ML17277A887

Forwards Request for Addl Info Re Emergency Classification Scheme in Emergency Planning Program.Response Requested by 831028

ML17277A887
Person / Time
Site:	Columbia
Issue date:	10/05/1983
From:	Schwencer A Office of Nuclear Reactor Regulation
To:	Mazur D WASHINGTON PUBLIC POWER SUPPLY SYSTEM
References
NUDOCS 8310120027
Download: ML17277A887 (10)

Text

OCT 5.

188)

DISTRIBUTION:

Document Control:

NRC PDR L

PDR NSIC PRC LB¹2 Rdg.

EHylton RAuluck

WPaton, OELD ACRS (16)

ELJordan, DEQA: IE

JHTaylor, DRP:IE Region V,

RA Docket No. 50-397 Mr. D. W. Mazur Managing Director 3lashfngton Public Power Supply System P. 0. Box 968 3000 George Washington Way Richland, Washfngton 99362

Subject:

Request for Additional Informatfon - WNP-2 Emergency Planning Program As a result of our review of your Emergency Planning Program, we find that we need additional information fn the area of emergency action levels pertaining to the WNP-2 emergency classification scheme.

The specific information fs descrfbed fn the Enclosure.

To maintain our licensing review schedule for the WNP-2, we will need responses to the enclosed request by October 2&, 1983. If you cannot meet this date, please inform us within seven days after receipt of this letter of the date you plan to submit your responses so that we may review our schedule for any necessary changes.

Please contact Rag Auluck, Licensing Pro)ect Manager, ff you desire any dis-cussion or clarification of the enclosed request.

Sincerely, ppjginal signed >P

Enclosure:

As stated A. Schwencer, Chief Licensing Branch No.

2 Division of Licensing cc w/enclosure:

See next page 83iOi20027 831005 PDR ADOCN 05000397 F

PDR OFFICEt/

SURNAME/

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NRC FORM 318110/80) NRCM 0240 OFFICIAL RECORD COPY K'ft

'lgpJ Q UZ. GPO 1983~00.247

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WNP-2 Mr. D. Mazur Managing Director Washington Public Power Supply System P. 0.

Box 968 3000 George Washington Way Richland, Washington 99352 CC:

Nicholas Reynolds, Esquire Debevoise 5 Liberman 1200 Seventeenth

Street, N.

W.

Washington, D. C.

20036 Mr. G. E. Doupe, Esquire Washington Public Power Supply System P.O.

Box 968

'000 George Washington Way

Richland, Washington 99352 Nicholas Lewis, Chairman Energy Facility Site Evaluation Council Mail Stop PY-ll Olympia, Washington 98504 Roger Nelson, Licensing Manager Washington Public Power Supply System P.O.

Box 968

Richland, Washington 99352 Mr.

W. G..Conn, Sr.

N/M Group Supervisor Burns and Roe, Incorporated 601 Williams Boulevard

Richland, Washington 99352 Mr. Richard Feil U.S.

NRC Resident Inspector WPPSS-2 NPS P.O.

Box 69

Richland, Washington 99352 Dr. G. D. Bouchey, Manager Nuclear Safety 8 Regulatory Programs Washington Public Power Supply System P.O.

Box 968, MD 650

Richland, Washington 99352

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ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION AND COMMENTS ON THE REVIEW OF WPPS WASHINGTON NUCLEAR PLANT g2 (WNP-2)

EMERGENCY CLASSIFICATION SYSTEM AND EMERGENCY ACTION LEVELS (EALs) s 432.26, The following comments have been developed as a result of the review of the EALs.

These comments should be incorporated into the licensee's emergency classification and action level scheme as presented in the Emergency Plan and Emergency Plan Implementing Procedure (EPIP)

13. 1. 1, "Emergency Classification

.System."

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d -0 C1 111 01 5

)F 10 CF0 550.47)

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.

Syyno >si s Emergency classification and action level schemes (EALs) compatible with NUREG-0654 Appendix 1 have been established.

Evaluation The licensee's plan and procedure satisfies Planning Standard D except as noted.

As a result of the EAL review, it was noted that Section 6 of the Emergency Plan (EP) dealing with classification should be reviewed and modified by the licensee to make it consistent with EPIP 13. 1. 1 for the following reasons:

a) b)

The EP discusses and categorizes the initiating conditions based on NUREG-0696 "Safety Groups" of reactivity control, core cooling parameters, coolant system integrity, containment integrity, and radioactivity control.

No mention is made of these "groups" in the EPIP section.

The EP and the EPIP do not include NUREG-0654 Appendix 1 class description statements as concerning radioactive material releases for Unusual Event, or class description statements concerning amounts of releases related to EPA Protective Action Guidelines (PAG) for Alert, Site Area Emergency, nor General Emergency.

c)

EP Tables 6-1 through 6-4, WNP-2 Initiating Conditions cross reference for Unusual Event, Alert, Site Area Emergency, and General Emergency respectively, contain numerous inaccuracies such as EP paragraphs listed

e) in the table that are not included in the plan, and EP paragraphs listed that do not correspond to the NUREG-0654 condition.

If such a

cross-reference table is to be used, cross-reference to the corresponding EPIP paragraph would be much more valuable to the user.

Numerous example initiating conditions of NUREG-0654 Appendix 1 are omitted or listed as "later" by the licensee.

Although not necessarily deficient, it was noted that many example initiating conditions of the Appendix are abstracted or paraphrased, and many more conditions (EALs) are found in the EP/EPIP than in NUREG-0654 Appendix I (example:

volcanic ash fallout).

Comments on EAL sets that are in error or are deficient are addressed, below by classification and the number of the initiating conditions within the classification.

Plannin Standard 0 - Evaluation Criteria (From NUREG-0654)

An emergency classification and-emergency action level scheme as set forth in Appendix I must be established by the licensee.

The specific instruments, parameters or equipment status shall be shown for establishing each emergency class, in the plant emergency procedures.

The plan shall identify the parameter values and equipment status for each emergency class.

Unusual Event Initiatin Condition 2 - Radiolo ical effluent technical s ecification limits excee ed.

e icensee as iste t eir E

L as

....in excess of Sp i

i lilt ifidbypl iyi."'Th licensee should consider deleting the modifier "as verified by sample analysis" since such analysis may inhibit the timeliness of classification and notification.

Initiatin Condition 7 - Loss of offsite ower or loss of onsite AC ower ca a i it e

oss o

o site power is o

itse not a

imiting con ition or operation, but the loss of onsite AC power capability is a

technical specification LCO.

The licensee should list as an example under Situation based initiating conditions (Unusual Event) loss of onsite AC power capability to call attention to the seriousness of the condition.

Initiatin Condition 8 - Loss of containment inte rit re uirin shutdown tec nica s eci ication.

t oug t is examp e wou e covere y

the icensee s genera statement of "Any plant condition requiring plant shutdown as a result of exceeding the LCO and associated action items

.....", the licensee should list this condition as an example under Situation Based Initiating Conditions (Unusual Event).

Initiatin Condition 13.b - 50 ear flood or low water,....

The icensee has isted oods river pump ouse in anger or inundation)".

The licensee should change this condition to read "..... in danger of inundation as observed" or "river level rising to feet of reported by appropriate monitoring agencies."

Initiatin Condition 14.a - Aircraft crash onsite or unusal aircraft activit over aci it.

e icensee s ou c ange iste equiva ent to rea

~ ircra t eras or unusual aircraft activity over facility, or train derailment onsite (if safety-related equipment is affected, see higher classification)".

Alert Initiatin Condition 5 - Primar coolant leak rate reater than 50 m;

ropose sets a

ress t is examp e initiating con ition on y indirectly, for example, "Situations where a release of radioactive material warrants...".

The licensee should prepare two EAL sets that include losses outside containment and primary coolant losses inside containment, but perhaps measured outside of containment.

Initiatin Condition 6 - Radiation levels or ai rborne contamination which in icate a severe e radation in t e contro o

ra ioactive materia s.

ropose L sets a dress t is examp w initiating con ition on y indirectly, for example, "Situations where a release of radioactive materials warrant....".

The licensee should prepare two EAL sets that include, for example, alarm with indication of recorder of increase of 1000x alarm setpoint on area radiation monitoring system or......

in airborne contamination.

Initiatin Condition 19 - Other lant conditions exist that warrant recautionar activation o

ec nica u

ort enter an acin near-site mer enc erations aci it an ot er e

emer enc ersonnel on stan e

icensee as erroneous y inc u

e in ituation ase nitiating Conditions (Site Area Emergency)",

paragraph 2.c, page

13. 1. 1-12 "Any plant condition that.... warrants the activation of the Technical Support Center (TSC), Operations Support Center, and Emergency Operations Facility for purpose of....".

In addition to correcting this wording appropriate for Site Area Emergency, the licensee should change the wording of the listed initiating condition "....warrant the use of addition personnel for accident assessment and in-plant response" to agree with NUREG-0696 and the initiating condition examples of NUREG-0654, Appendix I.

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V r

s Initiatin Condition 20 - Evacuation of Control Room antici ated or re uired wit contro o

s ut own s

stems estab is e

rom oca stations.

e

~censee as

>ste ontro oom evacuation

, and should re->nsert the word "anticipated" to achieve a satisfactory EAL.

Site Area Emer enc Initiatin Condition 2 -

De raded core with ossible loss of copiable eometr e

L set s ou e en ance y consi ering t e suggestions

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o NU G-0818.

Initiatin Condition 13.a - Effluent monitors detect levels corres ondin to reater t an 5

mR r

or 4 our or reater t an mR r w o e o

or two minutes at t e site oundar or a verse meteoro o

e icensee s ou d revise t e isted E

L to comp y wit t e UREG-0654 Appendix I initiating condition.

Initiating conditions 13.b and c should be similarly incorporated.

General Emer enc Initiatin Condition l.a and b - Effluent monitors detect (or dose rates are rogecte ase on ot er ant arameters eve s corres on in to 1

em r w o e bo or 5

em r t roi at t e site oun ar un er actua meteoro o ica con itions.

e icensee s

ou mo i y t e iste con itions to corre ate with the NUREG-0654 Appendix I initiating condition.

Protective Action Decision Hakin EALs General Emer enc Initiatin Condition 4 - Other lant condition.

The icensee addressed t is initiating condition as 'y maj or event that could couse a degradation of plant safety such that the release of large amounts of radioactive material in a short period of time is possibie."

Protective action decision by offsite officials for a General Emergency was not included in the EALs..

A review of EPIP 13. 14.2, Process for Determining Protective Action Recommendations, showed the flow chart to be absent.

Plannin Standard D - Evaluation Criteria (From NUREG-0654) 2.

The initiating conditions shall include the example conditions found in Appendix 1 and all postulated accidents in the Final Safety Analysis Report (FSAR) for the nuclear facility.

4

The following initiating conditions were not addressed by the licensee:

Unusual Event 9 (loss of engineered safety feature),

11, 14.e.

Alert 7, 8, 12, 14, 16, 17.a, 18.b, 18.e.

Site Area Emergency 6, 7, 10, 12, 14, 15.c, 16, 18 General Emergency 3, 7

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