2005 OFFICE
D:NSIR:EPD
D:NSIR:DPR
OES:IROB:DIPM
TL:IROB:DIPM
SC:IROB:DIPM
C:IROB:DIPM
NAME
NMamish
ELeeds
MKing
EBenner
MJRoss-Lee
PLHiland
DATE
6/16/2005
6/17/2005
06/14/2005
07/11/2005
07/15/2005
07/18/2005