ML071550160
| ML071550160 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 06/04/2007 |
| From: | James Shea Division of Reactor Safety II |
| To: | Archie J South Carolina Electric & Gas Co |
| References | |
| EA-07-079 IR-07-502 | |
| Download: ML071550160 (19) | |
See also: IR 05000395/2007502
Text
June 4, 2007
South Carolina Electric & Gas Company
ATTN:
Mr. Jeffrey B. Archie
Vice President, Nuclear Operations
Virgil C. Summer Nuclear Station
P. O. Box 88
Jenkinsville, SC 29065
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION - NRC EMERGENCY
PREPAREDNESS INSPECTION REPORT 05000395/2007502
Dear Mr. Archie:
On March 28, 2007, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection
at your Virgil C. Summer Nuclear Station. The enclosed report documents the inspection
results, which were discussed via teleconference on May 14, 2007, with you and other
members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel. The inspection also included a review of the Emergency Plan changes that
occurred between October 1980 and July 28, 2006.
Based on the results of this inspection, one apparent violation was identified and is being
considered for escalated enforcement action in accordance with the NRC Enforcement Policy.
The current Enforcement Policy is included on the NRCs Web site at http://www.nrc.gov/about-
nrc/regulatory/enforcement/enforc-pol.pdf. Based on a review of Summers Emergency Plan
changes, the staff determined there were Emergency Action Level (EAL) changes made that
decreased the effectiveness of the emergency plan and failed to maintain a standard
emergency classification scheme. This is a performance deficiency and an apparent violation
associated with emergency preparedness planning standard 10 CFR 50.47(b)(4),
10 CFR 50.54(q), and the requirements of Section IV.B of Appendix E to 10 CFR Part 50 to
obtain NRC approval prior to implementation of a revision to an EAL that changes EAL
schemes, uses alternate methods for complying with the regulations or decreases the
effectiveness of the emergency plan.
This finding was assessed using traditional enforcement. NRC Manual Chapter 0609,
Appendix BProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix B" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Section 2.2(e) states in part, Findings that potentially impede the regulatory
process (i.e., violations that impact the NRCs ability to oversee licensees activities) are not to
be evaluated through the SDP [Significance Determination Process]. Noncompliances may be
significant because they may challenge the regulatory envelope within which certain activities
SCE&G
2
were licensed. These types of violations include failures to receive prior NRC approval for
changes that result in a decrease in effectiveness of the Plan (10 CFR 50.54(q) issues). Such
violations are to be evaluated in accordance with the guidance in Section IV of the Enforcement
Policy (traditional enforcement). Additional details associated with this determination are
discussed in Section 1EP4 of the enclosed inspection report. This finding is also determined to
potentially have greater significance because the finding represents a failure to meet planning
standard 10 CFR 50.47(b)(4) and the requirements of Section IV.B of Appendix E to 10 CFR Part 50.
Regional inspectors and program office staff reviewed Summer's EALs and determined there
were additional EAL observations that support the apparent violation. The observations are
provided in Attachment 2 and should be included in the extent of condition during your review of
the four examples given in the apparent violation. You should consider if any corrective action
for the observations is warranted and include such in your corrective action program.
Before the NRC makes its enforcement decision, we are providing you an opportunity to either:
(1) respond to the apparent violation addressed in this inspection report within 30 days of the
date of this letter or (2) request a predecisional enforcement conference. If a conference is
held, it will be open for public observation. The NRC will also issue a press release to
announce the conference. Please contact Brian R. Bonser at 404-562-4653 within 7 days of
the date of this letter to notify the NRC of your intended response.
If you choose to provide a written response, it should be clearly marked as a "Response to an
Apparent Violation in Inspection Report No. 5000395/2007502; EA-07-079" and
should include: (1) the reason for the apparent violation, or, if contested, the basis for disputing
the apparent violation; (2) the corrective steps that have been taken and the results achieved;
(3) the corrective steps that will be taken to avoid further violations; and (4) the date when full
compliance will be achieved. Your response may reference or include previously docketed
correspondence, if the correspondence adequately addresses the required response. If an
adequate response is not received within the time specified or an extension of time has not
been granted by the NRC, the NRC will proceed with its enforcement decision or schedule a
predecisional enforcement conference.
In addition, please be advised that the number and characterization of apparent violations
described in the enclosed inspection report may change as a result of further NRC review. You
will be advised by separate correspondence of the results of our deliberations on this matter.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response, if you choose to provide one, will be made available
electronically for public inspection in the NRC Public Document Room or from the NRCs
SCE&G
3
document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/
reading-rm/adams.html. To the extent possible, your response should not include any personal
privacy, proprietary, or safeguards information so that it can be made available to the Public
without redaction.
Sincerely,
/RA/
Joseph W. Shea, Director
Division of Reactor Safety
Docket No. 0-395
License No. NPF-12
Enclosure: NRC Inspection Report No. 05000395/2007502
w/Attachments: 1. Supplemental Information
2. Listing of additional EAL Observations
cc w/encl:
R. J. White
Nuclear Coordinator Mail Code 802
S.C. Public Service Authority
Virgil C. Summer Nuclear Station
Electronic Mail Distribution
Kathryn M. Sutton, Esq.
Electronic Mail Distribution
Henry J. Porter, Director
Div. of Radioactive Waste Mgmt.
Dept. of Health and Environmental
Control
Electronic Mail Distribution
R. Mike Gandy
Division of Radioactive Waste Mgmt.
S. C. Department of Health and
Environmental Control
Electronic Mail Distribution
(cc w/encl contd - See page 4)
SCE&G
4
(cc w/encl contd)
Bruce L. Thompson, Manager
Nuclear Licensing (Mail Code 830)
South Carolina Electric & Gas Company
Virgil C. Summer Nuclear Station
Electronic Mail Distribution
Robert M. Fowlkes, General Manager
Engineering Services
South Carolina Electric & Gas Company
Virgil C. Summer Nuclear Station
Electronic Mail Distribution
Thomas D. Gatlin, General Manager
Nuclear Plant Operations (Mail Code 303)
South Carolina Electric & Gas Company
Virgil C. Summer Nuclear Station
Electronic Mail Distribution
David A. Lavigne, General Manager
Organization Development
South Carolina Electric & Gas Company
Vigil C. Summer Nuclear Station
Electronic Mail Distribution
Distribution w/encl:
R. Martin, NRR
C. Evans, RII EICS
L. Slack, RII EICS
RIDSNRRDIRS
PUBLIC
OFFICE
RII:DRS
RII:DRS
RII:DRP
RII:DRS
RII:EICS
SIGNATURE
RA
RA
NAME
KREH
MILLER
E.GUTHRIE
BONSER
EVANS
DATE
4/26/2007
4/26/2007
4/30/2007
4/30/2007
4/27/2007
E-MAIL COPY?
YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO
Enclosure
U. S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No.:
50-395
License No.:
Report No:
Licensee:
South Carolina Electric and Gas
Facility:
Virgil C. Summer Nuclear Station
Location:
576 Stairway Road
Jenkinsville, SC 29065
Dates:
August 15, 2006 - May 1, 2007
Inspectors:
Lee Miller, Senior Emergency Preparedness Inspector
James Kreh, Emergency Preparedness Inspector
Approved by:
Brian R. Bonser, Chief
Plant Support Branch 1
Division of Reactor Safety
Enclosure
Summary of Findings
IR 05000395/2007-502; 08/15/2006-05/01/2007; Virgil C. Summer Nuclear Station; Emergency
Action Level (EAL) and Emergency Plan Changes
The report covered an announced inspection by two emergency preparedness inspectors. One
apparent violation (AV) was identified. The NRCs program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 4, dated December 2006.
A.
NRC-Identified and Self-Revealing Findings
Cornerstone: Emergency Preparedness
TBD. The NRC identified an apparent violation (AV) related to the licensees
implementation of EAL changes which decreased the effectiveness of the Emergency
Plan, and related to the licensees failure to maintain a standard emergency
classification scheme. The AV is associated with 10 CFR 50.54(q), emergency
preparedness planning standard 10 CFR 50.47(b)(4), and the requirements of Section
IV.B of 10 CFR 50, Appendix E.
The licensee's implementation of EAL changes that resulted in a decrease in
effectiveness of the Emergency Plan and a failure to maintain a standard emergency
classification scheme are performance deficiencies. This finding is greater than minor
because it is associated with the Emergency Preparedness Cornerstone and affects the
cornerstone objective to ensure that the licensee is capable of implementing adequate
measures to protect the health and safety of the public in the event of a radiological
emergency. The finding is an identified weakness that demonstrates a level of
performance that could preclude effective implementation of the Emergency Plan in an
actual emergency. This finding is also determined to potentially have greater
significance because the finding represents a failure to meet planning standard 10 CFR 50.47(b)(4) and the requirements of Section IV.B of 10 CFR 50, Appendix E to obtain
NRC approval prior to implementation of a revision to an EAL that changes EAL
schemes, uses alternate methods for complying with the regulations or decreases the
effectiveness of the emergency plan. (Section 1EP4)
B.
Licensee-Identified Violations.
None
Enclosure
REPORT DETAILS
1.
REACTOR SAFETY
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level (EAL) and Emergency Plan Changes
a.
Inspection Scope
Between August 15, 2006 and May 1, 2007, an in-office review of Summers EALs was
conducted by the emergency preparedness program office staff and region based
emergency preparedness inspectors. The program office staff determined that Revision
5 of the Emergency Plan was the last NRC-approved revision. Revision 53 of the
Emergency Plan was the current revision at the time of the last Emergency
Preparedness Program inspection for Summer. The licensees available documentation
for Revisions 5 through 53 was reviewed to determine if the changes made to the EALs
had decreased the effectiveness of the emergency plan. The EAL revisions were also
reviewed to determine if they were consistent with the guidance in NUREG-0654,
Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and
Preparedness in Support of Nuclear Power Plants, Appendix 1, Emergency Action
Level Guidelines for Nuclear Power Plants.
The in-office review was conducted in accordance with NRC Inspection Procedure 71114, Attachment 04, Emergency Action Level and Emergency Plan Changes. The
applicable planning standard, 10 CFR 50.47(b)(4), and its related 10 CFR 50,
Appendix E requirements were used as reference criteria. The criteria contained in
NUREG-0654 and Regulatory Guide 1.101, Emergency Planning and Preparedness
For Nuclear Power Reactors, Revision 4, were also used as references.
The inspectors reviewed multiple change packages for the licensees emergency plan,
EP-100, Radiation Emergency Plan, Revision 5 through Revision 53.
b.
Findings
Introduction. The NRC identified an apparent violation (AV) related to the licensees
implementation of EAL changes which decreased the effectiveness of the Emergency
Plan and related to the licensees failure to maintain a standard emergency classification
scheme.
Description. NRC Inspection Report 05000395/2006012, dated September 1, 2006,
identified an Unresolved Item (URI), URI-05000395/2006012-01, Blending of EAL
Schemes. The URI was opened to review the Summer EALs to determine if the
changes made between October 1981 (Revision 5) and April 2006 (Revision 53)
resulted in decreases in effectiveness or a blending of EAL schemes.
4
Enclosure
Summers EALs are based on NUREG-0654. Revision 5 to the Summer EALs was the
last NRC-approved set of EALs for Virgil C. Summer Nuclear Station. Revision 53 was
the revision the inspectors used to compare to the last NRC-approved EAL revision.
The standard approved EAL schemes are based on NUREG-0654, NUMARC/NESP-
007, or NEI 99-01. Revisions to the EALs that contain combinations of two or more of
the standard EAL schemes are termed blending of EALs and must be approved by the
Commission prior to implementation. Revisions to the EALs that are not consistent with
the standard EAL schemes are termed non-standard EALs and must be approved by
the Commission prior to implementation.
The staff review identified two General Emergency and two Site Area Emergency EAL
changes that decreased the effectiveness of the emergency plan and/or resulted in a
failure to maintain a standard EAL scheme. The EALs are from EP-100, Table 4-1. The
four examples, documented below, compare the NRC approved revision, Revision 5, to
Revision 53, the current revision at the time of the inspection.
Attachment 2 provides additional observations that support these findings.
1) General Emergency (GE) EAL Number 411
The Initiating Condition in Revision 5 stated, Transient initiated by loss of feedwater
and condensate systems (principle heat removal system) followed by failure of
emergency feedwater system for extended period. Core melting possible in several
hours. Ultimate failure of Reactor Building possible if core melts.
The Detection Method in Revision 5 stated, Reactor trip on low feedwater flow; and
Decreasing wide-range steam generator levels toward off-scale low on all steam
generators; and 1) Emergency feedwater flow indicators indicate zero flow 2 min.
after required; or 2) Status lamps indicate emergency feedwater pumps not running
2 min. after required and Emergency feedwater cannot be restored within 30 min.
The Initiating Condition for EAL number 411 remained essentially the same between
Revisions 5 and 53. However, significant changes were made to the detection
methods between Revisions 5 and 53.
The Detection Method in Revision 53 stated, ALL of the following exists (1 AND 2):
1. Inability to Establish Bleed and Feed Cooling when required per EOP-15.0 - AND
- 2. Core Exit Temperatures > 700°F.
The revised EAL applied more restrictive criteria to when the EAL would be met and
could reduce the number of classifiable events or could delay the GE declaration.
As a result, the EAL changes appear to have resulted in a decrease in the
effectiveness of the emergency plan. Additionally, the revised detection methods
were not consistent with the standard EAL schemes, resulting in a non-standard
EAL.
5
Enclosure
2) General Emergency (GE) EAL Number 401
The Initiating Condition in Revision 5 stated, Small or large LOCA with failure of
ECCS to perform leading to severe core degradation or melt. Ultimate failure of
Reactor Building possible for meltdown sequences.
The Detection Method in Revision 5 stated, Safety injection signal with reactor trip;
and 1) Status lamps indicate safety injection system and RHR pumps not running :
or 2) Flow indicators for Safety Injection Systems read zero; and RMG-5, RMG-7,
RMG-18, high alarms; and RM-A2 high alarm.
The Initiating Condition for EAL number 401 remained essentially the same between
Revisions 5 and 53. However, significant changes were made to the detection
methods between Revisions 5 and 53.
The Detection Method in Revision 53 stated, Failure of BOTH of the following after
depressurizing the RCS to < 140 psig per EOP-14.0. Failure of (1 AND 2): 1. High
Head Injection Flow AND 2. Low Head Injection Flow
The revised EAL applied more restrictive criteria to when the EAL would be met, and
could reduce the number of classifiable events or could delay the GE declaration.
As a result, the EAL changes appear to have resulted in a decrease in the
effectiveness of the emergency plan. Additionally, the revised detection methods
were not consistent with the standard EAL schemes resulting in a non-standard
EAL.
3) Site Area Emergency (SAE) EAL Number 301
The Initiating Condition in Revision 5 stated, Known Loss of Coolant Accident
(LOCA) greater than charging pump capacity.
The Detection Method in Revision 5 stated, Pressurizer low pressure reactor trip;
and Pressurizer low pressure safety injection signal, and RM-A2 high alarm; and
High Reactor Building sump level; and High Reactor Building humidity; and High
Reactor Building pressure.
The Initiating Condition for EAL number 301 remained essentially the same between
Revisions 5 and 53. However, significant changes were made to the detection
methods between Revisions 5 and 53.
The Detection Method in Revision 53 stated, ANY of the following indications (1 OR
1. Evaluate the following indications to determine if a LOCA condition exists
(similar to EOP-1.0):
a. Pressurizer low pressure reactor trip.
b. Pressurizer low pressure safety injection.
6
Enclosure
c. Reactor Building pressure > 1.5 psig,
d. Abnormal Reactor Building sump level,
e. RBCU Drain Flow High,
f. Abnormal radiation levels on RM-A2 or RM-G7, or RM-G18. - OR -
2. Direct Entry into EOP-2.0 from EOP-1.0 due to the RCS NOT Being Intact. -
OR -
3. Stuck Open and Unisolable Pressurizer PORV or Safety Valve Leading to
Pressurizer Relief Tank Rupture - OR -
4. Initiating Bleed and Feed per EOP-15.0. (Refer to Initiating Condition 411
for possible escalation.)
The changes to the EAL may increase the number of classifiable SAE events. An
unwarranted SAE declaration is a non-conservative action which may place
members of the public at risk during an unnecessary evacuation process. The
Revision 5 detection methods were definitive criteria that had no procedural delay in
reaching a determination for the SAE declaration. The detection methods which are
reliant on an EOP transition point or entry point could result in a delay in making the
SAE declaration. As a result, the EAL changes appear to have resulted in a
decrease in the effectiveness of the emergency plan. Additionally, the revised
detection methods were not consistent with the standard EAL schemes resulting in a
non-standard EAL.
4) Site Area Emergency (SAE) EAL number 397
The inspectors noted that there was not an equivalent EAL in Revision 5 for EAL
number 397. This EAL was not included in the NUREG-0654 EAL scheme nor was
it required by NRC regulations. The licensee's Revision 23 to their EALs stated that
the EAL was added per Generic Letter (GL) 87-12, Loss of Residual Heat Removal
While The Reactor Coolant System is Partially Filled, but provided no evaluation or
technical basis to support the addition of this EAL. NRC review of GL 87-12
determined that there was no requirement to add an EAL.
The Initiating Condition in Revision 53 stated, Loss of Residual Heat Removal flow
for more than 40 minutes during half-pipe operations with vessel head installed and
High Head Safety Injection/charging unavailable.
The Detection Method in Revision 53 stated, ALL of the following (1 THROUGH 5)
For a period greater than 40 minutes:
1. Both RHR Loop A FLO LO AND RHR Loop B FLO LO annunciators in alarm, -
AND-
2. NEITHER RHR pump is running, - AND -
3. Core exit thermocouple temperatures increasing or at saturation temperature for
the current RCS pressure - AND -
4. Reactor Vessel Head is in place and RCS loops are drained to 434-7.43 or less.
- AND -
5. NEITHER train of Charging/SI is available.
7
Enclosure
This EAL was not consistent with the standard EAL schemes resulting in a non-standard
EAL.
Analysis. A performance deficiency was identified for the licensees implementation of
EAL changes which decreased the effectiveness of the Emergency Plan and for the
licensees failure to maintain a standard emergency classification scheme. This finding
is greater than minor because it is associated with the Emergency Preparedness
Cornerstone and affects the cornerstone objective to ensure that the licensee is capable
of implementing adequate measures to protect the health and safety of the public in the
event of a radiological emergency. The finding is an identified weakness that
demonstrates a level of performance that could preclude effective implementation of the
Emergency Plan in an actual emergency. This finding is also determined to potentially
have greater significance because the finding represents a failure to meet the
requirements of 10 CFR 50.54(q), the risk significant planning standard 10 CFR 50.47(b)(4), and the requirements of Section IV.B of 10 CFR 50, Appendix E.
MC 0609, Appendix B, § 2.2.e states, in part: "Findings that potentially impede the
regulatory process (i.e., violations that impact the NRCs ability to oversee licensees
activities) are not to be evaluated through the SDP. Noncompliances may be significant
because they may challenge the regulatory envelope within which certain activities were
licensed. These types of violations include failures to receive prior NRC approval for
changes that result in a decrease in effectiveness of the Plan (10 CFR 50.54(q) issues).
Such violations are to be evaluated in accordance with the guidance in Section IV of the
Enforcement Policy (traditional enforcement)."
Enforcement. 10 CFR 50.54(q) states, in part, The nuclear power reactor licensee may
make changes to these plans without Commission approval only if the changes do not
decrease the effectiveness of the plans and the plans, as changed, continue to meet the
standards of § 50.47(b) and the requirements of Appendix E to this part. Planning
standard 10 CFR 50.47(b)(4) states, A standard emergency classification and action
level scheme, the bases of which include facility system and effluent parameters, is in
use by the nuclear facility licensee, and State and local response plans call for reliance
on information provided by facility licensees for determinations of minimum initial offsite
response measures. Section IV.B of 10 CFR 50, Appendix E states, in part: A revision
to an EAL must be approved by the NRC before implementation if: (1) the licensee is
changing from one EAL scheme to another EAL scheme (e.g., a change from an EAL
scheme based on NUREG-0654 to a scheme based upon NUMARC/NESP-007 or
NEI 99-01); (2) the licensee is proposing an alternate method for complying with the
regulations; or (3) the EAL revision decreases the effectiveness of the emergency plan.
8
Enclosure
Contrary to 10 CFR 50, Appendix E, between October 1980 and April 2006, the licensee
made changes to its Emergency Plan which decreased the effectiveness of the Plan
and were not consistent with the NUREG-0654 EAL scheme. These changes were not
submitted to the NRC for approval prior to implementation.
This finding is identified as Apparent Violation (AV) 50-395/2007501-01, EAL Changes
Resulted in Decreases in Effectiveness and a Non-Standard EAL Scheme. This issue
has not yet been entered into the licensee's corrective action system.
4.
OTHER ACTIVITIES
4OA6 Meetings, including Exit
On May 14, 2007, the inspectors conducted a telephonic exit to discuss the results of
the inspection with Mr. J. Archie, Vice President, Nuclear Operations, and other
members of his staff. The inspectors confirmed that no proprietary information was
received by the inspectors during the inspection.
Attachments: 1. Supplemental Information
2. Listing of Additional EAL Observations
Attachment 1
1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
J. Archie, Vice President, Nuclear Plant Operations
D. Gatlin, General Manager, Nuclear Plant Operations
S. Zarandi, General Manager, Nuclear Support Services
G. Lippard, Manager, Operations
R. McCauley, Quality Assurance
F. Miller, Supervisor, Quality Control
B. Thompson, Manager, Nuclear Licensing
A. Cribb, Supervisor, Nuclear Licensing
R. Williamson, Supervisor, Emergency Services
NRC
J. Zeiler, Senior Resident Inspector
B. Bonser, Chief, Plant Support Branch 1
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
EAL Changes Resulted in
Decreases in Effectiveness and a
Non-Standard EAL Scheme (Section
1EP4)
Opened and Closed
None
Closed
Blending of EAL Schemes.
(Section 1EP4)
Discussed
None
Attachment 1
2
LIST OF ACRONYMS
Apparent Violation
CFR
Code of Federal Regulations
Emergency Action Level
Emergency Operating Procedures
Emergency Response Organization
FLO LO
Flow Low
General Emergency
GL
Generic Letter
IMC
Inspection Manual Chapter
Loss of Coolant Accident
NEI
Nuclear Energy Institute
NUMARC/NESP
Nuclear Management and Resources Council/National Environmental
Studies Project
Power Operated Relief Valve
RBCU
Reactor Building Cooling Unit
Site Area Emergency
Significance Determination Process
Safety Injection
To Be Determined
Unresolved Item
Attachment 2
1
LISTING OF ADDITIONAL EAL OBSERVATIONS
Regional inspectors and program office staff reviewed Summer's EALs and determined
that an apparent violation for failure to maintain a standard EAL scheme and for
decreases in effectiveness of the licensee's emergency plan had occurred. Four EALs
received an in-depth review and were used as examples for Apparent Violation (AV)05000395/2007502-01, EAL Changes Resulted in Decreases in Effectiveness and a
Non-standard EAL Scheme (Section 1EP4). Additional observations were noted with
other EALs. The observations are provided below and should be included in the
licensee's extent of condition during their review of the four examples provided in the
AV. The licensee should consider if any corrective action for the observations is
warranted and include such in their corrective action program.
The observations are listed by EAL number. The listing is sequenced in the following
order: General Emergency, Site Area Emergency, Alert, and Notification of Unusual
Event.
General Emergency
402 -
Detection method changes between Revisions 5 and 53 resulted in deletion of
the phrase Pressurizer low pressure reactor trip and Pressurizer low pressure
safety injection signal and added the phrase loss of primary or secondary
coolant in progress.
403 -
Detection method changes between Revisions 5 and 53 resulted in deletion of
the phrase LOCA as identified in Site Emergency and containment status panel
indicates incomplete isolation; and added the phrase a. dose equivalent I-131
activity > 1 ci/gm in primary coolant. OR b. core exit temperature >700EF.
431 - Detection method changes between Revisions 5 and 53 resulted in an additional
requirement for verification of primary coolant dose equivalent I-131 activity >
300ci/gm for RM-L1 alarm.
441 -
Detection method changes between Revisions 5 and 53 resulted in deletion of
the phrase Undervoltage alarms on 1DA and 1DB buses for > 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and
added the phrase Either a OR b a) Steam driven Emergency Feedwater pump
fails to start AND is unavailable for one hour OR b) Core exit temperature
>700EF
493 -
Revision 53 has a detection method that appeared to be inconsistent with the
NUREG-0654 scheme.
Site Area Emergency
302 -
Detection method changes between Revisions 5 and 53 resulted in deletion of
the phrases pressurizer low pressure alarm and reactor trip, or pressurizer level
rapidly decreasing; and Pressurizer low-level alarm; and undervoltage alarms on
Attachment 2
2
1DA and 1DB and steam generator water level rapidly increasing in one or more
steam generators, falling in the others, and ... The changes added the
condition Entry into EOP-4.0.
303 - Detection method changes between Revisions 5 and 53 resulted in deletion of
the phrase RM-A2 high alarm with no justification and added the requirement
for verification of dose equivalent I-131 activity > 300 ci/gm.
321-
Detection method changes between Revisions 5 and 53 resulted in deletion of
the phrase Thot and Tcold rapidly diverging (T rapidly increasing) or no T
across core and added the phrase no indication of forced or natural circulation.
The requirement for verification of failed fuel monitor offscale (>106 cpm) with
determination of dose equivalent I-131 activity > 300 ci/gm was added.
322 - Detection method changes between Revisions 5 and 53 resulted in deletion of
RM-A2" with no justification and addition of RM-G5.
341-
Revision 53 has a detection method that appeared to be inconsistent with the
NUREG-0654 scheme.
342 -
Revision 53 has a detection method that appeared to be inconsistent with the
NUREG-0654 scheme.
361 -
Revision 53 has a detection method that appeared to be inconsistent with the
NUREG-0654 scheme.
362 - Detection method changes between Revisions 5 and 53 resulted in addition of
the phrase radiation monitoring teams measure thyroid dose rates (equivalent I-
131concentrations) at one mile or greater from the plant. The initiating condition
specifies at the exclusion area boundary which the emergency plan defines as
within one mile.
371 - Detection method changes between Revisions 5 and 53 resulted in deletion of
the phrase major fire that defeats redundant safety system trains or functions
and added the phrase fire that renders both trains of a safety system or function
inoperable per the Technical Specifications.
392b - Detection method changes between Revisions 5 and 53 resulted in direction to
the user to Initiating Condition 394, which contains an error.
392c - Detection method changes between Revisions 5 and 53 resulted in deletion of
the phrase as detected by portable instrumentation AND which renders a train
of safety related system inoperable.
394 - Detection method changes between Revisions 5 and 53 resulted in deletion of
the OR between methods 2 and 3. The revisions added the phrase AND
between methods 2 and 3.
Attachment 2
3
396 -
Revision 53 has a detection method that appeared to be inconsistent with the
NUREG-0654 scheme.
Alert
201 -
Detection method changes between Revisions 5 and 53 resulted in deletion of
the and/or between the first and second detection methods in Revision 5 and
added a third detection method IPC CHGNET.
202 -
Detection method changes between Revisions 5 and 53 resulted in deletion of
the phrase pressurizer low pressure alarm and reactor trip; and pressurizer low
level alarm; and RM-A9 high alarm and pressurizer safety injection signal and
undervoltage on 1DA and 1DB buses; and RM-L3, RM-L7, and RM-L10 high
alarm, and added the phrase all of the following: Primary to Secondary
Leakage exceeds 10 gpm as determined per AOP-112.2 AND safety injection is
NOT required per AOP-112.2 AND a loss of offsite power has led to the loss of
condenser vacuum.
203 -
Detection method changes between Revisions 5 and 53 resulted in deletion of all
the Revision 5 methods and added the phrase Entry into EOP-4.0.
204 -
Detection method changes between Revisions 5 and 53 resulted in deletion of all
the Revision 5 methods and added the phrase EOP network has determined a
faulted steam generator exists and primary to secondary leakage exceeds 10
gpm ...
221 -
Detection method changes between Revisions 5 and 53 resulted in deletion of
the phase laboratory analysis which indicates an increase in failed fuel of 1% in
30 minutes or a total failed fuel of 5%.
222 -
Detection method changes between Revisions 5 and 53 resulted in deletion of
RM-A2" with no justification and the addition of RM-G5.
262 -
Detection method changes between Revisions 5 and 53 resulted in deletion of
RM-L3" and the addition of RM-A3 (Gas and Iodine) and RM-A4 (Gas).
Several of the radiation monitor alarm setpoint levels were changed. The
reference to setpoints established in the discharge permit or while steam
generator blowdown is directed to the blowdown system for RM-L5,
RM-L7, and RM-L9 was also deleted.
271 -
Detection method changes between Revisions 5 and 53 resulted in deletion of
the phrase fire potentially affecting safety systems and added the phrase fire
that has the potential for renders both trains of a safety system inoperable per
the Technical Specifications.
296 -
Detection method changes between Revisions 5 and 53 did not incorporate the
loss of indication in the control room or compensating non-alarming indications
unavailable with a significant transient in progress.
Attachment 2
4
297 -
Revisions 53 has a detection method that appeared to be inconsistent with the
NUREG-0654 scheme.
Notification of Unusual Event
101 -
Revision 53 has a detection method that appeared to be inconsistent with the
NUREG-0654 scheme.
104 -
Detection method changes between Revisions 5 and 53 resulted in deletion of
the phrase reduced RCS temperature and pressure and added the phrase see
Initiating Condition 102."
106 -
Detection method changes between Revisions 5 and 53 resulted in deletion of
the phrases Dose equivalent I-131 activity concentration greater than the limit in
figure 3.4-1 of Technical Specifications and laboratory analysis which indicates
an increase in failed fuel of 0.1% in 30 minutes. The revision added the phrase
Primary coolant dose equivalent I-131 activity > 300 ci/gm.
107 -
Revision 53 has a detection method that appeared to be inconsistent with the
NUREG-0654 scheme.
108 -
Detection method changes between Revisions 5 and 53 resulted in deletion of
RM-A9, RM-A10, and RM-A13" and deletion of the phase in valid alarm mode
for more than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and added specific values above background which had to
be maintained for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for the radiation monitors .
109 -
Detection method changes between Revisions 5 and 53 resulted in deletion of
RM-L10 and RM-L3." No 50.54(q) documentation was available for review.
112 -
Revision EAL has a detection method that appeared to be inconsistent with the
NUREG-0654 scheme.
115 -
Detection method changes between Revisions 5 and 53 resulted in deletion of
the phrase significant loss of vital assessment.