Information Notice 2013-01, Emergency Action Level Thresholds Outside the Range of Radiation Monitors
| ML12325A326 | |
| Person / Time | |
|---|---|
| Issue date: | 02/13/2013 |
| From: | Camper L, Laura Dudes, Mary Muessle NRC/FSME, Office of Nuclear Reactor Regulation, Office of New Reactors, Office of Nuclear Security and Incident Response |
| To: | |
| Banic M, NRR/DPR, 415-2771 | |
| References | |
| TAC ME9258 IN-13-001 | |
| Download: ML12325A326 (5) | |
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR SECURITY AND INCIDENT RESPONSE
OFFICE OF NUCLEAR REACTOR REGULATION
OFFICE OF NEW REACTORS
OFFICE OF FEDERAL AND STATE MATERIALS AND
ENVIRONMENTAL MANAGEMENT PROGRAMS
WASHINGTON, DC 20555-0001 February 13, 2013 NRC INFORMATION NOTICE 2013-01: EMERGENCY ACTION LEVEL THRESHOLDS
OUTSIDE THE RANGE OF RADIATION
MONITORS
ADDRESSEES
All holders of an operating license or construction permit for a nuclear power reactor or a
non-power (research or test) reactor under Title 10 of the Code of Federal Regulations
(10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, including those
that have permanently ceased operations and have certified that fuel has been permanently
removed from the reactor vessel.
All holders of and applicants for a power reactor early site permit, combined license, standard
design certification, standard design approval, or manufacturing license under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.
PURPOSE
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to
inform addressees of inspection findings related to licensees failures to properly evaluate the
effect of site equipment changes on the emergency plan. The agency intends this IN to inform
licensees of the importance of having adequate procedures to properly evaluate changes to
site procedures, equipment, and facilities for potential impact on the licensees ability to
maintain an effective emergency plan. Specifically, this IN informs licensees of issues that
arose when radiation monitors were not properly evaluated in conjunction with changes made
to emergency action level (EAL) thresholds for emergency classifications. The NRC
previously alerted licensees to similar issues in IN 2005-19, Effect of Plant Configuration
Changes on the Emergency Plan, dated July 18, 2005.
The NRC expects 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
At the plants cited below, effluent radiation monitor indications are used as EAL thresholds for
emergency classifications. Any site configuration or procedural changes that have the potential
ML12325A326 to affect the emergency plan, may benefit from being systematically evaluated by the licensee
for their impact on the effectiveness of the emergency plan.
EAL Thresholds Outside the Range of Radiation Monitors at Kewaunee
Kewaunee Power Station submitted a revision to its EAL scheme to the NRC for approval in
2005. The revision specified ALERT EAL thresholds for multiple instruments that were beyond
the display capabilities of those instruments by a decade or more. Both the waste effluent liquid
monitor and gaseous effluent radiation monitor were incapable of displaying values high enough
to trigger an ALERT declaration. According to the licensee such deficiencies would have
prevented timely and accurate emergency classification and response. The licensee staff that
developed revisions to the EAL scheme did not identify that the monitors could not display the
calculated values. The plant operated for approximately 2 years with inaccurate emergency
classifications or EAL thresholds, a condition that could have led to the failure of the licensee to
declare an ALERT emergency in a timely manner.
The NRC determined that a violation of 10 CFR 50.54(q) occurred because of the licensees
failure to follow and maintain in-effect emergency plans that meet the standards in
10 CFR 50.47(b)in particular, 10 CFR 50.47( b)(4). Additional information appears in
Kewaunee Power Station, NRC Emergency Preparedness Inspection Report 05000305/2008503, dated September 23, 2008, available on the NRCs public Web site in the
Agencywide Documents Access and Management System (ADAMS) under Accession
No. ML082670904.
EAL Thresholds Outside the Range of Radiation Monitors at Prairie Island
Prairie Island Nuclear Generating Plant submitted a revision to its EAL scheme to the NRC for
approval in 2005. The revision specified ALERT EAL thresholds for multiple instruments that
were beyond the display capabilities of those instruments by a decade or more. Both the waste
effluent liquid monitor and spent fuel pool vent radiation monitor were incapable of displaying
values high enough to trigger an ALERT declaration based on the licensees revised EAL
scheme. These deficiencies would have prevented timely and accurate emergency
classification and response. The licensee staff that developed revisions to the EAL scheme did
not identify that the monitors could not display the calculated values.
The NRC determined that a violation of 10 CFR Part 50.54(q) occurred because of the
licensees failure to follow and maintain in-effect emergency plans that meet the standards in
10 CFR 50.47(b), in particular, 10 CFR 50.47( b)(4). Additional information appears in Prairie
Island Nuclear Generating Plant, NRC Inspection Report 05000282/2010503, dated
April 09, 2010, on the NRCs public Web site in ADAMS under Accession No. ML100990307.
EAL Thresholds Outside the Range of Radiation Monitors at Crystal River
A revision to the licensees EAL scheme, in 2010, incorporated threshold values for declaring a
GENERAL EMERGENCY (GE) based on an effluent release that was well outside the range of
the licensees EAL-specified effluent monitors to report. The threshold for declaration of a GE
was above the maximum usable range of the reactor building and auxiliary building effluent
radiation monitors on the range specified. Therefore, the licensee had no way of accurately
measuring these threshold values or declaring a GE in a timely manner. In evaluating the root
cause for this condition, the licensee further identified that the radiation monitor indications were nonlinear above 2/3 full scale on the mid-range instrument, and that this monitor would enter an
automatic purge mode before reaching the EAL threshold. Both of these design features
lowered the usable display range even further.
The NRC determined that a violation of 10 CFR Part 50.54(q) occurred because of the
licensees failure to follow and maintain in-effect emergency plans that meet the standards in
10 CFR 50.47(b), in particular, 10 CFR 50.47(b)(4). Additional information appears in Crystal
River Unit 3NRC Emergency Preparedness Inspection Report 05000302/2011501, dated
September 23, 2011, on the NRCs public Web site in ADAMS under Accession
No. ML112660544.
DISCUSSION
The NRC requires licensees to comply with 10 CFR 50.54(q)(2), which states, in part, that a
licensee authorized to possess and operate a nuclear power reactor shall follow and maintain
the effectiveness of emergency plans that meet the standards in 10 CFR 50.47(b) and the
requirements in Appendix E, Emergency Planning and Preparedness for Production and
Utilization Facilities, to 10 CFR Part 50. Non-power reactor licensees, while not required to
comply with 10 CFR 50.47(b), must also meet the requirements of Appendix E.
Site configuration changes have the potential to adversely impact the licensees ability to
maintain and implement an effective emergency plan as required by 10 CFR 50.47(b) and
Appendix E to 10 CFR Part 50, as appropriate. The licensee may consider evaluating all site
configuration changes for their impact on the ability of the licensee to implement the sites
emergency plan and, if necessary, the need to implement compensatory measures. Changes, such as training, facility modifications, site egress and ingress, etc., can all affect the
In some of the instances discussed above, the licensees root cause evaluations generally
identified inadequate control of the calculations that established the EAL thresholds, and
deficiencies in the training of personnel responsible for these activities. Personnel were not
knowledgeable about the design and operation of the radiation monitors credited in their EAL
scheme.
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 NRC
project manager.
/RA/ /RA/
Mary C. Muessle, Acting Director Larry W. Camper
Division of Policy and Rulemaking Division of Waste Management and
Office of Nuclear Reactor Regulation Environmental Protection
Office of Federal and State Materials and
Environmental Management Programs
/RA/ JLuehman for
Laura A. Dudes
Division of Construction Inspection
and Operational Programs
Office of New Reactors
Technical Contact:
Jonathan Fiske, NSIR/DPR/DDEP/IRIB
301-415-6277 E-mail: JAF4@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.
ML12325A326 TAC ME9258 *via e-mail
OFFICE PM:NSIR Tech Editor* BC:IRIB:NSIR DD:EP:NSIR D:DPR:NSIR BC:RDB:FSME
NAME JFiske CHsu RKahler MThaggard RLewis BWatson
DATE 11/28/12 10/23/12 11/28/12 1/15/2013 1/24/13 1/29/13 OFFICE LA:PGCB:NRR PM:PGCB:NRR BC:PGCB:NRR DD:DCIP:NRO DD:DWMEP: (A)D:DPR:NRR
NAME CHawes MBanic DPelton LDudes LCamper MMuessle
(JLuehman for)
DATE 2/6/13 2/4/13 2/8/13 2/11/13 2/13/13 2/13/13