ML11307A407
| ML11307A407 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 11/07/2011 |
| From: | NGG Holdings, NRC/RGN-II, Progress Energy Co |
| To: | |
| References | |
| Download: ML11307A407 (31) | |
Text
Crystal River Unit 3 Nuclear Plant Emergency Preparedness Regulatory Conference N
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II Nuclear Regulatory Commission Region II November 7, 2011
O Jon Franke Vice President, Crystal River Unit 3 O John Stephenson Manager, NGG Fleet Emergency Preparedness Introduction O Mark Rigsby Manager, Support Services O Blair Wunderly Manager, Operations O Steve Cahill Director, Nuclear Design Engineering 2
O Apparent Violation O Background O Immediate Corrective Actions O Extent of Condition Agenda O Evaluation Results O Completed Actions O Actions Remaining O Significance O Closing Remarks 3
Requirements Apparent Violation September 23, 2011 License Condition 10 CFR 50.54(q) requires operating license holders to follow and maintain in effect emergency plans which meet the standards in 10 CFR 50.47(b) and Appendix E Apparent Violation 10 CFR 50.47(b)(4) requires 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 Emergency plan emergency action level (EAL) 1.4 (General Emergency -
Gaseous Effluents) contained instrument classification threshold values that were beyond the specified effluent radiation monitors capabilities to accurately measure 4
O 06/24/11: Reviewed Industry Operating Experience on EAL threshold above instrument/monitor range O 06/27/11: Licensee identified OE applicability at CR3, i.e. EAL 1.4 setpoints exceeded the instrument range of RM-A1/RM-A2 instrumentation
Background
g 5
O Immediately returned Radiation Monitor Mid-Range setpoints to the previous EAL 1.4 value O Completed an evaluation of the monitors capabilities and function:
Z Determined that RM-A1/A2 not capable of seeing EAL setpoints associated with EAL 1 4 (a)
Immediate Corrective Actions setpoints associated with EAL 1.4 (a)
Z Established EAL 1.4 threshold at 3 mR/hr on the high-range scale for RM-A1/RM-A2 O Completed Fleet EAL review to determine if similar vulnerabilities existed 6
O Implemented Interim Guidance for EAL Changes Z Field walk-downs for process monitor changes Z Clear expectations for more rigorous reviews X Senior Reactor Operator (SRO)
X EP Functional Area Manager X System Engineer (EALs relating to process equipment such as radiological instruments or environmental monitoring)
Immediate Corrective Actions radiological instruments or environmental monitoring)
Z Technical review by qualified SME (outside of EP)
Z Change Log to include check-off list to aid in the updating of RERP Z Validation review by an Emergency Coordinator Z Review/Approval by Plant Nuclear Safety Committee O Guidance/expectations provided to NGG Fleet/Site procedure writers for EAL changes 7
O Verified EP related instruments/equipment are capable of performing their intended function O Reviewed Emergency Preparedness Implementing Procedures (EPIPs)
Z EAL-Bases Manual Z EM-202, Duties of the Emergency Coordinator Z EM 219 Duties of the Dose Assessment Team Extent of Condition Z EM-219, Duties of the Dose Assessment Team Z EM-400, Operation of the Emergency Operations Facility (EOF)
Z EM-402, EOF Technical Support Team Z EM-911, Security Threats Z EMG-NGGC-0002, Off-Site Dose Assessment Z CH-631, Post Accident Sampling and Analysis of Reactor Building Vent, Auxiliary Building Vent and Reactor Building Atmosphere 8
O Root Cause Z Insufficient procedure detail/guidance for the EAL change process O Key Contributing Causes Evaluation Results Z Assumptions were made and not validated Z Reviews not adequate or not conducted 9
O Nuclear Safety Review Committee review of Root Cause Evaluation O Independent (outside PGN) consultant review of EAL scheme and EP program O Trained EP staff on new guidance for EAL guidance d H P
f F
d t l Completed Actions and Human Performance Fundamentals O EP Staff task analysis review O Reviewed change process for other non-plant operating manual documents O Shared OE with Fleet and Industry 10
O Corrective Action To Prevent Recurrence (CAPR)
Z Codify the interim guidance requiring a more rigorous process with specific guidance on the development, validation and implementation of EALs O Revise EAL Basis Manual and related training materials to more clearly define the RM-A1/RM-A2 mid-range and hi h it d diff t
lib ti Actions Remaining high range monitor responses and different calibration and response factors O Provide Operator training on the Low Medium High Valve Controllers (LMHVC) and the range of operation for RM-A1/RM-A2 mid and high range monitors 11
O EAL 1.4 can be entered by three options:
1)
RM-A1 or RM-A2 mid-range thresholds exceeded for
>15 min 2)
Dose Assessment results indicate SITE BOUNDARY dose >1000 mR TEDE or >5000 mR thyroid CDE for the actual or projected duration of the release AND Significance CR-3 EAL Scheme p
j core damage is suspected or has occurred 3)
Field survey results indicate closed window dose rates
>1000 mR/hr expected to continue for more than one hour; or analyses of field survey samples indicate thyroid CDE of 5000 mR for one hour of inhalation at or beyond SITE BOUNDARY 12
O NRCs White Finding significance determination based on Manual Chapter (MC) 0609 Appendix B, page B-34 (Sheet 1, Failure to Comply)
O Per MC 0609 Appendix B, EAL 1.4 was not degraded O General Emergency Declaration and Notification Z
Other EALs would be met to declare a General Emergency before EAL 1.4 dose thresholds were met Z
EAL 1 4 Option 2 Release Significance Category Determination would Significance General Emergency Declaration Remained Timely and Accurate Z
EAL 1.4 Option 2, Release Significance Category Determination would be conducted also supporting timely classification Z
EAL 1.4 Option 1 with the threshold error, would still contribute to a General Emergency Declaration O Postulated accidents involving site boundary dose rates at PAG levels would result in a timely General Emergency declaration that would not be delayed (<15 minutes)
O Clarification in the Draft Predecisional MC 0609, Appendix B also supports EAL 1.4 was not degraded 13
Significance CR-3 EAL Scheme - Diverse and Redundant Category UE Alert SAE GE Abnormal Radiation Levels/Effluents EAL 1.1-1.4 x
x x
x Natural/Manmade Hazards and EC Judgment x
x x
x System Malfunction x
x x
x 14 Loss of Power x
x x
x Loss/Potential Loss Fuel Clad x
x x
x Loss/Potential Loss RCS x
x x
x Loss/Potential Loss Containment x
x x
x
O Multiple alternative EALs would be met to declare a General Emergency well BEFORE EAL 1.4 dose thresholds would be reached O Fission Product Barrier EALs would be used to declare a General Emergency well before site boundary doses would exceed EPA PAG limits Significance Mitigating Factors/Alternative EALs - RERP exceed EPA PAG limits O Loss of 2 of 3 barriers with potential loss of third = General Emergency O Containment Radiation Monitors would provide indication of General Emergency condition ahead of RM-A1/RM-A2 15
Fission Product Barrier Matrix: Potential Loss Significance Mitigating Factors/Alternative EALs - RERP Potential Loss of Fuel Clad Potential Loss of RCS Potential Loss of Containment Entry into EOP RCS Leak one or more Injection Valves RB Pressure >54 psig Core Exit Thermocouples RCS Leak resulting in ES Actuation RB Hydrogen >4%
16 EC Deems Barrier in Jeopardy RCS Pressure/Temperature RB Pressure >30 psig with no Building Spray available HPI/PORV Cooling in Progress RB High Rad Monitors
>25,000 R/hr EC Deems Barrier in Jeopardy Core Conditions in Severe Accident Region of ICC Curves EC Deems Barrier in Jeopardy
Fission Product Barrier Matrix: Loss Significance Mitigating Factors/Alternative EALs - RERP Loss of Fuel Clad Loss of RCS Loss of Containment Core Condition in Region 3 of ICC Curves RCS Leak Resulting in Loss of Adequate Subcooling Margin Rapid Unexplained RB Pressure Decrease RCS Activity >300 µCi/gm RB High Rad Monitors RB Pressure or Sump Level 17 y
µ g
>100 R/hr for 15 minutes p
not consistent with LOCA Conditions RB High Rad Monitors
>100 R/hr for 15 minutes EC Deems Barrier is Lost OTSG Leak >10 gpm with Prolonged Steaming EC Deems Barrier is Lost RB Isolation incomplete and Release Path Exists EC Deems Barrier is Lost
Fuel Clad Potential Loss EAL 5.2 RCS Potential Loss EAL 6.2 Containment Potential Loss EAL 7.2 Significance Mitigating Factors/Alternative EALs - RERP Simplified Block Diagram Illustrating Relationship of the Fission Product Barrier EALs and EAL 1.4 Loss EAL 5.1 Loss EAL 6.1 Loss EAL 7.1 General Emergency 18 EAL 1.4
O EAL 1.4 can be entered by three options:
1)
RM-A1 or RM-A2 mid-range thresholds exceeded for
>15 min 2)
Dose Assessment results indicate SITE BOUNDARY dose >1000 mR TEDE or >5000 mR thyroid CDE for the actual or projected duration of the release AND Significance CR-3 EAL Scheme p
j core damage is suspected or has occurred 3)
Field survey results indicate closed windows dose rates >1000 mR/hr expected to continue for more than one hour; or analyses of field survey samples indicate thyroid CDE of 5000 mR for one hour of inhalation at or beyond SITE BOUNDARY 19
O Option 1: RM-A1 & RM-A2 O
At some General Emergency levels, mid-range for RM-A1/RM-A2 is beyond usable scale Z
Operator would recognize monitor had transitioned to the high range scale Significance EAL 1.4 Option 1 Z
Plant computer points (W330, W331, W335, & W336) provide continuous data of RM-A1 and RM-A2 mid-range and high-range readings Z
Plant computer data would clearly indicate a mid-range purge and high-range output would be available for EC and Dose Assessment Team evaluation O
Guidance contained in EAL would still contribute to a General Emergency Declaration 20
O Option 2: Dose Assessment Methods O RASCAL Z Primary Method Z Used by Dose Assessment Team at EOF for Alert or Higher O EM-204a Z Control Room Method Significance EAL 1.4 Option 2 Z Uses Low and Mid Range Monitors Z Limited for High Wind Speeds and Short Durations O Release Significance Category Determination Z Quick Method to Assess/Characterize Dose Z Used by Control Room, TSC and EOF Z Core Damage plus Release in Progress would support General Emergency Classification in <15 minutes 21
O Option 3: Field Monitoring Team Results Z Field Monitoring Teams available at an Alert or Higher Z Teams are dispatched from the TSC/OSC and/or by Shift Manager from the Control Room (on-shift RP)
Significance EAL 1.4 Option 3 RP)
Z Provides necessary information for General Emergency declaration using EAL 1.4 22
Fuel Clad Potential Loss EAL 5.2 RCS Potential Loss EAL 6.2 Containment Potential Loss EAL 7.2 Significance Mitigating Factors/Alternative EALs - RERP Simplified Block Diagram Illustrating Relationship of the Fission Product Barrier EALs and EAL 1.4 Loss EAL 5.1 Loss EAL 6.1 Loss EAL 7.1 General Emergency 23 EAL 1.4
O Spent Fuel Pool Accident Z Only other postulated event beyond fission product barrier loss resulting in PAG level site boundary doses Z A catastrophic failure (pool containing fuel and quickly drained) would be declared by EAL 2.27 based on:
The potential for uncontrolled radionuclide releases that can b
t d t d EPA P t
ti A ti G id li Significance Mitigating Factors/Alternative EALs - RERP be expected to exceed EPA Protective Action Guidelines Plume Exposure Levels beyond the site boundary Z Spent fuel pool failure over time would result in an Alert when leakage exceeds makeup capacity Z Dose assessment and field teams would be staffed Z EAL 1.4 Options 2 & 3 would be used to escalate to General Emergency in a timely manner 24
O Actual Experience Z Reviewed Exercises and Drills conducted since 1983 Z Scenarios involving PAG level site boundary doses routinely used Z EAL 1.4 has not been used to declare a General Emergencies (GE) since implemented in June 2000 due to the multiple alternative EAL thresholds that are met well b f it b
d d
h PAG l l
Significance Mitigating Factors/Alternative EALs - RERP before site boundary doses reach PAG levels Z The Dose Projection EAL was used prior to 2000 to declare a GE in some drills (prior to Fission Product Barrier EALs)
Z Previous approved EAL scheme did not include Option 1 (no radiation monitor reading option for GE)
Z Supports the effectiveness of the alternative EALs as Mitigating Factors 25
Significance Manual Chapter 0609, Appendix B 26 GREEN
O Excerpts:
Z As used herein, an EAL is ineffective when it no longer results in a timely and accurate declaration for the initiating condition.
Z An EAL may be rendered ineffective by changes to facility procedures systems or equipment; errors in Significance Mitigating Factors 1 facility procedures, systems, or equipment; errors in numeric thresholds; or any other cause that could result in an initialing condition, which should be declared, not being declared in a timely and accurate manner following the change(s) 27 1Draft Predecisional Manual Chapter 0609, App. B
O EAL schemes often have either redundant or diverse indications for the same Initiating Condition. Credit is to be given to these alternative EALs as MITIGATING FACTORS if they were part of the licensees approved emergency classification scheme before the ineffective EAL was identified.
One of the following two significance situations may exist:
1)
Significance Mitigating Factors 1 1) 2)
If the alternative EALs are such that an accurate and timely declaration of the initiating condition would still be made, the classification function is neither lost nor degraded. In this context, timely means within the 15-minute timeliness capability requirement. For example, loss or potential loss of the fuel barrier EAL may include thresholds such as reactor pressure vessel (RPV) level and drywell radiation monitor. An RPV level threshold is a precursor to core damage and can adequately compensate for an ineffective drywell radiation monitor threshold because the declaration will still be timely and accurate. However, a classification based on drywell radiation monitor threshold rather than an ineffective RPV level would likely be delayed (as the core damage must first occur for the radiation monitor to indicate).
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Significance Draft Manual Chapter 0609, Appendix B 29
O Progress Energy concurs with the Apparent Violation O Immediate actions taken to restore compliance O Prompt extensive and comprehensive Extent of Condition completed O Corrective actions ensure increased rigor in Emergency Plan changes EAL St t
d A id t S i
EAL Closing Remarks O EAL Structure and Accident Scenario EALs Z FPB loss or SFP accidents are precursors to PAG level site boundary doses Z Ensure timely and accurate classification and notification of General Emergency Z Ensure Protective Action Guides are followed Z Protect Public Health and Safety O Progress Energys conclusion, based on MC 0609 Appendix B, is the significance of this Finding is Green 30
Questions?
Questions?
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