ML17158A345
| ML17158A345 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/13/1994 |
| From: | Poslusny C Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9406210032 | |
| Download: ML17158A345 (11) | |
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Docket Nos.
50-387 and 50-388 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 June 13, 1994 LICENSEE:
Pennsylvania Power 8 Light Company (PP8L)
FACILITY:
Susquehanna Steam Electric Station, Units 1 and 2
SUBJECT:
MEETING WITH PENNSYLVANIA POWER AND LIGHT COMPANY STAFF TO DISCUSS REVISIONS TO THE SUSQUEHANNA STEAM ELECTRIC STATION (SSES)
SITE EMERGENCY PLAN JUNE 2, 1994 In January
- 1993, PP8L submitted a complete revision of its Emergency Plan (EP) implementing the new Emergency Action Levels (EALs) based on the NUMARC NESP-007 methodology.
In this submittal, the licensee had identified and justified a number of exceptions to the NUMARC methodology which were further addressed in a January 1994 submittal.
On June 2,
- 1994, NRC and PP&L staff met at the SSES Emergency Operations Facility to discuss the NRC position on some of these exceptions which would require further justification, clarification, or revision for final approval and implementation.
Enclosure 1 is a list of those who attended the meeting and Enclosure 2 is a list of staff concerns related to the proposed EALs provided by PP&L for which the staff had requested clarification or modification in previous discussions.
This list was the basis for detailed discussions during the meeting.
The following is a-brief summary of commitments for each concern listed in Enclosure 2 which were made during the meeting intended to lead to resolution of staff concerns and ultimate approval of the final EP.
(Note:
Refer to PP8L submittals dated January 21, 1993, "Susquehanna Steam Electric Station Revision to Emergency Plan",
and January 5,
- 1994, "Susquehanna Steam Electric Station
Response
to RAI on Revision to Emergency Plan Which Implemented NUMARC NESP-007" for a detailed listing of the EALs referenced in this meeting summary.)
1.
Lack of a fission product barrier matrix in the EALs.
The staff indicated that it is not necessary to include EAL's which indicate the loss or potential loss of a-fission product barrier in a matrix form as long as the PP&L clarification scheme results in an event being classified consistent with that resulting from using NUMARC methodology.
Additional staff evaluation of the equivalence of PP&L fission product EALs and the NUMARC fission product barrier matrix is yet to be completed.
It was agreed that the three bullets listed under this item would not be discussed but would be addressed in a follow-up conference call.
2.
Initiating conditions (ICs) are not included in the EALs After significant discussion, PP8L agreed to reformat their EALs to include ICS in each EAL.
The licensee committed to prepare a revised set of EALs and
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would discuss them with operators to determine the interface with Emergency Operating Procedure actions and decision processes.
Subsequently, the new EALs would be submitted to the staff for approval.
PPKL stated that it is important to have the approved in the near term to accommodate the training schedule window this year.
3.
EAL 2. 1.4a does not use the maximum core uncovery time graph.
The licensee provided a discussion of the justification for not using the NUNARC guidance based on the need to maintain consistency with the EOPs.
The staff found the justification acceptable and requested that it be provided to the staff in writing.
4.
EAL 2. 1.4.b classification may be overconservative; this would also apply to EAL 2.1.3.b.
PP8L indicated that it would modify the basis to discuss the importance of water level as an indicator of a significant transient and would add information taken from the corresponding EOP to indicate how the operator is aware that the water level is truly lost.
The proposed changes were acceptable to the staff.
5.
EAL 2.2.3 does not address all conditions.
PP&L agreed to specify a 5X power level in the EAL and to add a justification for the basis for a 110 'F suppression pool temperature.
6.
EAL 2.2.4 needs a justification for the 200 'F degree suppression pool temperature.
PP8L agreed to provide additional discussion of core cooling and heat removal capability of the pool in the EAL.
7.
EAL 3.1.2 needs a justification for the time period allowed for a 50 gpm leak of reactor coolant before an alert is declared.
PP8L indicated that leakage of that magnitude was difficult to measure accurately and that the more significant parameter to monitor was the drywell pressure.
NUMARC guidance indicates 1.72 psi would require an alert, but PPSL indicated that 3 psi is more justified because of the number of automatic and manual mitigation features in the design.
The staff agreed to evaluate the licensee's position further.
8.
EAL 4.2.2 classification as an alert level is in question.
The staff stated that this EAL was not part of the NUHARC package but suggested that PPKL modify the basis to reflect the indicators of low flow of main steam.
The staff also indicated that it would further consider the justification provided for this EAL.
9.
The dose calculation methodology used in Section
- 5. 1 EALS needs discussion.
PP&L indicated that the average annual meteorology as per RG 1.3 was used and the FSAR source terms were also used.
It was also stated that although the NUMARC document recommended using 200 times the technical specification (TS) dose limits for iodine for an alert level, 20 times the TS limits were used for Susquehanna based on realistic site meteorology.
10.
EAL 5.2.3 does not reflect NUMARC guidance.
PP&L agreed to provide a justification for reflecting the effective dose instead of the dose rate in this EAL.
ll.
EAL 5.2.4 does not reflect NUMARC guidance.
PP&L agreed to provide a justification for reflecting the effective dose instead of the dose rate in this EAL.
12.
EAL 6. 1.2 needs to address having one offsite line and no diesels.
PP&L agreed to make this change to the EAL.
13.
EAL 6. 1.4 does not include"fission product barrier monitoring.-
PP&L indicated that it had considered the information to be redundant to that included in fission product barrier EAL but the staff indicated that it was not.
The licensee agreed to review this EAL and'ake the necessary changes for conformity with the NUMARC guidance.
14.
EAL 7.3.3:
Clarify what will stop HPCI and RCIC from operating.
PP&L indicated that the actual pressure in the discharge line will stop the ECCS systems from injecting.
In addition, these lines can be manually isolated.
The staff indicated that it will reconsider this EAL.
15.
EAL 7.4.1.a:
Clarify whether the examples in Table 7.4. 1 should be joined with "and" or "or".
PP&L committed to look into this EAL for possibly adding further clarification.
16.
EAL 8.1.1 is not consistent with NUMARC guidance.
PP&L agreed to revisit this EAL, will provide additional justification, and will revise the EAL for clarification.
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4 Upon closure of the meeting, it was agreed that a status conference call will be held on Monday, June 13, at 2 p.m.
Enclosures:
1.
List of Attendees 2.
PP&L Handout cc w/enclosures:
See next page Original signed by:
, Chester Poslusny, Jr., Project Hanager Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation DISTRIBUTION w/Enclosure 1
WRussell/FHiraglia LReyes SVarga JCalvo CMiller HO'Brien OGC
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Upon closure of the meeting, it was agreed that a status conference call will be held on Monday, June 13, at 2 p.m.
Enclosures:
1.
List of Attendees 2.
PP8L Handout Chester Poslusny, Jr., Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation cc w/enclosures:
See next page
Pennsylvania Power E Light Company Susquehanna Steam Electric Station, Units 1
& 2 CC:
Jay Silberg, Esq.
- Shaw, Pittman, Potts
- 5. Trowbridge 2300 N Street N.W.
Washington, D.C.
20037 Bryan A. Snapp, Esq.
Assistant Corporate Counsel Pennsylvania Power 5 Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Mr. J.
M. Kenny Licensing Group Supervisor Pennsylvania Power 8 Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Mr. Scott Barber Senior Resident Inspector U. S. Nuclear Regulatory Commission P.O.
Box 35 Berwick, Pennsylvania 18603-0035 Mr. William P. Dornsife, Director Bureau of Radiation Protection Pennsylvania Department of Environmental Resources
,P. 0.
Box 8469 Harrisburg, Pennsylvania 17105-8469 Mr. Jesse C. Tilton, III Allegheny Elec. Cooperative, Inc.
212 Locust Street P.O.
Box 1266 Harrisburg, Pennsylvania 17108-1266 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Mr. Harold G. Stanley Superintendent of Plant Susquehanna Steam Electric Station Pennsylvania Power and Light Company Box 467 Berwick, Pennsylvania 18603 Mr. Herbert D. Woodeshick Special Office of the President Pennsylvania Power and Light Company Rural Route 1,
Box 1797 Berwick, Pennsylvania 18603 George, T. Jones Manager-Engineering Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Mr. Robert G.
Byram Senior Vice President-Nuclear Pennsylvania Power 5 Light Company 2 North Ninth Street Allentown, Pennsylvania 18101
ENCLOSURE 1
MEETING BETWEEN NRC
& PP&L DISCUSSION OF REVISIONS TO EMERGENCY PLAN JUNE 2, 1994 ATTENDEES Chet Poslusny Cornelius T. Coddington Jim O'rien Jim Minneman Bill Maier Chuck Myers Robert Barkley ORGANIZATION NRR/NRC PP&L Licensing NRR/NRC PP&L NRC - Region I PP&L PP&L PHONE NUMBER (301) 504-1402 (610) 774-7915 (301) 504-2919 (610)'774-7872 (610) 337-5344 (610) 774-6576
ENCLOSURE 2
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May 25, 1994 J.
M. Minneman C. A. Myers A. M. Price D. J.
Steffenauer A2-3 A2-4 SSES SSES SUSQUEHANNA STEAMELECTRIC STATION NRC MEETING ON EMERGENCY ACTIONLEVELS 77658 The meeting with the NRC to discuss our proposed EALs willbe held on June 2, 1994, in the small conference room in the EOF starting at noon. The followingNRC personnel willbe at the meeting:
Jim O'Brian, NRR; Chet Poslusny, NRR Project Manager; and a Region I inspector.
The NRC would like us to address the followingissues and questions:
1.
The main concern of the NRC is that our proposed EALs do not contain a fission product barrier matrix.
They are concerned &om both a technical area as well as from a human factors point of view.
They are concerned that since we classify using single points, this could lead to either over classifying or under classifying the event.
They are also concerned that without a matrix we willnot have a 'big picture ofthe event, Also without a matrix the notification to the outside agencies could be confused and could add confusion to the NRC monitoring ofthe event.
The followingtechnical issues are ofconcern to the NRC:
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Our treatment ofthe potential loss ofcontainment based on 4% hydrogen.
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Are there any events that would result in a containment pressure of> 53 psig other than a design basis LOCA?
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Is a containment rad monitor reading of2.8K really an indication ofthe potential loss of RCS?
The NRC acknowledged that NUhdARC never stated that the Qssion product barrier matrix had to be in the form ofa table. The NRC willpresent an alternative position at the meeting.
2.
The NRC's second major concern is that our EALs do not contain initiating conditions. They are concerned that there willbe miscommunication with outside agencies.
The NRC would like a discussion ofwhy our EALs work without containing initiating conditions.
3.
The NRC would like to know why we did not use the maximum core uncovery time graph
&om the EOPs in EAL2.1.4.a.
Other utilities use this graph.
4.
The NRC feels that the loss ofwater level indication indicated in EAL2.1.4.b may be an over
~ classification.
They believe that this is a loss of indication event and not a loss of fuel integrity. This would also apply to EAL2.1.3.b.
5.
The NRC does not believe that EAL 2.2.3 covers all conditions.
They want to discuss this further.
- 6. In EAL2.2.4, why was 200'F chosen?
7.
The NRC is concerned withthe time itwould take to declare an alert for a 50 gpm water leak inside containment in EAL 3.1.2.
They would like to discuss why it is acceptable to have a 50 gpm leak for over an hour before an alert is declared.
8.
What is the reason that EAL4.2.2 is classified at the alert level instead ofan unusual event or site area emergency?
9.
The NRC would like to discuss our dose calculation methodology that is used in the EALs for Section 5.1.
- 10. Why was EAL4 ofNUMARC's AS1 not included in EAL5.2.3?
- 11. Why was EAL4 ofMB~C's AG1 not included in EAL 5.2.4?
- 12. EAL 6,1.2 should be revised to account for the situation of having one offsite line and no diesels.
- 13. EAL 6.1.4 should be revised to included fission product barrier monitoring as stated in the hHJIVfARC guidance.
&om operating?
- 15. For EAL7.4.l.g are the examples in the table 'or'r are they 'and'?
- 16. EAL 8.1.1 does not meet the guidance given by NUMARCin that it does not discuss either a bomb discovered within the protected or any other events that are determined Gum the Safeguards Contingency Plan.