ML17291A173
| ML17291A173 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/24/1994 |
| From: | Clifford J Office of Nuclear Reactor Regulation |
| To: | Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| TAC-M88504, NUDOCS 9407060092 | |
| Download: ML17291A173 (12) | |
Text
I a
a June 24, 1994 Docket No. 50-397 Mr. J.
V. Parrish (Mail Drop 1023)
Assistant Managing Director, Operations Washington Public Power Supply System P. 0.
Box 968
- Richland, Washington 99352-0958
Dear Hr. Parrish:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING EMERGENCY ACTION LEVELS (TAC NO., H88504)
Enclosed is a request for additional information (RAI) related to your December 30, 1993, letter on revisions to your emergency plan implementing procedures.
Our review is focused on the emergency action levels proposed in your submittal.
After you have reviewed the enclosure, please contact me at 301-504-1352 to discuss schedules for response and subsequent NRC review.
Sincerely, Jamegs iI. 8/Nhrd, Senior Project Hanager Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation
Enclosure:
Request for Additional Lnformation cc w/enclosure:
See next page DISTRIBUTION:~
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& Local PDRs JRoe EAdensam TQuay JO'Brien JClifford DFoster-Curseen OGC ACRS (10)
- KPerkins, RIV, WCFO OFC LA:DRPW PH'PDIV-D: PDI NAME DFoster-Curseen JCli ord:
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WNP88504. RAI r '<0706009 05000397 Z 9+0624 PDR ADOCK PDR P
I UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 2055~001 June 24, 1994 Docket No. 50-397 Hr. J.
V. Parrish (Hail Drop 1023)
Assistant Hanaging Director, Operations Washington Public Power Supply System P. 0.
Box 968
- Richland, Washington 99352-0958
Dear Hr. Parrish:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING EHERGENCY ACTION LEVELS (TAC NO. H88504)
Enclosed is a request for additional information (RAI) related to your December 30, 1993, letter on revisions to your emergency plan implementing procedures.
Our review is focused on the emergency action levels proposed in your submittal.
After you have reviewed the enclosure, please contact me at 301-504-1352 to discuss schedules for response and subsequent NRC review.
Sincerely, Ja es W. Clif ord, Senior Project Hanager Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation
Enclosure:
Request for Additional Information cc w/enclosure:
See next page
(I t
f
Hr, J.
V. Parrish Washington Public Power Supply System WPPSS Nuclear Project No.
2 (WNP-2)
CC:
Hr. J.
K. Swailes WNP-2 Plant Hanager Washington Public Power Supply System P. 0.
Box 968
- Richland, Washington 99352-0968 G.
E.
C. Doupe, Esq.
(Hail Drop 396)
Washington Public Power Supply System 3000 George Washington Way P. 0.
Box 968
- Richland, Washington 99352-0968 Hr. Warren Bishop, Chairman Energy Facility Site Evaluation Council P. 0.
Box 43172 Olympia, Washington 98504-3172 Hr. II. K. Kook (Hail Drop PE20)
WNP-2 Licensing Hanager Washington Public Power Supply System P. 0.
Box 968
- Richland, Washington 99352-0968 Hr.
Paul R.
Bemis (Hail Drop PE20)
Regulatory Programs Hanager Washington Public Power Supply System P. 0.
Box 968
- Richland, Washington 99352-0968 Regional Administrator, Region IV U.S.
Nuclear Regulatory Commission Harris Tower
& Pavilion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Chairman Benton County Board of Commissioners P. 0.
Box 190
- Prosser, Washington 99350-0190 Hr.
R.
C. Barr U. S. Nuclear Regulatory Commission P. 0.
Box 69
- Richland, Washington 99352-0968 H.
H. Phil ips, Jr.,
Esq.
Winston
& Strawn 1400 L Street, N.W.
Washington, D.C.
20005-3502
Enclosure RE(VEST FOR ADDITIONAL INFORMATION REGARDING WASHINGTON NUCLEAR PROJECT NO.
2 EMERGENCY ACTION LEVEL REVISION TO NUMARC/NESP-007 METHODOLOGY The Emergency Preparedness Branch has completed its initial review of the proposed emergency action levels (EALs) in the Washington Nuclear Project No.
2 (WNP-2) draft procedure
- 13. 1. 1, "Classifying the Emergency."
The proposed EALs were reviewed against the guidance in NUMARC/NESP-007, "Methodology for Development of Emergency Action Levels" (Rev. 2).
NUMARC/NESP-007 has been endorsed by the NRC in Regulatory Guide 1. 101 (Rev. 3),
"Emergency Planning and Preparedness for Nuclear Power Reactors,"
as an alternative means by which licensees can meet the requirements in 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50.
Because the staff has previously endorsed the guidance in NUMARC/NESP-007, the staff focused on EALs that deviated from the guidance and EALs that required the development of site-specific thresholds.
In its initial review, the staff has identified a number of EALs for which additional information is needed to determine whether the EALs conform with NUMARC/NESP-007.
General Mode A licabilit The WNP-2 EAL scheme did not include the defueled mode as an applicable mode for EALs corresponding to NUMARC/NESP-007 EALs for which "all modes" were applicable.
2.
3.
Justify this deviation from the NUHARC/NESP-007 guidance.
General Safe Shutdown Buildin s The WNP-2 EAL scheme included EALs that referred to events occurring in or affecting "safe shutdown buildings."
A list of safe shutdown buildings was not included in the EAL scheme.
A list was included in the basis document supporting the EAL scheme.
Including the list of safe shutdown buildings within the EAL scheme would expedite the classification process.
Revise the EAL scheme to include a list of safe shutdown buildings or explain why including a list of safe shutdown buildings is not needed to efficiently classify events.
WNP-2 Initiatin Condition IC GU1:
An Un la'~oned Release of Gaseous or Li uid Radioactivit to the Environment That Exceeds Two Times the Radiolo ical Technical S ecifications for 60 minutes or Lon er a.
The WNP-2 EAL under Initiating Condition (IC) GUI ("Sample analysis and offsite dose calculations indicate greater than TWO times ODCM B6.2.2. 1 (B6.2. 1.2) limits for greater than 60 minutes") deviates from the NUMARC/NESP-007 EAL under IC AUl ("Confirmed sample
b.
C.
analyses for gaseous or liquid releases indicate concentrations or release rates with a release duration of 60 minutes or longer in excess of two times (site-specific technical specifications)").
The WNP-2 EAL requires that sample analysis and dose calculations exceed the threshold, whereas the corresponding NUMARC/NESP-007 EAL requires only a confirmed sample analysis.
Justify this deviation.
Give the setpoint for the "HIGH Alarm" specified in the WNP-2 EAL under IC GUl ("Valid HIGH alarm on any of the following monitors...")
and information on the relationship between the alarm setpoint and the EAL threshold of two times the radiological technical specifications.
Provide information regarding the procedure that prompts dose assessments to be performed.
WNP-2 IC GAI:
An Un lanned Release of Gaseous or Li uid Radioactivit to the Environment That Ex"eeds 200 Times the Radiolo ical Technical S ecifications for 15 ninotes~or Lon er a.
b.
The WNP-2 EAL under IC GA1 ("Sample analysis and offsite dose calculations indicate greater than 200 times ODCH limits for greater than 15 minutes") deviates from the NUMARC/NESP-007 EAL under IC AAI
("Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates with a release duration of 15 minutes or longer in excess of 200 times (site-specific technical specifications)").
The WNP-2 EAL requires that sample analysis and dose calculations exceed the threshold, whereas the corresponding NUHARC/NESP-007 EAL requires only a confirmed sample analysis.
Justify this deviation.
Give the setpoint for the "HIGH Alarm" specified in the WNP-2 EAL under IC GAI ("Valid HIGH alarm on any of the following monitors...")
and information on the relationship between the alarm setpoint and the EAL threshold of 200 times the radiological technical specifications.
WNP-2 IC GSI:
Boundar Dose Resultin from an Actual or Imminent Release of Gaseous Radioactivit That Exceeds 100 mR Total Effective Dose E uivalent or 500 mR Child Th roid Committed Dose E uivalent for the Actual or Pro 'ected Duration of the Release a ~
The WNP-2 EAL under IC GS1 ("Reading on one or more of the following monitors that exceeds or is expected to exceed the value shown:
PRH-RE-1B 133,000 CPS with SGT off... AND Is verified by Offsite Dose Calculation to indicate greater than 100 mrem TEDE or 500 mrem thyroid CDE for the actual or projected duration of the release" )
deviates from the corresponding NUMARC/NESP-007 EAL under IC ASl ("A
valid reading on one or more of the following monitors that exceeds or is expected to exceed the value shown indicates that the release may have exceeded the above criterion and indicates the need to assess the release with (site-specific procedure)...
Note: If the monitor reading(s) is sustained for longer than 15 minutes and the required assessments cannot be completed within this period, then the declaration must be made based on the valid reading").
The WNP-2 EAL does not require declaration on the valid reading if dose assessment cannot be completed within 15 minutes.
Justify this deviation.
b.
The meteorology (worst case) and default time (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) used to calculate the setpoints for the WNP-2 EAL under IC GS1 differs from the meteorology (annual average) and default time (I hour) specified in NESP.
Justify this deviation.
In addition, provide information regarding the relationship of the Alert level radiological effluent monitor EAL setpoint and the Site Area Emergency level radiological effluent monitor EAL setpoint.
c.
The WNP-2 IC GSI refers to "Child Thyroid," whereas the EAL under this IC refers to "Thyroid."
Justify the difference in terminology between the IC and EAL.
WNP-2 IC OUI:
Unex ected Decrease in Water Coverin Irradiated Fuel Assemblies The WNP-2 EAL under IC OUI did not include increases in area radiation monitor readings as a site-specific indication of the decrease in water level in the reactor refueling cavity or spent fuel pool.
Justify not including area radiation monitor readings as a site-specific indication of uncontrolled water level decrease in the reactor refueling cavity or spent fuel pool.
WNP-2 IC FUI:
Unex ected Increase in Plant Radiation Levels The WNP-2 EAL under IC FUI is "Any of the following Area Radiation Monitors exceeding 5,000 mr/hr:...."
The corresponding NUMARC/NESP-007 EAL under IC AU2 is "Valid Direct Area Radiation Monitor readings increases by a factor of 1000 over normal levels."
Show how this WNP-2 setpoint corresponds to 1000 times normal levels.
WNP-2 IC FAI:
Ha 'or Dama e to Irradiated Fuel or Loss of Water Level That Has or Will Result in the Uncoverin of Irradiated Fuel Outside the RPV
a.
One of the EALs specified under IC FAl is "A valid HIGH alarm on one or more of the following radiation or airborne monitors...."
Give the setpoint for the "HIGH" alarm specified in this EAL.
b.
WNP-2 IC OA2 ("Loss of Water Level That Has or Will Result in the Uncovering of Irradiated Fuel Outside the RPV") is very similar to the IC for FA1.
Justify the inclusion of both of these similar ICs.
9.
Fuel Clad Barrier Loss Reactor Vessel Water Level The WNP-2 EAL for the RPV level indication of the loss of the fuel clad barrier and the potential loss of the containment barrier is "Entry into PPM 5.1.7."
Justify the use of this procedure entry condition as an EAL for the loss of the fuel clad barrier and the potential loss of the containment barrier.
In addition, provide a copy of relevant parts of PPM 5. 1.7.
10.
Fuel Clad Barrier Loss Dr well Radiation Monitor Give the calculations for the drywell monitor setpoints used as an indication of the loss of the fuel clad barrier, loss of reactor coolant system barrier, and potential loss of the primary containment barrier.
ll.
Fuel Clad Barrier Loss - Main Steam Line Radiation Monitor Main steam line radiation level HI HI is included in the WNP-2 EAL scheme as an indication of the loss of the fuel clad barrier.
The basis for this EAL specifies that a main steam line radiation HI HI is an indication of the potential loss of fuel clad.
Justify including the main steam line radiation monitor as an indication of the loss or potential loss of fuel clad barrier and revise the EAL or basis document as needed to achieve consistency.
12.
Reactor Coolant S stem Loss Dr well Pressure The WNP-2 EAL for the drywell/containment pressure indication of the loss of the reactor coolant system (RCS) barrier is "Drywell pressure greater than 1.68 psig WITH indications of a leak inside drywell."
Justify including the condition "indication of a leak inside drywell."
In particular, describe which indicators operators will use to determine whether a leak exists inside the drywell.
13.
Reactor Coolant S stem Potential Loss RCS Leak Rate One of the WNP-2 EALs for the RCS indication of the loss of the RCS
barrier is "Primary System discharging outside Primary Containment as indicated by Area Temperature Alarm(s) or Radiation Alarm(s)
AND The affected containment penetration cannot be isolated."
Justify including the condition "The affected containment penetration cannot be isolated" in this EAL.
14.
Containment Barrier Loss Containment RCS Leak Rate 15.
The WNP-2 EAL'or the Containment Valves indication of the loss of the Containment barrier is, "Primary System discharging outside Primary Containment as indicated by Area Temperature 'Alarm(s) or Radiation Alarm(s)
AND The affected containment penetration cannot be isolated."
Justify including the condition "The affected containment penetration cannot be isolated" in this EAL.
Containment Barrier Potential Loss Dr well Pressure 16.
~ +
17.
The WNP-2 EAL for the Drywell/Containment Pressure indication of the potential loss of the containment barrier is "Containment pressure greater than 39 psig.... (or)... Wetwell pressure exceeds PSP."
Discuss why the design pressure of the containment was not used as the basis for this EAL as is specified in the basis for the corresponding EAL in NUHARC/NESP-007.
Containment Barrier Potential Loss Reactor Vessel Level The WNP-2 EAL for the potential loss of the containment barrier did not include an EAL corresponding to the NUHARC/NESP-007 EAL:
"Reactor vessel water level LESS THAN (site-specific) value and the maximum core uncovery time limit is in the UNSAFE region."
Justify this deviation from the NUHARC/NESP-007 guidance.
Vehicle Crash WNP-2 EAL ¹3 under IC LAl ("Vehicle crash into or projectile impacting safe shutdown plant structures or systems which represents a potential degradation to the safety of the plant" ) deviates from the corresponding NUMARC/NESP-007 EAL under IC HA1 by including the condition "which represents a potential degradation to the safety of the plant."
Justify this deviation from the NUNARC/NESP-007 guidance and specify how users of the EAL will determine whether this condition has been met.
18.
Turbine Failure WNP-2 EAL ¹6 under IC LA1 ("Turbine failure resulting in casing penetration or damage to turbine or generator seal AND Missiles generated from the turbine failure have affected safety related
19.
20.
21.
22.
23.
equipment") deviates from the corresponding NUMARC/NESP-007 EAL under IC HAI by including the condition "have affected safety related equipment."
Justify this deviation from the NUMARC/NESP-007 guidance.
Secur't Events It is not clear that the EALs listed under the Security Event ICs are appropriate.
For instance, IC NAl includes as one of its conditions a
bomb discovered in the vital area.
Under the NUHARC/NESP-007 EAL
- scheme, a
bomb discovered in a vital area is classified as a Site Area Emergency.
As another
- example, IC NU1 includes as an EAL "a Security Officer found incapacitated due to violent circumstances."
This EAL should consider the location of the incapacitated security officer in determining the appropriate classification level.
Explain how the EALs under the Security Event ICs are indicative of the ICs and how they relate to the corresponding NUMARC/NESP-007 EALs.
WNP-2 IC NGI:
Securit Event Resultin in Loss of Abilit to Reach and Maintain Cold Shutdown The WNP-2 EAL under IC NGI includes the condition "Loss of physical control of both divisions of the Remote Shutdown capability due to a
security event."
Justify including "both divisions" in this EAL.
WNP-2 IC DG1:
Loss of Offsite Power The WNP-2 EAL under IC DGI includes the condition that "power to either Bus SH-7 or SH-8 is not likely to be restored within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />."
Justify the 4-hour time limit.
WNP-2 IC BAI: Inabilit to Maintain Cold Shutdown The WNP-2 EAL under IC BAI, "Inability to maintain a reactor temperature of less than 200'F per PPM 4.4.2. 1," deviates from the NUHARC/NESP-007 guidance by not including the condition of "Loss of (site -specific) technical specification required functions to maintain cold sh'utdowii" as specified in the corresponding EAL in NUMARC/NESP-007 IC SA3.
Justify this deviation.
WNP-2 IC JU1:
Loss of Annunciators The WNP-2 EAL under IC JUI includes the condition, "Compensatory nonalarming indications ARE available."
Provide information regarding what nonalarming iridications are
~
~
Zi ~
accessible to operators at WNP-2, why the nonalarming indications are not specified in the EAL, and how the user of this procedure will determine the availability of nonalarming indications.
24.
WNP-2 IC JA1:
Loss of Annunciators The WNP-2 EAL under IC JA1 includes the condition "A significant unplanned plant transient is in progress OR Compensatory nonalarming indications are NOT available."
Explain why the transient must be unplanned for this IC to be applicable.
Justify not defining the conditions which indicate a "significant transient" in the EAL scheme.
25.
WNP-2 IC JS1:
Inabilit to Monitor a Si nificant Transient in Pro ress The WNP-2 EAL under IC JS1, "Loss of all Control Room annunciators/
indications needed to monitor ANY of the following plant critical safety parameters.....
OR Loss of most or all PROCESS Radiation Monitoring System Main Control Room indications for greater than 15 minutes....."
contains indications and a logic sequence which may result in events being classified as a Site Area Emergency when not warranted.
Explain why the loss of indications specified in the WNP-2 EAL is appropriate for this IC and is indicative of a Site Area Emergency classification.
26.
WNP-2 ICs CU1 CA1 AND CS1:
Antici ated Transient Without Scram The WNP-2 EALs under ICs CUl, CAl, and CS1 deviate from the corresponding NUMARC/HESP-007 EALs under ICs (SA2 and SS2) as follows:
a.
The WNP-2 EAL for failure of the automatic scram is classified at the Unusual Event level, whereas this condition is classified at the Alert level in NESP.
As stated in the basis for NUMARC/NESP-007 IC SA2, "this condition is more than a potential degradation of a safety system in that a front line automatic protection system did not function in response to a plant transient and thus the plant safety has been compromised, and design limits of the fuel may have been exceeded.
An Alert is indicated because conditions exist. that lead to potential loss of fuel clad or the.RCS."
/
Justify this deviation.
b.
The WNP-2 EAL scheme includes an Alert level EAL for the failure of the automatic and manual scram with the condition that "operator actions WERE successful in reducing reactor power to less than 5%
AND Existing control rod pattern alone cannot always assure reactor shutdown" and also includes a Site Area Emergency level EAL for the
failure of the automatic and manual scram with the condition that "operator actions WERE NOT successful in reducing reactor power to less than 5X."
The corresponding NUHARC/NESP-007 EAL under IC SS2 does not include this power level condition and instead specifies that the scram was not successful.
The NRC has determined that it is acceptable to have an EAL classified at the Site Area Emergency level with the condition that reactor power is'less than 5X as long as the EAL also includes a condition indicating that the heat removal capability of safety systems is not exceeded:
for example, that the suppression pool temperature is not above a site-specific value.
It is not acceptable, however, to have an EAL for the failure of the automatic and manual scram classified at the Alert level.
The licensee should modify the Alert and Site Area Emergency EALs for the failure of the automatic and manual scram to conform with>>
the NUHARC/NESP-007 guidance.
The WNP-2 EAL may include a Site Area Emergency EAL with a reactor power level indication and a heat removal indication as described above.
27.
WNP-2 IC CGI:
ATWS with Challen e to Core Coolin The WNP-2 EAL under IC CGI includes the conditions, "Suppression Pool temperature cannot be maintained less than the HCTL curve OR Entry into Primary Containment
- Flooding, PPH 5. 1.7, is required," corresponding to the NUMARC/NESP-007 (IC SG2) condition of "(site-specific) indications exist that the core cooling is extremely challenged OR (site-specific) indications exist that heat removal is extremely challenged."
Explain how the conditions specified in the WNP-2 EAL correspond to the NUHARC/NESP-007 conditions.
The WNP-2 EAL under IC CGI includes the condition "operator actions WERE NOT successful in reducing reactor power to less than 5%," which is not specified in the corresponding NUMARC/NESP-007 EAL.
Justify this deviation from the NUMARC/NESP-007 guidance.