ML18017A901
| ML18017A901 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/04/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML18017A900 | List: |
| References | |
| NUDOCS 9910080081 | |
| Download: ML18017A901 (11) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20~1 SAFETY EVALUATIONBY THE OFFICE OF NUCLEAR REACTOR REGULATION ON PROPOSED CHANGES FOR CAROLINAPOWER 8 LIGHTCOMPANY.
SHEARON HARRIS NUCLEAR POWER PLANT EMERGENCY ACTION LEVELS DOCKET NO. 50-400
1.0 INTRODUCTION
This safety evaluation addresses proposed changes to the Shearon Harris Nuclear Power Plant (SHNPP) emergency action levels (EALs) submitted by Carolina Power 8 Light Company (the licensee or CP8L) in a letter dated April 1, 1999.
2.0 APPLICABLE REGULATIONS AND GUIDANCE 10 CFR 50.47(b)(4) states, in part: "Astandard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee,..."
10 CFR Part 50, Appendix E,Section IV.B states, in part: "...These emergency action levels shall be discussed and agreed on by the applicant and State and local governmental authorities and approved by the NRC..."
Appendix E, Subsection IV.C, to 10 CFR Part 50 states, in part: "...Emergency action levels (based not only on onsite and offsite radiation monitoring information but also on readings from a number of sensors that indicate a potential emergency, such as pressure in the containment and response of the Emergency Core Cooling System) for notification of offsite agencies shall be described... The emergency classes defined shall include (1) notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency..."
Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors,"
Revision 2, states, in part: "The criteria and recommendations contained in Revision 1 of NUREG-0654/FEMA-REP-1 are considered by the NRC staff to be acceptable methods for complying with the standards in 10 CFR 50.47 that must be met in on-site and off-site emergency response plans."
Section II.D of NUREG-0654/FEMA-REP-1, Rev 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," includes the following criteria for EALs:
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PDR 1.
An emergency classification and emergency action level scheme as set forth in Appendix 1 must be established by the licensee.
2.
The initiating conditions shall include the example conditions found in Appendix 1
[of NUREG-0654]...
Regulatory Guide 1.101, Revision 3, endorsed NUMARC/NESP-007, "Methodology for Development of Emergency Action Levels," as an acceptable alternative to NUREG-0654 for developing EAL schemes.
Emergency Preparedness Position No. 1, "Emergency Preparedness Position (EPPOS) on Acceptable Deviations from Appendix 1 of NUREG-0654 Based upon the Staffs Regulatory Analysis of NUMARC/NESP-007, 'Methodology for Development of Emergency Action Levels',"
dated June 6, 1995, states that licensees could utilize the technical bases under the example EALs in NUMARC/NESP-007 to enhance and clarify some of their site-specific EALs developed from NUREG-0654.
(The chosen classification scheme, whether based on Appendix 1 to NUREG-0654 or NUMARC/NESP-007, must remain internally consistent.)
3.0 BACKGROUND
In a letter dated April 1, 1999, the licensee requested NRC review and approval of proposed changes to the SHNPP EALs.. Enclosure 1 to the letter provided a comparison of the currently approved EALs and proposed Revision 99-1. Enclosure 1 also provided a summary of the 10 CFR 50.54(q) evaluation performed by the licensee including the basis for the determination that the changes do not decrease the effectiveness of the SHNPP Emergency Plan.
4.0 EVALUATION The licensee grouped the changes in Revision 99-1 into the following four categories:
A. Clarification of Terminology B. Addition of EAL Reference Numbers C. Liquid Effluent Release Assessment D. Reactivity Control Related EALAssessment
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The proposed EAL changes in these four categories were reviewed using guidance provided in Appendix 1 to NUREG-0654/FEMA-REP-1, Rev.1, and NUMARC/NESP-007, Rev. 2. In addition, the staff considered the guidance in Nuclear Energy Institute (NEI) 97-03 and NEI 99-01 for those EAL revisions which the licensee stated were based upon NEI 97-01.
(NUMARC/NESP-007 is currently being revised by the industry (NEI). NEI 97-03 updates NUMARC/NESP-007 based upon lessons-learned from industry use of NUMARC. NEI 99-01 subsumes NEI 97-03 and includes additional EAL guidance for shutdown and refueling modes of plant operations.
A draft regulatory guide which endorses NEI 99-01 is currently under development by the NRC.)
f, The criteria used for determining whether the EAL revisions are acceptable were:
(1) the classification level (e.g., Alert) of the revised EAL is appropriate.
In other words, the level of degradation of safety of the plant, as reflected in the EAL, is consistent with the classification level; and (2) the revised EAL is integrated into the existing EAL scheme.
In other words, the EAL is integrated with similar EALs to provide for logical escalation (or de-escalation) of the classification level as an event worsens (or improves).
4.1 Cate o
A-ClarificationofTerminolo Under this category the licensee proposed to:
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Update the "Site Emergency" classification title to "Site Area Emergency."
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Upgrade text of "Security Alert" and "Security Emergencies" related assessments with more descriptive and equivalent criteria; adding such criteria for civil disturbances.
(This licensee utilized guidance in NEI 97-03 in upgrading these EALs.)
Add either Main Circuit Breaker (MCB) Trip to EALs 8-1-1 and 8-1-2 to clarify that a trip using either MCB would satisfy the criteria for an Anticipated Transient Without Scram (ATWS) assessment.
Add the Technical Specification (TS) actions to clarify the Fuel Damage and Reactor Coolant System (RCS) Leakage Unusual Events (UEs) in lieu ofjust referencing the TS.
Change the UE Category Name "Inabilityto Comply with TS Shutdown Requirements" to "Other Plant or Equipment Problems."
Change "note" format of break clarification for UE Category 3 to a parenthetical phrase to be consistent with other and similar UE clarifying information.
Change the lettered elements of Initiating Conditions in UE Category 6 to bullets to be consistent with other EALs.
Provided a definition of conditions equivalent to a hurricane and reworded tornado aspect of UE Category 9.
The licensee indicated that changing "Site Emergency" to "Site Area Emergency" is consistent with Appendix E to 10 CFR Part 50,Section IV.B. The licensee indicated further that the proposed criteria remained consistent with NUREG-0654 and NUMARC/NESP-007 EAL criteria in these areas.
The licensee stated that "Hostile Strike Action" was not included as an initiating condition because SHNPP is a non-union plant in a right-to-work State.
4 The staffs review finds that the changes in these EAL revisions are editorial in nature and were made to make classification easier.
In addition, the security event-related EALs were revised to be consistent with updated guidance provided in NEI 97-03. The staffs review determined these EALs provide for classification of security events at the appropriate classification level and provide for logical escalation and de-escalation of the classification level based upon the seriousness of the security event. The staff concludes that the revised EALs are acceptable.
4.2 Cate o
B - Addition of EAL Reference Numbers The licensee proposed to replace the current grid systems with reference numbers which would be shown for each action step (rounded rectangle) associated with "EALExceeded."
The licensee stated that these EAL reference numbers aid in communication of events between facilities and are linked to an EAL reference manual provided to offsite authorities.
The licensee also proposed to add a reference to the EAL numbering scheme and an "EAL Ref. No."
designator to the EAL Status Board (upper right hand corner of both sides of the flow path).
The licensee also added an additional action step (rounded rectangle) to all General Emergency terminus items to indicate which EAL has been exceeded and added Unusual Event category numbering (1-11) which corresponds to the EAL numbering scheme.
The staffs review finds that all the change: in these EALs are editorial in nature and were made to make classification easier.
These changes are acceptable.
4.3 Cate o
C - Li uid Effluent Release Assessment The licensee proposed to add Turbine Building Drain radiation monitor, REM-1MD-3528, to EAL Table 1, "Radiation Monitor Tag Numbers," and to add Turbine Building Drain Monitor to EAL Table 5, "Effluent Monitors." The licensee stated this is an additional potential liquid effluent release point which could be involved in the inadvertent release of radioactive material.
During primary to secondary leak or tube rupture scenarios, secondary system leakage could accumulate in the turbine building drain system.
Consequently, adding a radiation monitor, specifically, REM-1MD-3528, for this path would provide indication of such a release.
The addition of this indication in the licensee's EAL scheme is consistent with the criteria in NUREG-0654 for EAL schemes to include indications for a spectrum of off-normal conditions which warrant event classification.
Therefore, the staff concludes that the addition of an EAL for this effluent release path is acceptable.
4.4 Cate o
D - Reactivit Control Related EALAssessments The licensee proposed to delete the following EALs:
ALERT "UNCONTROLLABLEBORON DILUTIONwith Plant NOT IN MODE 6 with DILUTION EVENTLASTING> 45 MIN" and
SITE AREA EMERGENCY "UNCONTROLLABLEBORON DILUTIONwith PLANTIN MODE 6 with DILUTION EVENTLASTING > 35 MIN" The licensee proposed to replace these two EALs with an EAL classified at the Unusual Event level:
UNUSUAL EVENT EAL 8-4-1 "INADVERTENTCRITICALITY-EXTENDEDAND UNPLANNED SUSTAINED POSITIVE STARTUP RATE (THIS DOES NOT INCLUDECRITICALITY EARLIER THANESTIMATEDDURING PLANNED REACTOR STARTUPS)"
The licensee stated that the Boron Dilution event classifications are not specified in either EAL scheme guidance documents. The licensee indicated that these two EALs were added to its EAL'cheme in Revision 5 to the SHNPP Emergency Plan as a specific example of "Other Events." This was done in response to:
At that time (1994 and early 1995), industry concerns and investigation into potential consequences of boron dilution events; Simulation runs and training on SHNPP procedures and EALS being performed using the Seabrook station simulator (the SHNPP simulator was not yet functional); and Incorporation of FSAR Chapter 15 on reactivity control accident analysis.
The licensee referenced Generic Letter 85-15, "Inadvertent Boron Dilution Events," (to all PWR licensees) which states:
"The staff determined that while power excursions during boron dilution events are possible ifthe operator does not take any action and sufficient volume of dilution water is available, the excursion should be self limiting. The staff analyses indicate that these types of boron dilution transients should not exceed the staffs acceptance criteria...the consequences are not severe enough to jeopardize the health and safety of the public..."
The licensee stated that SHNPP FSAR Sections 4.3.1, 9.3.4, 15.4.6 and NUREG-0800,'Standard Review Plan," Section 15.4.6, describe the Chemical and Volume Control malfunctions and specifies that the operator is provided sufficient time to correct the situation in a safe and orderly manner.
The licensee also indicates these events are classified as American Nuclear Standards Condition II incidents, fuel damage not expected to occur,'which are accommodated with, at mos".,
hutdcvn ft' reactor.
The plant would be capable of returning to operation after corrective action.
SHNPP FSAR Section 15.4.6.2, "Analyses of Effects and Consequences,"
item 2, Dilution During Refueling, indicates an uncontrolled boron dilution accident cannot occur during refueling as a result of a reactor coolant makeup system malfunction. This accident is prevented by administrative controls which isolate the RCS from the potential source of unborated water (Plant Program PLP-629, Reactivity Management Program).
In its review of this EAL revision, the staff considered guidance provided in NUREG-0654 and NEI 97-03.
NUREG-0654 did not include a specific condition for boron dilution events.
NEI 97-03 did include guidance for an "inadvertent criticality"and determined that this event is an indication of a potential degradation of the safety of the plant warranting a UE classification.
The staff agrees this event is appropriately classified at the UE level because, as discussed in Generic Letter 85-15, the event is self-limiting and the consequences would then be limited.
Therefore, the staff concludes that the revised EALs are acceptable.
5.0 STATE AND LOCALGOVERNMENTALAGREEMENT In the April 1, 1999, letter, the licensee stated that these proposed EAL changes were discussed and agreed upon by the licensee (CP8L) and State of North Carolina and local governmental authorities as required by 10 CFR 50, Appendix E, IV.B.
6.0 CONCLUSION
The proposed revised EALs are consistent with guidance provided in NUREG-0654 and NUMARC/NESP-007. Allvariations from these guidance documents were determined to be acceptable in this review. The staff concludes that the proposed revised EAL scheme meets the requirements of 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50. Therefore, the licensee can implement the proposed revision.
Principal Contributor:
E. Fox, Jr.
Date: Octobex 4, 1999
Mr. James Scarola Carolina Power 8 Light Company Shearon Harris Nuclear Power Plant Unit 1 CC:
Mr. William D. Johnson Vice President and Corporate Secretary Carolina Power 8 Light Company Post Office Box 1551 Raleigh, North Carolina 27602 Resident Inspector/Harris NPS c/o U.S. Nuclear Regulatory Commission 5421 Shearon Harris Road New Hill, North Carolina 27562-9998 Ms. Karen E. Long Assistant Attorney General State of North Carolina Post Office Box 629 Raleigh, North Carolina 27602 Public Service Commission State of South Carolina Post Office Drawer Columbia, South Carolina 29211 Mr. Mel Fry, Director Division ofRadiation Protection N.C. Department of Environment and Natural Resources 3825 Barrett Dr.
Raleigh, North Carolina 27609-7721 Mr. Terry C. Morton Manager Performance Evaluation and Regulatory Affairs CPB 7 Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602-1551 Mr. Bo Clark Plant General Manager - Harris Plant Carolina Power 8 Light Company Shearon Harris Nuclear Power Plant P.O. Box 165 New Hill, North Carolina 27562-0165 Mr. John H. O'eill, Jr.
Shaw, Pittman, Potts 8 Trowbridge 2300 N Street, NW.
Washington, DC 20037-1128 Mr. Chris L. Burton Director of Site Operations Carolina Power 8 Light Company Shearon Harris Nuclear Power Plant Post Office Box 165, MC: Zone 1
New Hill, North Carolina 27562-0165 Mr. Robert P. Gruber Executive Director Public Staff NCUC Post Office Box 29520 Raleigh, North Carolina 27626 Chairman of the North Carolina Utilities Commission Post Office Box 29510 Raleigh, North Carolina 27626-0510 Mr. Vernon Malone, Chairman Board of County Commissioners of Wake County P.
O. Box 550 Raleigh, North Carolina 27602 Mr. Richard H. Givens, Chairman Board of County Commissioners
. of Chatham County P. O. Box 87 Pittsboro, North Carolina 27312 Ms. Donna B. Alexander, Manager Regulatory Affairs Carolina Power 8 Light Company Shearon Harris Nuclear Power Plant P.O. Box 165, Mail Zone 1
New Hill, NC 27562-0165 Mr. Johnny H. Eads, Supervisor Licensing/Regulatory Programs Carolina Power 8 Light Company Shearon Harris Nuclear Power Plant P. O. Box165, Mail Zone 1 New Hill, NC 27562-0165
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