ML18100A551
| ML18100A551 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 08/12/1993 |
| From: | Hagan J Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N93138, NUDOCS 9308200041 | |
| Download: ML18100A551 (5) | |
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Public Service Electric and Gas Company Joseph J. Hagan Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200 Vice President
- Nuclear Operations AUG 12 1993 NLR-N93138 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO UNRESOLVED ITEM 50-272/93-13-01; 50-311/93-13-01; and 50-354/93-09-01~
NRC INSPECTION REPORT 50-272/93-13; 50-311/93-13; and 50-354/93~09.
DOCKET NO.. 50-272 ;. 50-311; AND 50-354 Public Service Electric and Gas (PSE&G) has received the NRC Inspection Report 50-272/93-13; 50-311/93-13; and 50-354/93-09; dated June 28, 1993.
Within the scope of this report, one unresolved item was identified regarding the NRC's understanding of the licensee's practice of not declaring and reporting terminated emergencies.
In the attachment to this letter, as requested in your report, PSE&G submits its assessment and response to the* identified unresolved item.
Should you have any questions regarding this transmittal, please do not hesitated to contact me.
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9308200041 930812 PDR ADOCK 05000272 G
PDR Sincerely,
Document Control Desk NLR-N93138 Attachment c
Mr. J. c. Stone Licensing Project Manager Mr. T. Johnson Senior Resident Inspector 2
Mr. T. Martin, Administrator Region I AUG 12 1993 Mr~ Kent Tosch, Manager IV New Jersey Department of Environmental Protection Division of Environmental Quality
- Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625
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ATTACHMENT 1 NRC STATEMENT OF CONCERN 112. NON -
DECLARATION OF TERMINATED EMERGENCIES The most significant concern about the EP program inspection was the Event Classification Guide (ECG) provisions that became apparent after the December 1992 loss of overhead annunciator system in the Salem Unit 2 control room.
During the event, operators promptly restored the system upon discovery, and the need for emergency augmentation of the on-shift staff was thereby eliminated.
An NRC Augmented Inspection Team found that plant conditions existed for an Alert declaration prior to recognition, but no emergency classification or declaration was made, nor was there timely notification of the existence of the emergency
.condition to the States of New Jersey and Delaware or to the NRC.
In this case, the prescribed emergency classification was an Alert for loss of annunciators.
Since, from a safety viewpoint, that loss of annunciators did not have the safety significance of an Alert, that specific non-declaration was not of safety importance.
In the general case, however, non declaration of terminated emergencies does not appear to meet the NRC and FEMA.
guidance contained in the "Class Description" sections of Appendix 1 to NUREG-0654/FEMA-REP-1.
The specific guidance involved is the first sentence of the Class Description for each of the four emergency levels.
That sentence specifies that the events "are in progress or have*occurred."
The licensee indicated that the non-declaration of a terminated emergency was appropriate because declaration of an Alert or higher condition requires a staff augmentation response.
NRC review noted, however, that the NRC has found prompt declaration and reporting of terminated emergencies without requiring the staff augmentation prescribed for ongoing emergencies to be acceptable.
In such a case, for example, a licensee can declare an "Alert-Terminated" (if so specified in their plan and procedures) and make the associated reports without automatic call-out of the Emergency Response Organization (ERO).
NRC review also identified the followi~g reasons for declaring terminated emergencies.
o Emergency declaration and reporting provides a timely trigger for licensee senior management, State and local, and NRC assessment of event significance, of the.appropriateness of the licensee's action, and of the need for further follow-up.
o Declaration and reporting of an emergency results in inclusion in industry and NRC records of emergency conditions, and in associated assessments of the safety import of the emergency conditions which occur at nuclear power plants.
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o Failure to declare and report emergency conditions could lead to non-identification of licensee inability to accomplish timely identification of defined emergency conditions.
In this case, the licensee revised their Emergency Classification Guide to specify one hour notification of the NRC and State when a major loss of assessment capability not exceeding an. emergency action level was determined to occur.
That does not fully address the above concerns.
Therefore, this item is unresolved pending licensee submittal of the safety justification of not declaring and reporting terminated emergencies, and further NRC review of the safety significance of declaration of terminated emergencies.
(UNR 50-272/93-13-01; 50-311/93-13-01; and 50-354/93-09-01). 11 PSE&G RESPONSE PSE&G appreciates the opportunity afforded by NRC Region I management to discuss this unresolved issue at a meeting on August 6, 1993.
This response is consistent with PSE&G 's position as discussed at the working meeting.
In response to an NRC identified programmatic concern regarding the ".. licensee's practice of not declaring and reporting terminated emergencies, the following justification is provided as requested.
PSE&G's current Event Classification Guide (ECG) contains directions on classifying emergencies which follow NUREG-0654.
Specifically, as stated in your Inspection Report, NPREG-0(554 states that an emergency should be declared for "events which are in progress or have occurred."
The introduction section of the PSE&G's ECG, in the definitions of the Emergency Classes, specifically states that an emergency be declared -for events which are in progress or have occurred.
In addition, PSE&G's ECG also stipulates that the Emergency Action Levels (EALs) are not all inclusive and do not identify every specific event or parameter which could lead to an event classification.
Therefore, if plant conditions are equivalent to one of the four emergency class descriptions in the Introduction Section III of the ECG, an emergency should be declared.
Personnel who are designated to fill the Emergency Coordinator function are annually requalified in this guidance.
Concerning the December 1992, Annunciator Event, the subject NRC inspection report states that an "Alert" was not declared because the event was quickly terminated and on-shift augmentation was not needed.
However, in this instance, the Alert was not declared because applicable EALs were not exceeded to justify the Alert declaration.
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All EP personnel designated as "Emergency Coordinator's" are trained to declare emergencies based upon EAL requirements.
Therefore, the decision to declare an "Alert" was strictly based on whether the EAL was exceeded or not.
Since the EAL for declaring an Alert for a "Loss of Annunciators", was never exceeded, (ie, fifteen (15) minutes had not passed from the time of discovery), no emergency was declared, which is consistent with PSE&G's ECG guidance, and EP training.
As stated above PSE&G procedures and EP training do not support using on-shift augmentation as a criteria for emergency declaration.
However, as identified in PSE&G's Significant Event Response Team (SERT) findings, PSE&G should have made a more timely non-emergency report.
Non-emergency action level (EAL lOD of PSE&G's ECG) required a one (1) hour notification for "Major Loss of Emergency Assessment Capability."
The need to provide better guidance was identified and this EAL has since been revised.
As a result of lessons learned, and self-assessments, PSE&G opted not to declare and terminate an emergency at the same time.
This decision, along with the associated procedural changes, was implemented to ensure that an emergency is not terminated without a thorough and proper review of the plant and emergency status, thus assuring public and plant personnel safety.
Recent NUMARC guidance provides an alternate method to the classification of after-the-fact discovery of emergencies.
PSE&G is presently considering and evaluating this guidance for incorporation and implementation into its ECG.