ML18214A423

EP SDP Comment Form, Over-Classification Improvement

ML18214A423
Person / Time
Site:	Harris
Issue date:	07/31/2018
From:	Yarley C Duke Energy Progress
To:	Raymond Gibson Policy and Oversight Branch
References
Download: ML18214A423 (1)

Text

FOCUSED SELF-ASSESSMENT:

EMERGENCY PREPAREDNESS SIGNIFICANCE DETERMINATION PROCESS STAKEHOLDER COMMENT FORM EP SDP FSA Comment Number: ____________________ (To be entered by NRC Staff)

Originator: Chuck Yarley Organization: Shearon Harris Regulatory Affairs Relevant Procedure(s): IMC 609 Appendix B, Emergency Preparedness SDP Applicable Section(s): Table 5.10-1, Entry (b)(4), Degraded RSPS FUNCTION table entry Please return to Ray Gibson at the following email: Raymond.Gibson@nrc.gov COMMENT:

In Table 5.10-1, under the entry for (b)(4), there is a Program Element for "A standard scheme of emergency classification and action levels is in use." Under the 'Degraded RSPS Function' column, there is an entry, "The EAL classification process* would result in an over classification that would lead to OROs implementing, by procedure (i.e., a non-discretionary action),

unnecessary protective actions for the public. (In making this determination, consider only those public protective actions that would be triggered by an ORO receiving notification of a particular emergency classification (e.g., when the plant reports this then do this). This condition should also be considered met if the licensee would make a PAR to the OROs because of the overclassification.)" Meeting this criteria would screen White.

Many EALs have limits based on radiation dose calculated using approved methods outlined per their E-Plan. However, industry experience has shown these numbers can vary dramatically, depending on the conditions of the plant assumed in the analysis or the method used. Variations of over one order of magnitude are possible, with both values being considered 'correct'. In all such cases, the event being considered is extreme, with some amount of significant dose being identified due to presupposed significant fission product barrier degradation.

Significant violations over the calculated doses in EAL schemes have occurred, even when the deficient EAL was derived using similar methods as other sites, or when the calculated value matches other sites. Further, these violations are for proposed events which are deep into accident progression, with many unknowns and variables that would cause real-life variation.

Further, public awareness of the situation would already be heightened, and would require significant off-site resources to properly manage. Additional harm caused by over-classifying an event with significant fuel damage would be limited.

PROPOSED RESOLUTION:

Overclassifications resulting from errors in the calculated dose of EAL schemes, for thresholds derived in the upper end of expected dosage in an extreme accident scenario, should be allowed some amount of error prior to the issue screening to White. (I.e. dose calculations errors with values above those expected to accompany more than 1% fuel damage should be allowed several factors of error prior to screening higher in significance in SDP space.)

NRC RESPONSE:

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