ML20012B226

Emergency Preparedness Insp Repts 50-317/90-04 & 50-318/90-04 on 900122-25.No Violations Noted.Major Areas Inspected:Emergency Action Levels,Changes to Emergency Preparedness Program & Independent Reviews/Audits

ML20012B226
Person / Time
Site:	Calvert Cliffs
Issue date:	02/20/1990
From:	Conklin C, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20012B225	List: ML20012B224 ML20012B226
References
50-317-90-04, 50-317-90-4, 50-318-90-04, 50-318-90-4, NUDOCS 9003140007
Download: ML20012B226 (18)

See also: IR 05000317/1990004

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

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Report Nos: 50-317/90-04

50-318/90-04

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Docket Nos: 50-317

50-318

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License Nos: DPR 53

DPR 69

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Licensee:

Baltimore Gas and Electric Company

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Calvert Cliffs Nuclear Power Pinnt

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MD Rts 2 & 4. P.O. Box 1535

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Lusby. Maryland 20657

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Facility Name:

Calvert Cliffs Nuclear Power Plant. Units 1 and 2

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Inspection At:

Lusbv. Maryland

-Inspection Conducted:

January 22 25. 1990

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inspector:

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Craig C()nklin,' Senior Emergency

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Prepa(dness Specialist, Division of

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Radiation Safety and Safeguards (DRSS)

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Approved By:

N[da -- Aa/<

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7dd[9o

William Lazardif(ChiejEmergency

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. Preparedness Section, DRSS

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inspection Summary: Jnspection on January 22-25. I'990 (Combined Inspection Reoort

Nos 50-317/90-04 and 50 318/90-04)

Areas Inspected: A special, announced >:mergency preparedness inspection was

conducted at the Calvert Cliffs Nuclear Power Plant. The inspection areas included:

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Emergency Action Levels; Changes to the Emergency Preparedness Program;

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Independent Reviews / Audits; and Licensee Actions on Previously Identified Findings.

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Results: No violations were identified. The licensee's approved Emergency

Classification Systr.n does not provide Emergency Action Levels consistent with the

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guidance of NUREG-0654.

9003140007 900220

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DETAll3

1.0

Persons Contacted

The following licensee representatives attended the exit meeting held on January

25, 1990.

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G. Creel, Vice President Nuclear Energy

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R. Denton, Manager, Quality Assurance and Services Department

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T. Forgette, Supervisor, Emergency Planning Unit

N. Millis, General Supenisor, Radiation Safety

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. J. Carlson, Supervisor, Technical Training

J. Osborne, Licensing Engineer

L Smialek, Senior Plant Health Physicist

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S. Cowne, Senior Engineer, Quality Assurance

F. Kramme, Emergency Planning Analyst

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The inspector also interviewed and observed the activities of other licensee

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personnel.

2.0

Licensee Actions on Previously Identified items

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CLOSED (UNR) (50-317/88-04 01 and 50-318/88-05 01). Some Emergency

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Action Levels (EALs) do not conform to the guidance of NUREG 0654, while

others were inappropriate for the levels of intended response.

This item is administratively closed. Refer to section 3.6 for details.

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OPEN (VIO) (50-317/89-16-01 and 50-318/89-17 01). The Control Room does

not have the capability to perform dose assessment based upon a steam

generator tube rupture.

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The licensee contracted with a consultant to develop a methodology for dose

assessment based upon a steam generator tube rupture. The first draft was

reviewed by Radiological Safety, Operations, Chemistry and, Emergency

Preparedness. The final draft was reviewed by Nuclear Engineering. This

methodology has been incorporated into Emergency Response Plan

implementing Procedure (ERPIP) 3.0, immediate Actions. This ERPIP is

scheduled for approval by 2/14/90 and for full implementation by 2/21/90. The

inspector indicated that it would be appropriate to evaluate this methodology

against other methodologies currently in use to identify differences prior to

implementation. The licensee agreed that methodology correlation and

validation are necessary. This area will be reviewed in a subsequent inspection.

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CI OSED (UNR) (50 317/891602 and 50-318/89-17-02). The licensee will

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review past audits for disputed findings.

The Ouality Assurance group reviewed the Request for Managers Corrective

Action Reports (RMCAR) issued for 1988 and 1989 with emphasis on areas of

dispute resolved by the Manager, Quality Assurance and Site Services (OASS).

RMCAR 88-26-03, Conduct of Random Assembly Drills, was identified and

forwarded to the Vice President Nuclear Energy (VPNE) for review. This issue

was deemed satisfactory and no additional action was taken. Additionally, QAP.

21, Attachment C of the Quality Assurance Manual has been revised to ensure

the VPNE resolves all disputed findings pertaining to QASS units. Based upon

the above review, this area is acceptable.

3.0

Operational Status of the Emergency Preparedness Program

3.1

Chances to the Emergency Prenaredness Program

Several changes were noted in the Emergency Response Plan (ERP) and

Emergency Response Plan Implementing Procedures (ERPIP) since the

last. Inspection. The changes that have been made have received, or are

in the process of receiving, proper management and Plant Operational

Safety Review Committee (POSRC) review prior to implementation.

ERPIP 4.1.2, Site Emergency Coordinator, has been revised to ensure the

Shift Supervisor utilizes Attachment 1, which properly considers release

and non release accident sequences, prior to determining a Protective

Action Recommendation. This ERPIP change is scheduled for approval

and implementation by 2/15/90. This area will be reviewed in a

subsequent inspection.

ERPIP B.1, Equipment Checklist, Revision 15, has been revised to require

a review / approval of all completed checklists by the Supervisor,

Emergency Planning Unit.

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10 CFR 50.54(q) requires a liansee to follow and maintain the emergency

plan in accordance with 10 CFR 50.47(b) and Appendix E. Changes may

be made provided the changes do not decrease the effectiveness of the

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emergency plan. In response to NRC questions regarding the 10 CFR 50.54(q) evaluation process, the licensee recognized the lack of a formal

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evaluation program, and prior to this inspection developed a formal

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50.54(q) evaluation process. This process, contained in Standard

Operating Procedure 5, is scheduled for implementation on 2/1/90 and

appears to meet the intent of the 50.54(q) evaluation process.

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Based upon the almve review, this area is acceptable.

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3.2

Emergency Facilities. Eculpment. Instrumentation and Supplies

The inspector reviewed the licensee's efforts to restore to service the two

trailers used to perform backup Post Accident Sampling System analysis

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and counting. The analysis trailer is essentially operational. A new Gas

Chromatograph (GC) is being procured for the chemistry laboratory (the

existing GC will be placed in the trailer) and demineralized water lines

need to be repaired. In the counting trailer, the ND 66 sample analysis

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system is installed, but is experiencing detector problems which are being

addressed. The trailers are scheduled to be in full service by 5/1/90. All

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surveillances will be reinstituted prior to that date. Chemistry has also

agreed to utilize the trailers during periodic training. This area will be

reviewed for implementation in a subsequent inspection.

Based upon the above review, this area is acceptable.

3.3

Organization and Management Control

ERPIP A.1, Emergency Organization Personnel, Revision 38, has added

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the additional position of Radiological Assessment Director (both directing

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and assessing). Two individuals were selected to fill these positions but

not yet trained. One individual has subsequently left the company and

the licensee has yet to identify a replacement.

The licensee agreed to

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expedite the selection and training for these personnel.

Based upon the above review, this area is acceptable.

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3.4

Knowledge and Performance of Duties (Training)

The Techn. cal Training Unit (TTU) is developing lesson plans for both

overview emergency response training and specialty training. Several

lesson plans are completed and all are scheduled for completion by

6/1/90.

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The inspector noted that all members of the Emergency Response

Organization (ERO) were retrained in 1989 to reestablish qualifications

and/or to maintain the ERO current.

Based upon the above review, this area is acceptable.

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3.5

ladenendent Reviews / Audits

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The audit to meet 10 CFR 50.54(t) requirements was conducted from July

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21 to August 28,1989. The audit was performed by a team consisting of

two members of the Quality Assurance (QA) unit and a consultant

experienced in emergency preparedness. The checklist utilized was

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detailed and thorough. The OA team identified valid issues and these

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issues were properly categorized. The audit also adequately addressed

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offsite interfaces and the report was distributed to the applicable offsite

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agencies. The inspector noted that several areas that were identified in

the 1988 audit (for example: use of the backup Operations Support

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Center; Public Information Brochure format; training content and lesson

plan issues; and drill / exercise observer issues) were also identified in the

1989 audit. Additionally, the 1988 audit identified past issues with offsite

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notification, and a problem was subsequently identified in the 1989

exercise. Although these areas have been addressed by the licensee for

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corrective action, these actions appear to be ineffective as the problems

have recurred. This indicates a lack of effective root cause analysis

and/or ineffective corrective actions. This item is Unresolved (UNR) (50-

317/90-04 01 and 50-318/90-04-01)

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Except as noted above, this area was acceptable.

3.6

Emergency Action Levels

A reactive inspection, conducted to review the licensee actions in response

to an Alert (Report Nos. 50-317/88-04 and 50 318/88-05), identified that

some Emergency Action Levels (EALs) were not in conformance with

NUREG-0654. A routine emergency preparedness inspection (Report

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Nos. 50-317/8916 and 50-318/89-17) indicated that some minor EAL

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revisions had been made, but the EALs still were not in conformance with

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NUREG 0654. The licensee's EALs were subsequently reviewed by an

NRC contractor. This review identified numerous problems with the

EALs including omission of initiating events and areas where additional

clarification is necessary (see specific details below). As a result of the

contractors findings, the inspector conducted a detailed review of the

licensee's EAL formulation and revision history. In 1981, the NRC

conducted an Emergency Preparedness Implementation Appraisal (EPIA)

(Report Nos. 50 317/81-19 and 50 318/8118) that identified many areas of

concern with the EALs, as well as numerous EALs that were contained in

NUREG 0654 but not addressed by the licensee's EAL scheme. The

EALs were found inadequate. In a subsequent 1982 letter, the licensee

detailed the actions they would take to correct the deficiencies identified

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m the EPIA, however, they took exception to the majority of the NRC

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findings. The inspector noted during this inspection that the corrections

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to the EALs proposed by their 1982 letter were subsequently made.

Although there is no record of an NRC response to the licensee's 1982

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letter, the Office of Nuclear Reactor Regulation, in a letter dated May 11,

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1983, indicated that the licensee's onsite emergency preparedness was

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adequate and met the intent of NUREG-0737 Item III.A.2.1. This letter

also indicated that NRC Region I was verifying corrective actions

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regarding previous inspection findings. There is no indication that

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subsequent NRC inspections followed up on the EPIA findings. The

NRC has concluded the licensee's Emergency Plan (and thus the EALs)

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was approved by the issuance of the May 11,1983 letter. It is also clear

that the emergency classification system EALs did not conform to the

guidance in effect at the time and there was no resolution of the

identified inadequacies. We now conclude that the NRC erred in 1983 in

approving the licensee's EALs. The inspector discussed the specific EAL

inadequacies with the licensee, and the licensee agreed to evaluate and

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upgrade their EALs to conform to NUREG 0654. Additionally, the

licensee committed to keep the NRC apprised of progress and schedular

problems and to inform the NRC in writing when this task is complete.

This item is Unresolved (UNR)(50-317/90-04-02 and 50-318/90-04 02).

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Specific details of the EAL review are as follows,

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GENERAL COMMENTS

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The format of the Calvert Cliffs EAL Criteria was a two page document

that listed ten categories of accidents, such as Radioactivity Release,

Security, Fire, and Weather on the vertical side of the sheet. Two

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adjacent columns opposite the categories listed the specific EALs for each

of the categories. The first page included EALs for General Emergency

and Site [ Area] Emergency and the second page for Alert and Unusual

Event. The listed EALs were based on plant conditions or events in each

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of the categories that when observed, caused the user to proceed to page

17 to continue the classification process. Although fission product barrier

degradation was listed as a category, symptomatic indicators such as idJh

containment dose rates or airborne activities were not listed as EALs.

The EALs did incorporate reference to Abnormal Operating Procedures

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(AOPs) or Emergency Operating Procedures (EOPs) being implemented.

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EVALUATION

Evaluation of the licensee's EAL classification scheme was based on

NUREG-0654 and 10 CFR 50 as follows:

NUREG-0654 Planning Standard Section D. Emergency

Classification System. A standard emergency classification and

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action level scheme, the basis of which includes facility system

effluent parameters, is in use by the nuclear facility licensee, and

State and local response plans call for reliance on information

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provided by facility licensees for determination of minimal initial

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offsite response measures.

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Criteria

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1.

An Emergency Classification t.nd Emergency Action Level

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scheme, as set forth in Appendix 1, must be established by

the licensee. The specific instruments, parameters, or

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equipment status shall be shown for establishing each

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emergency class in the in plant procedures. The plan shall

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identify the parameter values and equipment status for each

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emergency class.

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The initiating conditions shall include the example conditions

found in Appendix 1 and all postulated accidents in the

Final Safety Analysis Report (FSAR) for the nuclear facility.

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Additionally, the regulatory requirements of 10 CFR 50.47,

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and Appendix E.IV.B. and E.IV.C. were considered in the

evaluation.

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SYNOPSIS OF REVIEW

An emergency classification and emergency action level scheme, consistent

with the intent of NUREG-0654, Appendix 1, and with the requirements

of 10 CFR 50, has been established by the licensee in their Emergency

Response Plan Implementing Procedure, ERPIP 3.0, Immediate Actions,

Revision 13. However, several differences between ERPIP 3.0 and

NUREG 0654 were noted h1 conducting this review that require

modification. Several suggestions of areas for improvement were also

noted. It did not appear that each accident of the licensee's FSAR had

been considered in formulating the EAL scheme.

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SPECIFIC EAL REVIEW COMMENTS

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The following comments are provided in the order of the Example

Initiating Conditions of Appendix 1, NUREG 0654, with the number and

a short descriptive phrase from NUREG-0654 provided first. Absence of

any comment indicates that the EAL was acceptable.

NOTIFICATION OF UNUSUAL EVENT (NOUE)

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1.

NOUE #1, Emergency Core Cooling System (ECCS) hitiated and

discharged to vessel.

This EAL was not addressed by the Calvert Cliffs scheme except

indirectly if EOP 4, EOP 5, or EOP 6 were implemented. Should

an inadvertent ECCS initiation occur, the entry conditions would

not be achieved, thus a declaration would not be made. The

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licensee should add this Example Initiating Condition to assure an

Unusual Event (UE) is declared for any ECCS initiation except

authorized testing.

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NOUE #3.c., Failed fuel monitor indications.

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No EAL has been prepared equivalent to the example condition.

The basis document stated that the instrument .... by itself does not

provide sufficient information to determine equivalent fuel failure.

There are other symptomatic indicators that do provide supporting

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information to the failed fuel monitor, including, for example,

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containment continuous air monitors (show elevated values due to

normally leaking coolant) and containment radiation monitors.

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Coolant sampling can easily take an hour to obtain results

necessary to determine if fuel failures have occurred. This delay in

emergency declaration is not consistent with the anticipatory intent

of NUREG 0654. The licensee should identify supporting,

symptomatic indicators that will permit the use of the failed fuel

detector to make classifications, without the need for sampling.

This does not preclude the need to identify failed fuel by sampling.

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NOUE #4, Abnormal temperatures, pressures.

NOUE #f, Excessive leak rates.

NOUE #7, Imss of AC power capability.

NOUE #8, Loss of containment integrity.

NOUE #9, Loss of engineered safety feature.

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Each of the above example initiating conditions was addressed by

the licensee's EAL in the category General Safety that stated,

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" Mode change required by Tech. Spec. 3.0.3 for not meeting

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Limiting Condition for Operation (LCO)." The licensee should

assure that the interpretation of the EAL is such that any time an

unplanned shutdown is initiated in accordance with an LCO or to

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avoid entering an LCO, an Unusual Event will be declared at the

time the decision is made by plant management to change modes.

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NOUE #9, Loss of fire protection system function.

The licensee's EAL scheme did not address the subject of loss of

fire protection systems. A review of the basis document indicated

that loss of fire protection systems would not necessitate a

shutdown by either Unit's Technical Specifications.

Notwithstanding Technical Specification requirements, plant

management would consider shutdown on extensive loss of fire

protection systems if adequate compensatory measures could not be

established. Such a shutdown should warrant a declaration of an

NOUE since a potential degradation of the level of safety of the

plant has obviously occurred. The licensee should consider the

omission of loss of fire protection functions from this perspective,

and determine if it is still appropriate not to include such an EAL.

5.

NOUE #11, Significant loss of assessment or communication

capability.

This example initiating condition was not addressed by the

licensee's EAL scheme, and the basis document stated that such

loss .... does not represent conditions sufficient for UE description.

The basis document went on to state that backup methods were

available to obtain meteorological data. As to the first condition of

significant loss of assessment capability, the intent of the NUREG

condition was to describe a significant loss, i.e., with no backup.

The loss of all meteorological source data should be considered a

significant loss, and worthy of notification to offsite authorities. As

to the second condition of significant loss of communication

capability, the loss of all in plant communications would be very

significant, and adversely affect the safety of the plant's operations.

Additionally, the loss of all (or nearly all) offsite communication

links would also be very significant, especially when followed by a

coincident accident. Therefore, the licensee should add this

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example condition to assure that an EAL addresses the subject

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NOUE #13, Natural phenomena being experienced beyond usual

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IcVels - n. carthquake, b. water, c. tornado, d. burricane.

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The above example conditions were not addressed by the licensee's

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scheme. The basis document stated that ... No useful purpose is

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served for NOUE declaration for the phenomena itself. Offsite

agencies would be aware of these phenomena by day-to-day

operations, etc. Since weather phenomena are frequently localized

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conditions, it was not necessarily a valid point that offsite agencies

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would be aware of such occurrences by day to-day operations.

Earthquake monitoring instrumentation installed at the plant is

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likely more sensitive than any available within reasonable distance

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of the plant. Adverse natural phenomena may be precursors to

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more serious conditions at the plant. Therefore, in keeping with the

carly alerting, anticipatory intent of NUREG 0654, the licensee

should include the example conditions in their EAL scheme.

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NOUE #14 a., Other hazards, aircraft crash on site or unusual

aircraft activity over the facility.

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This example condition was not addressed by the licensee's scheme.

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The basis dacument stated that ... Offsite authorities will be

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notified of the condition when fire fighting and/or rescue assistance

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is needed or as a newsworthy event in accordance with CCI 118,

Calvert Cliffs Reporting Requirements.... There is a logical

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relationship between an aircraft crash onsite or unusual activity

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over the facility and degradation of safety to the plant. Also

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fundamental to the early reporting requirements placed on

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licensees by NUREG 0654 is the concept of accurate awareness

and knowledge by offsite agencies of adverse conditions at the

plant that may affect its safety. The licensee should include this

example initiating condition in its EAL set.

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NOUE #16, Transportation of contaminated, injured individual.

This example condition was not addressed by the licensee's EAL

set. The basis document stated that ... Off site authorities will be

notified of this event when rescue squad services are called for

and/or as a newsworthy event in accordance with CCI 118, Calvert

Cliffs Reporting Requirements.... At the present time, the

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governing guidance concerning this event is NUREG-0654 which

clearly states that a NOUE will be declared if a contaminated,

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injured individual requires transport to an offsite hospital for

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treatment. Across the industry, all classification schemes implement

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this example cor.dition in this manner. Therefore, the licensee

should modify their EAL scheme to be consistent with currently

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applicable guidance and the balance of the industry.

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ALERT

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Alert #1.c., Failed fuel monitor indicates failed fuel.

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This example initiating condition was not addressed by the

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licensee's EAL scheme. As discussed in Comment #2. above, the

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basis document stated that ... The failed fuel monitor by itself does

not provide sufficient information to determine fuel failure, it was

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not the intent of NUREG 0654 to limit observation only to the

failed fuel monitor. If supporting instrumentation is required to

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validate the readings obtained on the failed fuel monitor, the

licensee should include all the instrument readings that are

symptomatic of failed fuel, thus obviating the necessity to wait for

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sample analysis results. As discussed above, other process and

radiation monitors may be available that could give clear indication

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of failed fuel. For example, if greater than 50 R/ hour (or whatever

the computed value is) were observed on the containment high

range radiation monitor, the only possible source for that

magnitude of reading would be failed fuel. The licensee should

identify and list all instrument parameters that may be used to

validate and quantify evidence of failed fuel, and utilize those

readings as a complete EAL set for the condition.

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Alert #6, Radiation levels or airborne contamination which indicate

a severe degradation in the control of radioactive materials (e.g.,

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increase X1000 in direct radiation readings).

Alert #15, Radiological effluent >10 times Tech Spec

instantaneous limits.

As stated in the basis document, the licensee's EALs addressed this

example condition with effluent monitor readings and

actual / potential doses as follows:

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Any valid RMS readings 2 listed for 215 minutes and expected to

last 21 hour2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br />.

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NUMBER

U1/2 WRNGM

1/2-RIC-5415

4.7 E6 uCi/sec

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Other plant conditions with actual / potential DOSES 2100 mrem

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Whole Body 2 500 mrem thyroid (Excluding controlled area).

The first group of EALs (effluent monitors) inappropriately -

included the time modifiers of continuing for 15 minutes and

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expected to last for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Reference to Alert Example Initiating

Condition #15 showed no such time modifiers, simply stating ...

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Radiological effluent greater than 10 times technical specification

-instantaneous limits ..... Allowing a release to occur for 15 minutes,

and requiring the release to be expected to continue for one hour,

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before making an Alert declaration is not consistent with the

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anticipatory intent of NUREG-0654. The licensee should modify.

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this EAL concerning the times.

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As to the second set of EALs that appear to directly address the

subject example condition, the value of the EAL is adequate.

However, the modifier, " excluding the controlled area", raised

concerns. As discussed above concerning fuel failures, there are

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several possible symptomatic indicators of degradation of control of

radioactive materials. For example, if the area dose rate in the

coolant charging pump cubicle increased by a factor of 1000, the-

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loss of control of radioactive materials has degraded to the point of

warranting an Alert declaration. The increase in the charging

pump room is a precursor to a problem that may escape the

confines of the facility, and thus warrants immediate attentien.

The licensee should increase the scope of the second EAL in this -

category to address those other monitors (including in the

controlled area) that may be indicative of severe degradation of

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radioactive material control.

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Alert #9, Coolant pump seizure leading to fuel failure.

The licensee has not addressed this example condition with its EAL

scheme, and stated in the basis document that ... Fuel failure for

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whatever reason will be dete;ted by methods addressed in response

to example 1.b. and 6. Omission of events that cause fuel failures

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(e.g., control rod accidents, pump seizures, etc.) is acceptable if a

complete set of symptomatic indicators of fuel failures is

incorporated into the scheme. The EAL scheme must permit

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dealing with all symptoms of fuel failure if the events are to be

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omitted.

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Alert #10, Complete loss of any function needed for plant cold

shutdown.

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This example condition was not directly addressed by the licensee's'

EAL scheme, however, the basis document indicated that the

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condition was indirectly addressed by Category General Safety and

its associated EAL that stated ... Conditions exist which have

substantially degraded plant safety. This EAL was perceived as

very subjective when used as the criteria for determining adequacy

of cold shutdown functions. The basis document also stated ...

Since CCNPP is not designed to reach cold shutdown (Mode 5) as

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a safe condition, then it is not appropriate to develop an EAL for

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failure to be able to reach this mode. An EAL is appropriate,-

- however, for failure to maintain cold shutdown as substantial safety -

degradation could occur under this scenario. AOP-3B, Loss of

Shutdown Cooling, provides specific conditions for Alert emergency

declaration. The AOP specifies General Safety category.

Notwithstanding the above basis document comments, if the plant -

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is not in cold shutdown, significant motive force for radioactive

material release exists, and thus the inability to reach and/or-

maintain cold shutdown constitutes a significant degradation in

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safety of the plant. Systems capability, such as residual heat

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removal, component cooling water, charging, and boration, must be

objectively considered to reach and/or maintain cold shutdown.

The loss of any of the above types of functions must be properly

addressed by the licensee's scheme.

In addition, the basis document indicated that AOP-3B may

provide for an emergency declaration of Alert under some

circumstances of loss of shutdown cooling. Only one document, the

EAL classification document, should provide for a declaration of an

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emergency. AOP-3B should do no more than refer the user to the

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classification document to make the declaration.

13.

Alert #12, Fuel damage accident with release of radioactivity.

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The licensee's EALs stated ... AOP-6D, Fuel handling incident

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Auxiliary Bldg. AOP-6E, Loss of refueling pool level implemented

AND radioactivity released in Containment.

Neither of these EALs quantified the amount of radioactivity

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release and thus did not provide an objective value, that when

observed by instrumentation or other measurement, constituted an :

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action level upon which to base an emergency declaration.

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Therefore, the licensee should modify the listed EALs to provide

objective, measurable values, to permit ready implementation.

SITE AREA EMERGENCY

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14.

SAE #1, Known loss of coolant accident greater than makeup _

pump capacity.

The licensee's equivalent EAL stated ... EOP 8, Functional

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Recovery Procedure implemented and Safety Function criteria not

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met for 15 minutes. If Safety Function criteria are not met, a core

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melt situation potentially exists, and it is merely problematic as to

how long the plant can continue until melt occurs. Waiting 15

minutes to make an emergency declaration to determine whether

the Functional Recovery Procedure is going to be effective is not

consistent with the anticipatory intent of NUREG-0654. Therefore,

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the licensee should remove the modifier related to time to

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classification when a potential core melt sequence is in progress.

This comment also applies to the EALs for SAE #2, #3, and #5.

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15.

SAE #8, Complete loss of function needed for plant hot shutdown,

The licensee's equivalent EAL stated ... EOP-8, Functional

Recovery Procedure implemented AND Safety Function criteria not

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met for > 15 minutes.

The discussion above in comment #14 concerning the 15 minute

time element is also applicable in this EAL In addition, EOP-8

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addressed the Critical Safety Functions (CSFs) of steam generator

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inventory control, reactor coolant system (RCS) inventory control,

and reactivity control. However, additional system functions

required for hot standby, e.g., of RCS charging capability, steam

generator safety valves, boration capability, and RCS pressure

control capability may not be directly addressed by the CSFs.

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Therefore, as in the discussion in Comment #12 above, the loss of

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these types of functions should be fully addressed by the licensee's

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scheme.

16.

SAE #10, Major damage to spent fuel in containment or fuel

handling building.

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The licensee did not include this example condition in its EAL

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scheme, and stated in the basis document that the threshold for

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major damage was best determined by subsequent radiological

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conditions. However, the licensee utilized on!y effluent monitoring

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as EALs for fuel damage. While ef0uent monitors are one

symptomatic indicator of fuel damage, others probably exist in the

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installed instrumentation of the plant. For example, the

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containment radiation and continuous airborne monitors, and fuel

handling building equivalent instrumentation, could also be used as

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indicators of spent fuel damage. The licensee should also include

as EALs those locally available and applicable instruments that are

symptomatic of fuel damage, rather than relying only on the

ef0uent monitors for the facility.

17.

SAE 13.b., These dose rates are projected based on other plant

parameters,

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The licensee's equivalent EAL stated .. 2 0.5 rem whole body,

2 2.5 rem thyroid measured, or 2.250 rem /hr projeu,ed at site-

boundary using actual meteorology. The EAL as stated adequately

addressed the intent of the example initiating condition. However,

stating that the EAL was adequate assumed that the licensee's dose

projection / dose assessment procedures fully addressed the subject

of the example condition, i.e., making projections based on plant

parameters. The absence of any EALs relating, for example,

containment high radiation monitor readings to extent of fuel

~ damage, led to the conclusion that the intent of the EAL may not

be able to be implemented. This perception was due to

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inadequate consideration of relationships such as extent of fuel

damage and containment radiation levels. The licensee should

assure that their dose projection programs are fully capable of

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projecting doses based on plant parameters. This discussion

applies also to the example initiating condition of General

Emergency 1.b.

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SAE #17, Other plant conditions exist that warrant activation of

monitoring teams or a precautionary notification to the public near

the site.

The licensee's equivalent EAL stated ... Plant conditions exist which

could result in gross high level plant contamination. The

fundamental issue in the example initiating condition was that plant

conditions existed that would cause radiological conditions at or

near EPA guidelines, at or near the site boundary, that warranted

activation of monitoring teams and precautionary notification to the

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public. The licensee should modify its EAL to reflect the site -

boundary conditions that warrant declaration of a Site Area

Emergency.

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19.

GE #2, Loss of 2 of 3 fission product barriers with the potential

loss of the third barrier.

The licensee implemented this example initiating condition with the

following EAL: Any TWO of the following three, AND potential

of occurrence for the THIRD.

RCS activity > 300 uCi/cc I-131 Dose Equivalent

EOP-5, LOCA-implemented

Containment degradation-(any of the below):

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- Equipment hatch not closed / sealed

- Either airlock inoperable

- Containment pressure > 25 psig

- All penetrations not closed or capable of .....

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Two concerns were noted on the above EALs, As discussed in

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Comment #9 concerning detection of fuel failures, the licensee

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should consider defining fuel failure on the basis of several

symptomatic indicators such as containment radiation levels and

status of Critical Safety Functions. Additionally, it was unclear

what is the meaning of "Either airlock inoperable." The licensee

should unambiguously define the EAL as either airlock not capable

of being sealed, or both doors of either airlock not capable of

being sealed, for example.

20.

GE #4, Other plant conditions exist, from whatever source, that

make release of large amounts of radioactivity in a short time

period possible; e.g., any core melt situation.

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The licensee implemented this example initiating condition with the

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EAL that plant conditions exist which could result in imminent core

degradation. Two concerns were noted with this EAL

Plant conditions were not specified based on instrumentation

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or other observed parameters.

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Imminent. core degradation does not necessarily mean that

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large amounts of activity may be released in a short time

period.

The licensee should specify in an unambiguous manner those plant

conditions that will, or potentially could, result in large amounts of

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radioactivity being released so that Emergency Coordinators make

classifications and declarations of emergencies in an objective

manner. For example, Critical Safety Functions of Reactivity

Control, RCS Inventory, and Containment Integrity may indicate

plant conditions that will (or potentially will) release large amounts

of activity in a short period of time. Other relationships also exist

that permit objectively defining this EAL as follows:

FISSION PRODUCT BARRIER

RELATED CSF

Clad Integrity

Reactivity Control

Core Heat Removal

RCS Integrity

RCS Inventory Control

RCS Pressure Control

RCS Heat Removal

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Containment-Integrity

Containment Isolation

Containment Temperature /

Pressure Control

Containment Combustible-

Gas Control

If any of the CSFs for each of the fission product barriers is under

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challenge,- then the related fission product barrier is deemed

challenged / failed, and an emergency declaration can be made.

- The licensee may wish to consider the extension of the concept to

declaration of Alert and Site Area Emergency. It may be shown

mathematically that the loss of two barriers will result in a

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radiological problem of a magnitude approximating EPA guidelines

at the site boundary (definition of Site Area Emergency),.and the

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loss of one barrier will result in a radiological problem that is a-

small fraction of EPA guidelines at the site boundary (definition of

an Alert). The remaining attribute of such a scheme is the

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definition of all the symptomatic indicators for defining loss of

fission product barrier integrity as discussed above in detail for the

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4.0

Exit Meeting

The inspector met with licensee personnel denoted in Section 1 at the conclusion

of the inspection to discuss the scope and findings of this inspection as detailed

in this report and was followed up with a subsequent telephone conversation on

January 31,1990 between Dr. Ronald R. Bellamy of this office and Mr. Richard

Heibel of your staff. The licensee was informed that no apparent violations

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were identified. Mr. Heibel committed to evaluate and upgrade the Emergency

Classification Level system to conform with NUREG-0654, and to keep the NRC

apprised of progress and schedular slippage.

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