ML18009A412
| ML18009A412 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/23/1990 |
| From: | Richey R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18009A413 | List: |
| References | |
| HO-900056-(O), NUDOCS 9004030188 | |
| Download: ML18009A412 (15) | |
Text
ACCELERATED DISTRIBUTION DEMONSHRATION SYSTEM
~
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C REGULATORY INFORMATION DISTRIBUTION SYSTEM. (RIDS)
ACCESSION NBR:9004030188 DOC.DATE: 90/03/23 NOTARIZED: NO FACIL:50-400 Shearon Harris-Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFI'LIATION RICHEY,R.B.
Carolina Power 6 Light Co.
RECIP.NAME RECIPIENT AFFILIATION
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Document, Control Branch (Document Control Des DOCKET g
05000400 RECIPIENT ID CODE/NAME BECKER,D COPIES LTTR ENCL 1
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SUBJECT:
Forwards Rev 17 to PLP-201, "Emergency Plan" S fission I
product barrier analysis.
D DISTRIBUTION CODE:
A045D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: OR Submittal:
- Plans, Implement'g Procedures,-
C NOTES:Application for permit renewal filed.
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INTERNAL: AEOD/DOA/IRB NUDOCS-ABSTRACT EXTERNAL: LPDR NSIC 1
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PLEASE HELP US TO REDUCE WASEEl CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINA'IEYOUR NAMEFROM DISTRIBUTION LIFIS FOR DOCUMENTS YOU DON'T NEEDl TOTAL NUMBER OF COPIES REQUIRED:
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CME Carolina Power & Light Company HARRIS NUCLEAR PROJECT P.O.
Box 165 New Hill, North Carolina 27562 NAB 2 5 1990 Letter Number.'0-900056 (0)
Document Control Desk United States Nuclear Regulatory Commission Washington, D.C.
20555 NRC-706 CAROLINA POWER AND LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400 LICENSE NO. NPF-63 Gentlemen:
In accordance with
Carolina Power 6 Light Company hereby transmits one copy of the affected pages for Revision 17 to the Emergency Plan (PLP-201).
This revision to the Emergency Plan incorporates comments received during the recent licensed operator requalification training in Emergency Plan procedures.
The previous revision 16 to the Emergency Plan had a number of changes to the Emergency Action Levels which were included in this training.
With the completion of training and the incorporation of the changes in Revisions 16 and 17 of the Emergency Plan into the Plant Emergency Procedures, the changes to the Emergency Action Levels in these two Emergency Plan revisions will be implemented shortly.
The only text change to the Emergency Plan is a
rewrite of Tables 4.2-1, 4.2-2, 4.2-3, and 4.2-4 of the Emergency Plan to restate more clearly and segregate required notifications versus additional notifications.
Activations for the Unusual Event classification were clarified.
No commitments were changed.
During the course of training on the Emergency Action Levels, it was discovered in the fission product barrier evaluations (Side 1, columns A through F) that barrier status determinations could be bypassed inadvertently due to the order that the questions were presented.
In this revision, all such potential bypasses were corrected simply by rearranging the questions.
9004030188 900323 PDR ADOCK 0S000400 F
PDC MEM/H0-9000560/1/Osl
Document Control Desk Page 2
The question "SG Affected Pressure
) Safety Valve Setpoint" which followed the steam generator safety valve open question was deleted.
A new
- question, "CNMT Integrity exists per Tech.
Specs.,"
which also incorporates the old
- question, "CNMT Penetrations Isolated per Tech Specs."
has been put in front of most of the containment barrier questions.
The new
- question, includes determining the operability of steam generator safety valves and PORVs (i.e., stuck open or not).
Containment integrity would not exist per Technical Specifications if a steam generator safety valve was stuck open, so the question to evaluate whether the steam pressure was above the safety valve setpoint was superfluous.
The other change to the Emergency Action Levels.was to include "Return to Entry Point in each side's EAL Status Board blocks.
These changes meet 10CFR50.54q requirements for immediate implementation.
Revised pages to the Emergency Action Level NUREG 0654 basis document are included for reference.
Very truly yours, R. B. Richey, anager Harris Nuclear Project MGM:dgr Attachments cc'Mr. R. A. Becker (NRC)
Mr. S.
D. Ebneter (NRC-RII) (w/two copies of procedures)
Mr. J.
E. Tedrow (NRC)
MEM/HO-9000560/2/OS1
t K
FISSION PRODUCT BARRIER ANALYSIS Preface:
The philosophy applied, directed by NUREG-0654, while building the SHNPP Emergency Action Level Flowpath is that the classification of emergencies should be anticipatory to allow early notification for events that could escalate into major specific events and major releases.
A comparison of the events recommended by NUREG-0654 and the events included in the SHNPP EAL Guidelines is provided in the next attachment.
In many cases the NUREG-0654 recommendation was based upon the Actual or predicted loss of one or more of the Fission Product Barriers.
Instead of attempting to develop a group of procedures that would address the specifics recommended in NUREG-0654, SHNPP took the'pproach that the loss of a Fission Product Barrier should be analyzed.
Action should be taken based upon the number of Barriers that have been breached or are in jeopardy of being breached.
In order to accomplish this task, the plant had to determine what indications would show that any single Fission Product Barrier had been breached or potentially could be breached (is in jeopardy).
This task was accomplished and resulted in the development of the first forty-seven steps of the flowpath.
The Site Emergency Coordinator can quickly access the status of the three Fission Product Barriers by answer'ing the questions listed on the flowchart.
In this manner, if the Fission Product Barriers are breached or in jeopardy (potential for breach is present),
the event can be quickly escalated to the correct classification.
Once all of the Fission Product Barriers are examined, the flowpath is completed to determine if any other reason exists that would require the classification of an Emergency Action Level (EAL).
In using this method, we handle the major emergencies, followed by other types of emergencies which could become major emergencies.
The average SRO licensed individual is expected to take approximately five minutes to go through the entire flowpath and determine that an Emergency Classification is, or is not, warranted.
In the case of an Unusual Event, Alert, or Site Emergency condition, the time delay is acceptable.
If conditions are quickly deteriorating, a faster method of classification is needed.
EAL/NUREG-0654 Page 3 of 93
Preface:
(continued)
Because of this, the Site Emergency Coordinator is directed on the flowpath to declare a General Emergency as soon as it is determined to exist. If conditions warrant this declaration, notification should begin IMMEDIATELY! The required notifications due to a Site Emergency, Alert, or an Unusual Event are reduced sufficiently that it is worth the time necessary to finish the flowpath, to find out if a higher level classification exists, prior to the declaration of the event.
The flowpath is designed to look at the worst case event first, then the other events in descending order of importance.
Some consideration was given to the layout of the path, so some of the potential events were moved to make the path flow better.
The EAL flowpath follows the same rules and conventions that the EOP (Emergency Operating Procedure) flowpath's follow.
This is an aid to the user in that he does not have to learn two conventions, just follow the one on which he has been trained.
In addition, items previously covered by attachments to the PEP-101 are now directly on the flowpath.
This eases the use of the flowpath and ensures that the entire spectrum is covered every time the flowpath is entered.
General:
Each of the Barriers is analyzed to determine if it is breached or in jeopardy.
The first indication of either event results in declaring the specific barrier to be either bieached or jeopardized.
From an EAL declaration standpoint, it does not matter whether the barrier is breached or in j eopardy.
- However, it is important to the actions executed by other plant documents; therefore, the breach indicators are examined before the, jeopardy indicators.
When any single indicator shows any barrier to be breached or jeopardized,
.the FPB Status Board is marked to show the indication, and the rest of the indications are bypassed.
If there is proof that a barrier is breached, there is no need to continue to examine that barrier.
EAL/NUREG-0654 Page 4 of 93
General:
(continued)
The EOP Network has many indications that would prove one or more of the Fission Product Barriers to be breached.
The plant staff has analyzed the EOP Network in an effort to determine those points at which any one (or more) of the barriers indicates a
breach.
These points are identified in the EAL flowpath as entry points T, U, and V. If the Fuel indicates
- breached, in the EOP Network, the EOP Network orders the operators to enter the EAL flowpath at ENTRY POINT T.
The same process is used for entry points U (RCS breached) and V (Containment breached).
These entry points serve two purposes:
first, they force a
reentry into the EAL flowpath in case the Emergency Action Level should be upgraded; and second, since the entry point, as determined by the EOP's, has already determined that one of the Fission Product Barriers -is breached, it reduces the time necessary to arrive at the correct Emergency Classification.
This aid is used throughout the Fission Product Barrier Analysis.
FISSION PRODUCT BARRIER STATUS Fuel Fission Product Barrier'.
Flowpath Coordinates A-2 through A-6 A-2 ANY RAD MONITOR EAL TABLE 6 IN ALARM?
EXPLANATION:
If none of the Rad monitors are in alarm, Coordinates A-3 through A-5 can be bypassed which speeds up the time to go through the flowpath.
The next valid question would be at Coordinate A-5.
A-2 PLANT VENT STACK 81 WIDE RANGE GAS MON EFFL CHNL
>3.6 E5 uCi/sec?
EXPLANATION:
The stack effluent monitor would exceed this level if the Containment airborne concentration of radioactivity was due to a 50 gpm RCS leak with an RCS activity of 300 uCi/cc (I-131).
This includes the dilution effects that are predicted to occur during the release through the Plant Vent Stack release path.
This is an indication that all 3 FPBs are breached.
EAL/NUREG-0654 Page 5 of 93
A-4 EITHER CNMT HI RANGE ACCIDENT MON >17.5 R/HR?
EXPLANATION:
The CNMT monitors would not indicate this level of radiation unless a fuel breach and an RCS breach had occurred.
This radiation level is based upon 300 uCi/cc RCS activity (I-131) (Alert level) and 40 gpm leakage from the RCS to Containment in addition to the 10 gpm allowable by Technical Specifications.
A-4 ANY EAL TABLE 2 MONITOR >1000 TIMES NORMAL?
EXPLANATION This value was taken directly from the NUREG-0654 recommendations.
A-4 WAS ENTRY POINT AT T?
EXPLANATION:
If the entry point was at T, the Fuel Fission Product Barrier is indicating breached, based upon the EOP Network determination.
A-5 GFFD INCREASED >1 E
CPM IN 30 MINUTES?
fr<
EXPLANATION:
This item complies with the NUREG-0654 recommendation for Alert level declaration.
An increase of this magnitude indicates that the Fuel FPB is breached.
The set point is below the NUREG-0654 "Alert" classification which is based on 1X failed fuel in 30 minutes or 5X failed fuel.
Only two set points were provided by Westinghouse on the Gross Failed Fuel Detector (the lower set point was used for the Unusual Event Declaration).
A-5 RCS ACTIVITY (I-131 DOSE EQUIVALENT) >300 uCi/cc?
EXPLANATION The value of 300 uCi/cc (I-131) was taken directly from NUREG-0654.
EAL/NUREG"0654 Page 6 of 93
A-6 CORE COOLING CSF RED?
EXPLANATION A Red CSF-2 would be due to either core temperatures above 1200'F or core temperatures above 730'F and RVLIS less than 39%.
In either case, the fuel is in jeopardy.
REACTOR COOLANT SYSTEM FISSION PRODUCT BARRIER Flowpath Coordinates A-7 through A-10:
A-7 ANY RAD MON IN EAL TABLE 6 IN ALARM?
EXPLANATION If none of the Radiation Monitors is in alarm, the section of the RCS Barrier that asks if the Radiation Monitors have exceeded a specific level is bypassed.
This reduces the time needed to go through the path, and is appropriate because all of the Radiation Monitors questioned have alarm points at or below the level used to determine the RCS breached.
A-7 PLANT $
ENT STACK gl WIDE RANGE GAS MON EFFL CHNL
>9.4 E
uCi/sec.
EXPLANATION This level of activity would indicate that a release from the Containment was occurring (CNMT FPB breached) concurrent with an RCS breach.
This level would occur if the RCS was breached with Technical Specifications allowable activity levels in the system and the activity released was fully diluted by the Containment atmosphere and the plant vent stack.
Note that this level is substantially below the level required for this monitor to indicate fuel breach; an indication of only an RCS and Containment breach.
A-8 CNMT LEAK DET RAD MON NOBLE GAS CHNL >8.0 E
uCi/cc?
EXPLANATION With normal activity in the RCS, if the Containment Leak Detection Radiation Monitor noble gas channel increases to greater than 8.0 E
uCi/cc, the RCS is leaking at a
rate greater than 40 gpm in addition to the Tech.
Spec.
limit of 10 gpm.
EAL/NUREG-0654 Page 7 of 93
A-9 EOP PATH-2 ENTERED?
EXPLANATION This is an indication of an SG tube rupture with safety injection.
The RCS is breached with an initial leak rate of >120 gpm.
B-9 ANY MAIN STEAMLINE RAD MON >20 mR/HR?
EXPLANATION:
The limit of 20 mR/HR is based upon having 300 uCi/cc RCS activity (I-131) leaking at 40 gpm into a Steam Generator.
This does not include the 10 gpm of leakage from the RCS to the Containment Atmosphere.
If EOP PATH 2 has been entered, the SG radiation monitor levels are an indication that both the fuel and the RCS barriers are breached.
A-9 WAS ENTRY AT POINT U?
EXPLANATION If the entry point, into the EAL Network, was at entry point U, then the EOP Network has already determined that the RCS boundary is either breached or in jeopardy.
The determination is made and time 'is saved in going through the EAL Network.
A-10 RCS LEAKAGE >50 GPM?
EXPLANATION This is an indication of an RCS breach, regardless of the activity level in the system.
This was taken directly from NUREG-0654.
A-10 INTEGRITY CSF MAGENTA OR RED?
EXPLANATION If the Integrity does not indicate green or yellow, the RCS FPB is in jeopardy.
This ensures that a pressurized thermal shock event will be classified at least as an Alert.
EAL/NUREG-0654 Page 8 of 93
CONTAINMENT FISSION PRODUCT BARRIER A-11 ENTRY AT POINT V?
EXPLANATION If the EOP Network has ready determined that the CNMT FPB has been breached, we do not need to ask Questions related to the CNMT barrier.
We declare the breach and bypass the steps.
D-2 CNMT INTEGRITY EXISTS PER TECH.
EXPLANATION If all Containment penetrations are isolable, then related steps can be bypassed.
This is because the related questions further confirm that an event is in progress where the Containment barrier is needed.
D-2 ALL SG SAFETY VALVES SHUT?
EXPLANATION An open Steam Generator Safety Valve is one indication of a Main Steam break outside of Containment (Containment breach).
If they are all shut, we can bypass E-2, which looks for a stuck'pen safety.
If the answer is NO, we have to determine if the safety valve should be open, or is stuck.
EXPLANATION This is normally the case, following a Reactor Trip.
The PORV's may open momentarily, but quickly close as the energy is dissipated.
By the time that the Shift Foreman gets to this point in the flowchart, all of the PORV's should be closed and this step can be bypassed.
If one (or more) is open, then he must determine if it is stuck open.'his is done by reviewing the next two steps.
EAL/NUREG-0654 Page 9 of 93
E-3 ANY MAIN STEAM PORV STUCK OPEN?
EXPLANATION If the PORV's are working correctly, the answer is NO and the rest of the indications of the Containment Barrier are examined.
If the answer is YES, the next question is asked.
E-3 BLOCK VALVE FOR STUCK OPEN PORV CAN BE SHUT?
EXPLANATION If the stuck PORV block valve can be shut, the Containment is not breached, and the path should be continued.
If the block valve cannot be shut and the PORV is stuck open, the Containment FPB is breached.
This is indicated on the FPB status board and the number of lost barriers is queried.
F-4 PRIMARY TO SECONDARY LEAKAGE TO'FFECTED SG TECH.
EXPLANATION The Containment is not considered breached by stuck open SG safeties or PORVs unless there is a release pathway caused by primary to secondary leakage in the affected SG.
This is in accordance with NUREG-0654.
D-4 CNMT PHASE A ISOLATION ACTUATED?
EXPLANATION If a Phase A Isolation has been received and any of the Containment penetrations are not isolable (per T.S.),
then the Containment FPB may be breached when needed during an event and is so,indicated on the FPB status board.
D-5 CNMT VENT ISOL ACTUATION?
EXPLANATION If a Containment Ventilation Isolation Actuation has
- occurred, the Containment FPB may be breached because radiation levels have increased inside Containment.
The unisolable penetration MAY permit a release.
EAL/NUREG-0654 Page 10 of 93
D-5 FUEL AND RCS INTACT ON FPB STATUS BOARD?
EXPLANATION If either the Fuel or RCS Fission Product Barriers is in jeopardy or breached and one or more Containment penetrations is not isolable, then the Containment may be breached in an event when it is needed to protect the public.
E-5 PATHWAY FOR FISSION PRODUCTS TO ESCAPE CNMT EXISTS' EXPLANATION This question prevents escalating on the basis of an isolation failure in a closed system or a failure of one of two redundant isolation valves.
D-6 UNISOLABLE STEAM AND/OR FEED BREAK OUTSIDE CNMT?
EXPLANATION A unisolable steam and/or feed break outside of the containment is a breach of the containment FPB if a release pathway via primary to secondary leakage exists.
D-7 PRIMARY TO SECONDARY LEAKAGE TO AFFECTED SGs EXCEEDS 10 GPM?
EXPLANATION The Containment is not considered breached due to an unisolable secondary break unless primary to secondary leakage in the affected Steam Generator exceeds.
NUREG-0654 limits.
D-7 SG PRESS
>1230 PSIG?
EXPLANATION If SG pressure is below 1230
Following a Reactor trip, the SG pressure rapidly increases but remains below 1100 PSIG. If it increases above this, the PORV's and Safeties lift to restore the pressure.
If the pressure cannot be maintained below 1230 PSIG, an SG tube rupture has occurred.
The RCS will already be considered breached because EOP PATH-2 will be entered.
If the SG cannot be controlled to prevent filling up, the PORV and safeties are about to lift, and Containment is in jeopardy.
EAL/NUREG-0654 Page 11 of 93
E-8 SG LEVEL >82.4Z?
EXPLANATION If SG pressure is greater than 1230 PSIG and the affected Steam Generator does not have a tube rupture, then the SG level will be less than 82.4X.
This is a
final check to see if the SG has ruptured or the operator is just trying to control Tavg.
D-8 CNMT CSF MAGENTA OR RED EXPLANATION If the Containment CSF is not Yellow or Green, the Containment is in jeopardy of being breached.
EXAMPLE INITIATINGCONDITIONS NOTIFICATIONS OF UNUSUAL EVENT Unusual Events are declared when conditions warrant and a higher level declaration is not needed.
Once the flowpath is completed, if a declaration of an Alert, Site Emergency, or General Emergency is not needed, the Site Emergency Coordinator is directed to evaluate against the Unusual Event Matrix.
This Matrix is located at the bottom of the flowpath.
If a higher level classification is in effect, the Unusual Event Matrix is not examined in order to expedite initiation of the actions required by the higher level declaration.
NOUE = Notification of Unusual Event as defined in NUREG-0654.
EAL/NUREG-0654 Page 12 of 93