ML20052A875

Board Notification 82-28:forwarding Info Re Safety Relief Valve Control Sys,Qa During Const & Emergency Preparedness Relevant to OL Proceeding.Resolution of Listed Issues Will Be Documented in Future SER Suppl

ML20052A875
Person / Time
Site:	Fermi
Issue date:	03/24/1982
From:	Tedesco R Office of Nuclear Reactor Regulation
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19296F582	List: ML19296F581 ML20052A875
References
REF-PT21-77-007-005, TASK-AS, TASK-BN-82-28 BN--82-28, NUDOCS 8204290297
Download: ML20052A875 (10)

Text

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JAAR 2 41982 Docket flo.: 50-341 NEMORANDUM FOR: Atomic Safety and Licensing Board for Femi 2 FROM:

Robert L. Tedesco, Assistant Director for Licensing, DL SilBJECT:

BOARD !!OTIFICATION INFORMATION REGARDING FERMI 2 SAFETY RELIEF VALVE C0tlTROL SYSTE!1, QUALITY ASSURANCE DURING CONSTRUCTION AND EMERGENCY PREPAREDHESS BOARD NOTIFICATION (82-28)

In accordance with the guidance set forth in NRR Office Letter No.19, Revision 1, we are providing you with recent information which is relevant to the Femi 2 operating license proceeding.

The staff's Final Environmental Statement (August 1981), FES Addendun (March 1982),

Safety Evaluation Report (July 1981), SER Supplement No.1 (Septenber 1981) and SER Supolement No. 2 (January 1982) appropriately considers relevant and naterial infomat?on concerning environnental and safety natters that was available prior to the prrparation of these five documents. The staff's testimony, dated February 26, 1982, appropriately considers relevant and naterial infomation concerning the two CEE contentions (4 and 8) that was available up to the time of its preparation. Section 1.8.1 of SER Supplenent No. 2 lists the outstanding safety issues (in addition to the two contentions) that must be resolved prior to issuing an operating license. The resolution of these issues will be documented in a future supplement to the SER, prior to issuing an operating license. There are no outstanding environmental issues.

The Femi 2 hearing is scheduled to start March 31, 1982. There are two contentions:

CEE Contention 4 regarding quality assurance and quality control during construction and Contention 8 regarding evacuation of a small community adjacent to the site during energencies (see Enclosure 1). The prospective license issuance date is in November 1982, based on applicant's target date for fuel loading. The final supplenent to the SER is scheduled for issuance in Novenber 1982.

j The licensing project manager, L. L. Kintner has reviewed the Division of Licensing listing of board notifications through BN 82-19, which was entered on March 3, 1982.

Except for 3 notifications addressed in the following paragraph, the material in the listing either (1) had been appropriately disposed of in the Femi 2 SER and its supplements (Hos. I and 2) and the Femi 2 FES and its addendun, or (2) was currently being considered and will be appropriately disposed of by regular j

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Atonic Safety and Licensing Board W 24 W for Fermi 2 NRC procedures for plant specific issues and generic issues. The resolution of plant specific issues will be addressed in a future supplement to the SER prior to issuance of an operating license. The resolution of generic issues will be addressed in an SER supplenent if inplenentation dates are prior to ifcense issuance and in license amendments if implenentation dates are later than the license issuance date.

The three board notifications in the DL listing that had not been considered in Ferni 2 staff documents, and their disposition follows:

1.

Board Hotification Ho. 53, Decenber 16, 1977, letter from G. G. Sherwood (GE) to E. Case (NRC) regarding selection of BWR relief valve control systen nodification.

(Enclosure 2)

This rodification, called the low-low set relief logic, would prevent more than one relief valve from opening under certain reactor transient events, thus meeting the design basis for containment loads. This nodification is applicable to GE Mark I and Mark II containments, as well as Mark III containments.

The plant unique analysis for the Fermi 2 Hark I containment is an outstanding issue in the OL review. The applicant has advised staff that it plans to use the low-low set relief logic. This modification is currently heing reviewed by the staff for other BWR plants and will be reviewed for Ferni 2 as well. We will report our conclusions in a supplenent to the SER. This issue is not relevant to either Contention 4 or 8, 2.

Board Notification No. 81-08, June 11,1981, regarding the consideration of earthquakes on offsite transportation and concunications during emergencies.

(Enclosure 3) This issue was raised in the San Onofre 2 and 3 proceeding. Since then the Commission has decided to withdraw it fron consideration in the San Onofre licensing proceedings and treat it generically (Menorandun from Chilk, March 1, 1982 Enclosure 3). This issue nay be relevant and naterial to Contention 8.

3.

Board Hotification No. 82-08, February 9,1982, regarding errors in BWR water level measurenent.

(Enclosure 4) This issue, which is being reviewed on a generic basis, nay result in changes to equipment, operating procedures, and energency procedures.

This issue is not relevant to either Contention 4 or 8.

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NRC FORM M 00% NRCM ONO OFFIClAL RECORD COPY usoeo m m m

b Atonic Safety and Licensing Board 14R 2 41982 for Femi 2 The licensing boards for BWRs, including Femi 2, have been notified of this issue.

The licensing project nanager has also reviewed principal correspondence on the Femi 2 docket that was received since preparation of staff documents. The correspondence described below is believed relevant and natorial to the Femi 2 operating license proceeding. They are applicable to Femi 2 only and, therefore are not recownded for notification to other plant boards.

1.

A January 8,1982 letter from !!RC Region III to applicant transnitting the correspondence between the staff and one of the allegers in a staff investigation reported in IE Report No. 50-341/80-22.

(Enclosure 5)

This may be relevant and naterial to Contention 4.

2.

A January 26, 1982 nenorandum fren FEMA, to the staff providing interim findings on offsite energency preparedness.

(Enclosure 6) This may be relevant and naterial to Contention 8.

3.

A March 3,1982 letter to applicant transmitting IE Report No. 50-341/82-02 (DEPOS) providing staff conclusions on the Ferni 2 energency exercise conducted February 1-3, 1982.

(Enclosure 7) This nay be relevant and naterial to Contention 8.

The Femi 2 board will receive board notifications of future correspondence detemined to be naterial and relevant to the Fenni 2 operating license proceed-ing in accordance with Office Letter No.19, Revision 1, procedures.

W Robert L. Tedesco, Assistant Director for Licensing Division of Licensing

Enclosures:

As stated cc w/encls.:

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OFFICIAL RECORD COPY usapo: mi-mm

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Mr. Harry Tauber MAR 2 4 ES2 Vice President Engineering & Construction Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 cc:

Mr. Harry H. Voigt, Esq.

LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N. W.

Washington, D. C.

20036 Peter A. Marquardt, Esq.

Co-Counsel The Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 Mr. William J. Farner Project Manager - Fermi 2 The Detroit Edison Company 2000 Second~ Avenue Detroit, Michigan 48226 Mr. Larry E. Schuerman Detroit Edison Company 3331 West Big Beaver Road Trcy, Michigan 48084 David E. Howell, Esq.

3239 Woodward Avenue Berkley, Michigan 48072 Mr. Bruce Little U. S. Nuclear Regulatory Commission Resident Inspector's Office 6450 W. Dixie Highway Newport, Michigan 48166 Dr. Wayne Jens Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 Mr. James G. Keppler Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

ENCLOSURE 1 "CEE Contentions 4 and 8" i

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'a The follu.: fur cositentiunu 'nd their factur.1 bases ura supported a

by the direct and in.*i re.I hun.'Jedne at.it Icact one rx=bt r of C.EE who is and has becu person.nlly involved in the construction of Fermi 2 since work was ber.un.

(a) There has been an appalling lack of physieni security at the construction site since the inception of construction.

Civen the need for c>:tremely c3ose quality control in the crec-tion of a nuelcar plant, thin failinr,could well lead to finws in the structure, through deliberate sabotage or unintentional injury to components.

(b) The Applicant's Quality Assurance Inspection Program has not been executed in conformance with Criterion X of Appen-dix B to 10 CFR Part 50.

Recent reinspections of various materials and worknanship indicate that quality control was inadequate during construction prior to the 1974 shutdown of l

construction activities at the site.

Specifically, CEE identi-fies:

(1) large and small bore pipe hangers, and (2) welds of safety related components.

l (c) The Applicant has not maintained sufficient quality 1

j assurance records to furnish evidence of activities affecting quality to comply with Criterion XVII of Appendix B to 10 CFR Part 50 in that records have been destroyed or lost during the course of construction.

(d) Detroit Edison twice replaced the team of super-l visors from the first general contractor, Ralph M. Parsons Co.,

then terminated its contract with Parsons and hired a second firm, because Parsons' employees refused to sacrifice quality control in order to expedite the construction schedule.

(e)

Specific flaws in construction can be identified, among them:

(1)

Excessive water in the reactor hole which caused the concrete base to crack severely, a probl'em purportedly remedied by patching.

1 (2)

Hafrline esachs< in 'dtructural rtsul turtound-iny tne ury well.

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r. f r..: 11:le escape route for the.recidenen of the Stony Pointo ::rcs. v;alch J :.1]ncent tri ?!..

Fermi 2 site.

The only road leading to and from the area, Pointe Aux Peaux, lies very close to the reactor site.

In case of an accident the residents would have tc travel towards the accident before they could move away from it.

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, M$$Qf*f 3E GENERAL ELECTRIC NUCLEAR ENERGY.

SYSTEMS DIVISIO'N GENERAL ELECTRIC COMPANY.175 CURTNER AVE.. SAN JOSE, CALF"' "" 5 NUCLEAR ENERGY MC 682, (408) 925-5040

-ys PROJECTS DIVISION

'I December 16, 1977

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MFN-482-77 Mr. Edson G. Case, Acting Directc t.

DtOrN U. S. Nuclear Regulatory Commissi6 o p"g #fd Office of Nuclear Reactor Regulath

.,c Washington, D.C.

20555 M.

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Dear Mr. Case:

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SUBJECT:

SELECTION OF BWR/6 RELIEF VALVE CONTROL SYSTEM MODIFICATION On October 6,1977, G' neral Electric advised representatives of Inspection e

and Enforcement and Nuclear Reactor Regulation-of a reportable condition under 10CFR21.

That condition was connected with the relief valve control system which, under certain transientisolation events, would allow more than one relief valve to reopen resulting in load combinations not currently specified in the licensing documentation.

On October il, 1977 General Electric submitted a report which described the relief valve control system deficiency under 10CFR Part 21.

Since that time, General Electric has met with members of the NRC staff on October 13, 1977 and November 11, 1977 to discuss this matter.

l Although this letter identifies the selection of a relief valve control i

system modification in the context of BWR/6 plants, the modification l

selected to remedy this condition can be applied generically for use on l'

EWRs in Mark I and Mark II plants if required.

This modification to the relief valve control system is referred to the low-low set relief i

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l This letter provides a summary of the information presented to the NRC staff regarding icw-low set relief logic addition to the relief valve control system.

The low-low set relief logic assures that tne number of elief valves wnich could reccen folicwinc a reactor isication event do not exceed tnose currently used as the licensing : asis for design.

It is a further purpose of this letter to seek concurrence by the staff that the aoprcach being taken by General Electric for resolution of this item is acceptable.

Discussion The low-low set relief system logic improvement has been selected to I

resoi/e the concern for multiple valve subsequent actuation on EWR/6 Mark III. 'This selection was made on the basis that~when comoared to other alternatives, it best satisfies all design objectives and require-ments.

The design objectives and design requirements for the relief system logic are sum arized on Page 1 of the attachment.

Page 2 of the DESIGNATED ORIGIML wgm ceu,.m

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G E N E R A L () E LECTRIC E. G. Case Page 2 attachment summarizes the setpoint arrangement for both the normal pressure relief setpoints and for the low-low set relief portion of the control system.

Note that the design is single-failure proof and further does not. compromise margins for either overpressure. protection or inad-vertent relief valve opening.

The design is also testable during normal operation.

The low-low set relief logic system adds circuitry which imposes pre-established lower opening and closing set poi'nts for selected valves which override the normal setpoints following the initial opening of these valves.

This logic is armed or activated by the existing pressure sensors of the second normal relief setpoint group.

Once the transient has ended, the low setpoints can be disengaged by manual reset.

A schematic 1,gic diagram for the BWR/6 relief valve control' system with o

the low-low set feature is attached.

See Pages 3 and 4 of the attachment to this letter.

The reactor performance during an isolation event with the low-low set relief system is summarized on Page 5 of the attachment.

All valves would be expected to open on the first pressure rise after isolatioh when conservative design assumptions /models are employed.

Subsequent pressure peaks will result in no more than one relief valve experiencing subsequent actuations, with a margin of 4 0 psi existing between the lowest set valve and the next lowest set valve in the armed logic.

The low-low set relief system mintains the current design documented basis for containment and NSSS equipment evaluation methods and for overpressure transients.

Thus, no additional load cases for containment or NSSS equipment are required and the overpressure transients will not have to be redone.

In addition, introduction of this system will result in a significant reduction in containment fatigue duty cycles resulting from relief valve cycling during the decay heat dominant period late in an isolation transient.

This represents an increase in-design margins in the fatigue area.

l It will no.t be necessary to reevaluate any transient analyses presented in Chapter 15 of GESSAR because the current submittal.s will not be invalicatec.

The purpose of the events presented in Chapter 15 is to demonstrate that established overpressure protection and fuel thermal

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limits criteria are met for the expected spectrum of abnormal transients.

This is accomplished by making conservative assumptions with regard to ecuipment performance and initial conditions.

Forfexample,theupper range of the nominal opening relief valve setpoints are conservatively used.

Any effect of low-low set relief on transient response occurs

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GEN ER AL h ELECTRIC 3.

E. G. Case Page 3 considerably later in the transient than the time of minimum margins, i.e., peak vessel pressures and minimum MCPRs for the limiting events occur on the initial pressure rise, whereas low-low set affects subse-quent pressure peaks.

Although the subsequent pressore signature after the initial p'eak nay change due to low-low set, the established peak vessel pressures and minimum thermal margins will not change from that currently presented in Chapter 15 of GESSAR.

Future Actions In accordance with discussions with members of the NRC Staff, General Electric has agreed to provide, in January 1978, additional information regarding the design'and analyses of the low-low relief set alternative.

This information will be of the same level at detail as that contained in the 238 Nuclear Island GESSAR.

The following identifies the contents

- of the January 1978 submittal which will be t-re.nsmitted by letter on the 238 Nuclear Island GESSAR, Docket STN 50-447:

o Replacement documentation for portions of.the GESSAR affected by addition of the low-low relief set logic.

o System description, analyses, FCD's, P&ID's and elementary wiring '

diagrams as they pertain to low-low relief set logic.

o Typical information as identified above for the ADS Inhibit feature should GE propose it as part of the standard design.

We request that the NRC staff concur that the addition of the low-low set relief logic to the BWR/6 relief valve control systam, if designed in accordance with the criteria described herein, is acceptable as the remedy to the condition as reported in our letter of October 11, 1977.

Because of the critical schedules associated with this item, we would 3::reciate receiving your concurrence on this matter as early in Jan-uary 1975 as is feasible.

If you nave any questions or comments regarding this matter, please contact Mr. J. F. Quirk of my staff.

Very truly yours, k

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G. G. Sherwood, Manager Safety and. Licensing SWR Projects Department Mail Code 676, Ext. 5040 GGS:sj/59-61 Attachment cc:

R. Scyd V. Stello, Jr.

R. J. Mattsen E. Volgenau 2

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• ATTACHMENT MARK III BWR/6 SRV CONTROL SYSTEM EVALUATIONS FOR SUBSEQULNT ACIVATION '

DESIGN OBJECTIVES 1.

ONE'SRV SUBSEQUENT ACTUATI6N 2.

MAINTAIN CURRENT DESIGN BASIS e

CONTAINMENT LOADS e

OVERPRESSURE IRANSIENT&-

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SIMPLICITY 5F IMPLEMF!!TATION 4.

GEtiERIC APPLICATION 5.

REDUCE LO!!G TERM SRV CYCLING DESIGt! REQUIREMENTS 1.

RETAIN CURRElli LOAD EliVELOPE s.

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ACCEPTABLE OVERPRESSURE PROTECTInN 3.

DO NOT OPEN S/R VALVES Ofl SPRING (SAFETY)

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ACCEPTABLE MARGIN AGAliiST IllADVEP.TElli OPENIllG 5.

SIf1GLE FAILURE PR00F LOGIC 6.

TESTABLE DURIliG fl0'Rf9L OPERATI0i'l

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MARK III Bt!R/6 SRV C0!! TROL SYSTEti: EVALUATIONS LOW-LOW SET RELIEF PERFORMAtlCE

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o ISOLATION EVENT PERFORf1ANCE ALL VALVES 1ST ACTUATION'

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1 VALVE SUBSEQUENT ACTUATION SUBSEQUENT PEAK PRESSURE MARGIN TO MULTIPLE VALVE

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ENCLOSURE 3

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UNITED STATES g* c NUCLEAR REGULATORY COMMISSION 4'

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The Atomic Safety and Licensing Board for San Onofre Nuclear MEMORANDUM FOR:

Ge*1erating Station, Units 2 and 3 Darrell G. Eisenhut, Director, Division of Licensing, NRR FROM:

BOARD NOTIFICATION - EMERGENCY PLANNING (BN 81-08) 5UBJECT:

The enclosed letter addresses NRC staff criteria for the consideration of This information is being forwarded to the earthquakes in emergency planning.

San Onofre 2 and 3 Licensing Board because it relates to a legal issue that the Board has stated (see Prehearing Conference Order of May 8,1981) should be resolved before the hearing.

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Dacket Nos.:

50-361/252 Mr. D. W. Gilman Mr. Robert Dietch Vice President - Power Supply Vice President San Diego Gas & Electric Company Scuthern California Edison Company 101 Ash Street

'I 4 Walnut Grove Avenue P. O. Box 1831

r. O. Box 800 San Diego, California 92112

'osemead, California, 91770

Dear Gentleme'n:

CLARIFICATION OF STAFF LETTER OF DECEMBER 17, 1980 REGARDING E OF EARTHOUAKES ON EMERGENCY RESPONSES AT SAN ONO 5'J JECT:

This letter is to provide clarification of the subject staff request for additional The intent of that request is to assure that adecuate consideration has been given to the complicating factors which might be caused by earth'cuakes information.

We believe that in the development of the emergency plans for your facility.

planning for that eventuality should be part of your emergency plan in view of th Accordingly, as relatively high frequency of severe earthquakes in California. letter, you are re

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indicated in our December 17, 1980 ef fects earthquakes would have on your emergency response capability and v

include these considerations in your emergency plan.

For purposes of this evaluation, as a planning basis you may assume that the plant site experiences While earthquake ef fects no more severe than the Safe Shutdown Earthquake.

you need not assume that a reactor accident occurs simulta the plant might have been adversely affected by the earthquake (e.g.

through failures or degradations in non-seismically qualified systems and t'at components) and may, therefore, be more prone to the potential for an incident tnat might result in off-site releases of radioactive material.

Specifically the following items should be considered in the evaluation of the effect of earthquakes on your emergency plan:

Ability to' transport necessary personnel to the plant to cope with degraded 1

modes of plant operation.

Cc-rnunication between the plant and outside agencies.

Mility to obtain damage estimates, both to the plant and to transportation /

This information should be available communication f acilities off-site.

to factor into the decision making process, including recomendations to,

of fsite authorities for protective actions af ter an earthcuake.

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Develop a range.of recommendations to off site authoritier that takes l

i into account various degrees and locations of damage to the plant environs.

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Robert L. Tedesco, Assistant Director for Licensjng Division of Licensing a:

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r. Pobert Dietch m. D. W. Gilman 1

cc:

Charles R. Kocher, E sc.

James A. Beoletto, Esq.

Southern California Edison Company 2244 Walnut Grove Avenue P. O. Box 800 Rosemead, California 91770 Chickering & Gregory ATTN:

David R. Pigott, Esq.

Counsel for San Diego Gas & Electric Company &

Southern California Edison Company l

3 Embarcadero Center - 23rd Floor San Francisco, California 94112 Mr. George Caravalho g-,)

City Manager j

City of San Clemente 100 Avenido Presidio can Clemente, California 92672 Alan R. Watts, Esq.

Rourke & Woodruff l

Suite 1020 1055 North Main Street Santa Ana, California 92701 L awrence 0. Garcia, Esq.

l California Public Utilities Commission 5066 State Building l

San f rancisco, California 94102 Mr. V. C. Hall Combustion Engineering, incorporated I

l 1000 Prospect Hill Road l

Windsor, Connecticut 06095 1

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, Mr. Robert Dierch Mr. D. W. Giltaan Calif ornia Department of Health Chief, Environmental Radiation cc:

ATTN:

Lontrol Unit Radiol ogical Health Section j

714 P Street, Room 498 95814

. f Sacramento, California Director Energy Facilities Siting Division Energy Resources Conservation &

Development Commission 1111 Howe Avenue 95825 Sacramento, California Chairman, Board of Supervisors San Diego County 92412 San Diego, California I

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Mayor, City of San Clemente92672 San Clemente, California U. 5. Environmental Protection Agency ATTN:

EIS Coordinator Region IX Office 215 F reemont Street 94111 San Francisco, California Energy Resources Conservation &

Development Commission ATT N L ibrarian 111 Howe Avenue 95825 Sacramento, California O

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BOARD NOTIFICATION DISTRIBUTION (EMEntVINCY FLANNING)

San Onofre Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Appeal Board Docketing and Service Section A. S. Carstens Phyllis M. Gallaher, Esq.

David W. Gilman Dr. Cadet H. Hand, Jr.

Mrs. Lyn Harris Hicks Mrs. Elizabeth B. Johnson James L. Kelley Janice E. Kerr, Esq.

J. Calvin Simpson, Esq.

Lawrence Q. Garcia, Esq.

Charles R. Kocher.

Charles E. McCl ung, Jr., Esq.

Davi d R. Pi gott, Esq.

Samuel B. Casey, Esq.

John A. Mendez Alan R. Watts, Esq.

Richard J. Wharton, Esq.

ACRS Members Mr. Myed Bender Dr. Max W. Carbon Mr. Jesse C. Ebersole Mr. Harold Etherington Dr. William Kerr Dr. Harold W. Lewis Dr. J. Carson Mark Mr. William M. Mathis Dr. Dade W. Moeller Dr. David Okrent Dr. Milton S. Plesset Mr. Jeremiah J. Ray Dr. Paul G. Shewron Dr. Chester P. Siess

[

Mr. Davi d A. Ward O

(

BOARD NOTIFICATION DISTRIBUTION Docket File 50-361/362 LPDR PDR NSIC TERA LB#3 File DEisenhut RPurple SVarga TIppolito RClark RReid BJYoungblood ASchwencer FMiraglia JRMiller DCrutchfield BRussell J01shinski HRood

_ Project Manager DL.en..

RHVoifin'er TMurley RMattson 5Hanauer B5nyder RHartfield, MPA OELD 01&E (3)

ACRS (16)

HDenton ECase PPAC (H. Thompson)

(EHughes]

t.suensom bcc:

W. J. Di rcks V. Stello I

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MAR 2 41982 BOARD fl0TIFICATI0ft DISTRIBUTI0ft (82-28)

~*DocketFile(50-341)

• PDR M;

• LPDR

• fiSIC

• TERA LB#1 Rdg.

• 0Eisenhut/MJambor RPurple SVarga DVassallo RClark JStolz RTedesco JYoungblood ASchwencer FMiraglia EAdensam JMiller DCrutchfield WRussell Tippoli to l

• RVollmer 4

• HThompson

• RMattson

• Silanauer

• BSnyder

• RHartfield, MPA

• RDeYoung a \\ r-

• BGrimes

• JConklin, REGI0ft III O

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• LKintner, Project Manager MService bcc: *WDircks

• VStello GCunningham

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ASLBP SECY OGC OPE EDO

• With Enclosures.

M 2 41982 l

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DISTRIBUTION OF BOARD NOTIFICATION (BN 82-28) l l

Fermi 2 ACRS Members Atomic Safety and Licensing Dr. Robert C. Axtmann Board Panel Mr. Myer Bender Atomic Safety and Licensing Dr. Max W. Carbon Appeal Board Panel Mr. Jesse C. Ebersole Docketing and Service Section Mr. Hamid Etherington Mr. David E. Howell Dr. William Kerr Peter A. Marquardt, Esq.

Dr. Harold W. Lewis i

e Gary L. Milhollin, Esq.

Dr. J. Carson Mark Dr. David R. Schink Mr. William M. Mathis

• -~

Dr. Peter A. Morris Dr. Dade W. Moeller Ha rry Voigt, Esq.

Dr. David Okrent Dr. Milton S. Plesset Mr. Jeremiah J. Ray Dr. Paul G. Shewmon Dr. Chester P. Siess Mr. David A. Ward

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UNITED STATES o

s:

Ms

'd gf1 NUCLEAR REGULATORY COMMISSION 8

,j W ASHINGTON, D.C. 20555 March 1, 1982 ngham Mnton CFFICE OF THE W&

SECRETARY MEMORANDUM FOR:

William J. Dircks, Execu

.ve Director for Operations FROM:

Samuel J.

Chilk, Secret

SUBJECT:

STAFF REQUIREMENTS -- EMER ENCY PLANNING (REF:

SECY-81-622A - D '

COMMISSION.

ORDER ON SAN ONOFRE SUA S ONTE)

The San Onofre Licensing Board has identified emergency planning areas which, in the Board's opinion, deserve further consideration.

The Commission has removed this issue from the hearing, and requests that the staff now take several actions to follow up on the issues raised by the Board.

The Commission (with Chairman Palladino and Commissioners Roberts and Gilinsky agreeing) believes the staff should consider the following questions:

1.

Should the emergency' planning activities of NRC licensees include consideration of the possible effects on emergency plans of a very large earthquake?

2.

If NRC requirements are to include this consideration, then what criteria should be applied in evaluating the adequacy of such plans in this respect?

The staff is requested to consult with FEMA in addressing these questions.

If the staff concludes that rulemaking is appropriate, then it should prepare the necessary documents for Commission consideration.

The Commission should also be informed if the staff concludes rulemaking is not necessary.

(E-GG) (SECY SUSPENSE:

4/30/82)

.In Commissioner Ahearne agrees with the Licensing Board that tn; identified areas deserve further consideration.

He believes plans should be designed so thay have flexibility and can provide protection even in the event of a plant accident at the same time as the occurrence of a natural phenomenon (i.e. earthquake, flood, tornado, bli==ard, etc.)'

which would be expected to occur at least once in the lifetime of a plant.

The objective is not to develop new requirements to assure the plans will function normally during these DESIGNATED ORIGINAL C

Certified By

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disasters.

Rather, it is to describe techniques for examining 19 33 the flexibility of the plans so we can evaluate the extent

. ? '?

- to which plans remain capable even in the face of such once l?T) in a lifetime events.

Consequently he believes the following

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actions should be taken:

"rs

'S$Il 1.

The staff should, in conjunction with FEMA, develop 1:S!

an approach for checking the ability of, emergency v a J3 plans to cope with natural phenomena which would be expected to occur during the life of the plant.

.;-j Examples are:

earthquakes, blizzards, tornadoes,

~ l.j hurricanes, tsunamis, and ficods that might be expected once every 40 years.

FEMA and the staff 3

should develop quidelines for examining plans for c:

flexibility and should identify measures which can 1

be used to assure flexibility.

i

'. 5 2.

=

The staff should develop a list of the once in a

'ifetime natural disasters most likely for each y

plant either holding en operating license or in f:

the OL process.

>l 3.

Existing emergency plans should be examined to

' 3[

determine whether adequate flexibility is present.

=:3

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He would then amend the emergency planning rule to incorporate (j) whatever flexibility features are determined to be required.

cc:

Chairman Palladino Commissioner Gilinsky Commissioner Bradford Commissioner Ahearne Commissioner Roberts Commission Staff Offices 0

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l e-ENCLOSURE 4 4

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UNITED STATES

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[),)M NUCLEAR REGULATORY COMMISSION y,(

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,I WASHINGTON, D. C. 20556

~

e Docket Nos. 50-322 FEB B 1982 t

50-341

[

50-358 50-387/388 3

50-466 50-556/557 I

MEMORANDUM FOR: The Atomic Safety & Licensing Boards for:

Shoreham Nuclear Power Station, Unit 1 Enrico Fermi Atomic Power Plant, Unit 2 William H. Zimmer Nuclear Power Station, Unit I Susquehanna Steam Electric Station, Units 1 and 2 a

Allens Creek Nuclear Generating Station, Unit i Black Fox Station, Units 1 and 2 FROM:

Robert L. Tedesco Assistant Director for Licensing Division of Licensing

SUBJECT:

BOARD NOTIFICATION - ERRORS IN BWR VESSEL WATER LEVEL INDICATION (Board Notification 82-08)

In accordance with present NRC procedures regarding Board notifications, the enclosed information is being provided for your information as constituting new information relevant and material to safety issues.

This information is generic and has applicability to all dockets with boiling water reactors.

h-1< _ _

Robert L. Tedesco Assistant Director for Licensing Division of Licensing

Attachment:

DSI/NRR memo dated 1/15/82 cc: See next page pgsIGNATED 0 IGIN

^ #-

4 Certified BT

-[M3 0 I 0 38 f

e y

FEB 9 1982 DIS'TRIBUTION OF BOARD NOTIFICATION Allens Creek, Docket No. 50-466 ACRS Members Texas Public Interest Research Dr. Robert C. Axtmann Group, Inc.

Mr. Myer Bender Hon. Ron Waters Dr. Max W. Carbon.

Region IV Mr. Jesse C.'Ebersole Bryan L. Baker Mr. Harold Etherington Margaret Bishop Dr. William Kerr Dr. John H. Buck Dr. Harold W. Lewis Dr. E. Leonard Cheatum Dr. J. Carson Mark Carolina Conn Mr. William M. Mathis J. Gregory Copeland, Esq.

Dr. Dade W. Moeller Stephen A. Doggett, Esq.

Dr. David Okrent Mr. John F. Doherty Dr. Milton S. Plesset Robin Gri ffi.th Mr. Jeremiah J. Ray Carro Hinderstein Dr. Paul G. Shewmon Leotis Johnston Dr. Chester P. Siess Christine N. Kohl, Esq.

Mr. David A.' War'd Rosemary N. Lemmer Mr. Gustave A. Linenberger Enrico Fermi, Docket No. 50-341 D. Marrack Brenda A. McCorkle Mr. David E. Howell Hon. John R. Mideska Peter A. Marquardt, Esq.

Jack R. Newman, Esq.

Gary L. Milhollin, Esq.

Mr. William Perrenod Dr. David R. Schink Susan Plettman, Esq.

M-

" :M ' : Eh0".D N lib A 'bH Hr. Wayne Rentfro b..e 5. L ~.e, - k., k r. M r, IO60 Yolel Alan S. Rosenthal, Esq.

./

c' Mr. William J. Schuessler Susouehanna. Docket Nos. 50-387c 50-388 Hon. Jerry Sliva Shel don J. Wol fe, Esq.

Gerald R. Schult:, Esq.

Robert W. Adler, Esq.

Shoreham. Docket No. 50-322 Mr. Glenn 0. Bri ght Dr. John H. Buck MHB Technical Associates Robert M. Gallo Ecua rd M. Ba rrett, Es q.

Mr. Thomas M. Geru' sky E:ra I. Sialik', Esq.

James P. Gleason Howard L. Blau, Esq.

Mr. Thomas J. Halli gan Joei Blau, Esq.

Dr. Judith H. Johnsrud Lawrence Brenner, Esq.

Ms. Colleen Marsh Dr. James L. Carpenter Mr. Thoras S. Moore Hon. Peter Cohalan Dr. Paul W. Purdom Jeffrey C. Cohen, Esq.

Jay Silberg, Esq.

David H. Gilmartin, Esq.

Mr. DeWitt C. Smi th.

Marc W. Goldsmith Bryan A. Snapp, Esq.

S tephen 9. Latham, Esq.

Dr. Emmeth A~. Luebke Mr. Srian McCa ffrey W. Taylor Reveley, III, Esq.

Ralph Shaairo, Esq.

Mr. Jeff Smith l

Di'stribution of Board Notification - p. 2 Zimmer, Docket No. 50-358 Black Fox, Docket Nos. 50-556, 50-557 Dale D. Brodkey Mr. Lawrence Burrell Troy B. Conner, Jr., Esq.

Mrs. Carrie Dickerson Andrew B. Dennison, Esq.

Mr. Gerald F. Diddle Michael C. Farrar. Esq.,

Joseph R. Farris, Esq.

~

James H. Feldman, Jr., Esq.

Joseph Gallo, Esq.

Lawrence R. Fisse, Esq.

Martha E. Gibbs, Esq.

Mr. John H. Frye, III Richard B. Hubbard W. Peter Heile, Esq.

Mr. Maynard Human Timothy S. Hogan, Jr.

Dr. W. Reed Johnson Dr. Frank F. Hooper Michael I. Miller, Esq.

11. Stanley Livingston Dr. Paul W. Purdom David K. Martin, Esq.

Dr. M. J. Robinson William J. Moran, Esq.

Mr. Richard S. Salzman

. George E. Pattison, Esq.

Mr. Frederick J. Shon Mr. Samuel H. Porter Dr. John B. West Dr. Lawrence R. 'Quarl es Mr. Clyde Wisner Fichard S. Salzman, Esq.

Sheldon J. Wolfe,. Esq.

Mrs. Deborah Webb, Esq.

Mrs. Ilene H. Younghein John D. Woliver, Esq.

Dr. John C. Zink Atomic Safety and Licensing Board Panel Atomic Sa fety and Licensing Appeal Board Panel Docketing and Service Section e

-p

Mr. M. S. Pollock Vice President - Nuclear Long Island. Lighting Company 175 East Old Country Road Hicksville, New York 11801 cc:

Howard L. Blau, Esquire MHB Technical Associates I 23 "3"

" ^**"" "

• 1 N

r dge Ro San Jose, Camornia 95125 Hicksville, New York 11801 Stephen Latham, Esquire Jeffrey Cohen, Esquire Twomey, Latham & Schmitt Deputy Commissioner and Counsel e

cond St et gency Bu iding Riverhead, New York 11901 Empire State Plaza Albany, New York 12223 Joel Blau, Esquire New York Public Service Commission energy Research Group, Inc.

The Gov. Nelson A. Rockefeller Bldg.

e 400-1 Totten Pond Road Empire State Plaza-Waltham, Massachusetts 02154 Albany, New York 12223 Jeff Smith Ezra F. Bialik, Esquire Shoreham Nuclear Power Station Assistant Attorney General Post Office Box 618 Environmental Protection Bureau Wading River, New York 11792 New York State Department of Law 2 World Trade Center

'W. Taylor Reveley III, Esquire New York, New York 10047 Hunton & Williams Pest Office Box 1535 P.esident Inspector r.1cnmond, Virginia 23212 Snoreham NPS, U.S.N.R.C.

Fost Office Box 5

..alpn Shapiro, Esquire Rocky Pcint, New York 11778

~

Cammer & Shapiro 9 East 40th Street New York, New York 10016 Mr. Brian McCaffrey Long Island Lighting Company 250 Old Country Road i

v.ineola, New York 11501 Honorable Peter Conalan Suffolk County Executive l

County Executive / Legislative Building Veteran's Memorial Highway l

Hauppauge, New York 11788 i

Davic Gilmartin, Escuire Suffolk County Attorney Ccunty Executive / Legislative Builcing Veteran's ilemorial Hignway Hauppauge, New York 11788 1

)

_ _ _ _ _. _. _ _ _.. a __ _

- l

c..,

Mr. Norman W. Curtis Yice President Erigir aering and Construction Pennsylvania Power & Light Company-l Allentown, Pennsylvania 18101 ces: Jay Silberg, Esquire Ms. Colleen Marsh Shaw, Pittnan, Potts & Trowbridge P. O. Box 538A, RD #4 1800 M Street, N. W.

Mountain Top, Pennsylvania 18707 Washington, D. C. 20036 Mr. Thomas J. Halligan Edward M. Nagel, Esquire Correspondent General Counsel and Secretary The Citizens Against Nuclear Dar ars Pennsylvania Power 4 Light Company P. O. Box 5 2 North Ninth Street Scranton, Pennsylvania 1850 Allentown, Pennsylvania 18101 Mr. J. W. Millard Mr. Willian E. Barberich Project Manager Nuclear Licensing Group Supervisor Mail Code 395 Pennsylvania Power & Light Company 2 North Ninth Street General Electric Company 175 Curtner Avenue Allentown, Pennsylvania 18101 San Jose, California 95125

.Mr. G. Rhodes

. Robert R. Adler, Esquire Resident Inspector Office of Attorney General P. 0. Box 52 505 Executive House Shickshinny, Pennsylvania 18655 P. O. Box 2357 Harrisburg, Pennsylvania 17120 Gerald R. Schultz, Esquire Susquehanna Environmental Advocates P. O. Box 1560 Wilkes-Barre, Pennsylvania 18703 fe. E. B. Poser Project Engineer Becntel Power Corporation P. O. Box 3965 l

San Francisco, California 94119 l

Dr. Judith H. Johnsrud Co-Di rec to r l

Environmental Coalition on Nuclear Poer l

433 Driando Avenue State College, Pennsylvania 16801 Mr. Thomas M. Gerusky, Director Eureau of Radiation Protection Resources Commonwealth of Pennsylvania l

P. O. Box 2063 Harrisburg, Pennsylvanta 17120 l

l-

~

i 3

Mr. Harry Tauber Vice President Engineering &. Construction...

Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226

-[

cc:

Mr. Harry H. Voigt Esq.

LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N. W.

Washington, D. C.

20036 Peter A. Marquardt, Esq.

Co-Counsel The Detroit Edison Company 2000 Second Avenue Detroit, Michigan 48226 Mr. William J. Farner Project Manager - Fermi 2 The Detro'it Edi. son Company 2000 Second Avenue Detroit, Michigan 48226 Mr.. Larry E. Schuerman Detroit Edison Company.

3331 West Big Beaver Road Tfoy, Michigan 48084-David E. Howell, Esq.

.J L3 7 EEEE Woodward Avenue 5erkley, Michigan 48072

r. Bruce Little

b. S. Nuclear Regulatory Ccmmission Resident inspector's Office 6450 W. Dixie Highway Newport, Michigan 48166 Dr. Wayne Jens

e:rcit Edisen : mpan:.

2000 Second Avenue Detroit, Micnigan 48226 Mr. James G. Keppler Nuclear Regulatory Commission Region III 799 Roosevelt Road Gien Ellyn, Illinois 60137

~

3 i

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~'

Mr Earl A. Borgmann Senior Vice President Cincinnati Gas & Electric Company Post Office Box 960 Cincinnati, Ohio 45201 Deborah Faber Webb Troy B. Conner, Jr., Esq.

7967 Alexandria Pike cc:

Conner, Moore & Corber

_ Alexandria, Kentucky 41001 1747. Pennsylvania Avenue, N.W.

Washington, D. C.

20006 Andrew B. Dennison, Esq.

Mr.' William O. Moran 200' Main Street Batavia, Ohio 45103 General Counsel Cincinnati Gas & Electric Company George E. Pattison, Esq.

Post Office Box 960 Clermont County Prosecuting Attorney Cincinnati, Ohio 45201 462 Main Street Batavia, Ohio 45103 Mr. Samuel H. Porter Porter, Wright, Morris & Ar'thur Mr.WaldmanChristi5nson 37 West Broad Street Resident Inspector /Zimmer Columbus, Ohio 43215 RFD 1, Post Office Box 2021 U. 5, Route 52 isr. James D. Flynn, Manager Moscow, Ohio 45153 Licensing Environmental Affairs Cincinnati Gas & Electric Company Mr. John Youkilis Post Office Box 960 Office oi the Honorable William Cincinnati, Ohio 45201 Gradison United States House of Representatives David Martin, Esq.

Office of the Attorney General Washington, D. C.

.20515 209 St. Clair Street Timothy S.' Hogan, Jr., Chairman First Ficor Frankfort, Kentucky 40601 Board of Commissioners 50 Market Street, Clermont County Batavia, Ohio 45103 James H. Felcman, Jr., Esq.

216 East 9th Street Lawrence R. Fisse, Esq..

Cincinnati, Ohio 45220 Assistant Prosecuting Attorney 462 Main Street W. Peter Heile, Esq.

Batavia, Ohio 45103 Assistant City Solicitor l

l Room 214 City Hall Mr. Jame's G. Keepier Cincinnati, Ohio 45220 U. S. 14RC, Region III i

799 Roosevelt Road John D. Woliver, Esq.

Glen Ellyn, Illinois 60137 Legal Aid Security Post Office Box #47 550 Ki'igore Street Sata'vi:, Ohio 45103 l

w

1 BLACK F.OX Mr. G. W. Muench, Manager Black Fox Station Nuclear Project Public Service Conpany of Oklahoma P.O. Box 201 Tulsa, Oklahona 74102 cc:

Mr. Vaughn L. Conrad Ms. Ilene H. Younghein Public Service Co. of Oklahona 3900 Cashion Place P.O. Box 201 Oklahoma ~ City, Oklahona 43112 Tulsa, Oklahona 74102 Andrew T. Dalton, Jr., Esq.

Mr. John C. Zink 1437 South Main Street Manager, Nuclear Licensing Tulsa, Oklahoma 74119 Public' Service Co. of Oklahoma P.O. Box 201 Joseph R. Farris, Esq.

Tulsa, Oklahoma 74102 Greem, Feldman, Hall & Woodard 816 Enterprise Building Mr. Michael I. Miller Tulsa, Oklahoma 74103

• Isham, Lincoln & Beale One 1st National Plaza Sheldon J. Wolfe, Esq.

Suite 4200 Atomic Safety' & Licensing Board C.hicago, Illinois 60606 U.S. Nuclear Regulatory Commission Washington, D. C.

20555 Isham, Lincoln & Beale Mr. Joseph Gallo, Esq.

Mr. Paul W. Purdom, Director Room 325 Environmental Studies Group 1120 Connecticut Avenue, N.W.

Drexel University Washington, D. C.

20036 32nd and Chestnut Streets Philadelphia, Pennsylvania 19104 Dr. M. H. Robinson Black & Veach Mr. Frederick J. Shon P.O. Box 8405 Atomic Safety & Licensing Board Kansas City, Missouri 64114 U.S. Nuclear Regulatory Ccmmission Washington, D. C.

20555 l

Mr. Maynard Human l

General Manager Jan Eric Cartwright, Esq.

Western Farmers Electric Cooperative Attorney General P.O. Box 429 State of Oklahora Anadark o, Oklahoma 73005 112 State Capitol Building i

Oklahoma :ity, Oklancma 73105 Mr. Gerald F. Diddle General Manacer John T. Collins,- Regional Administrator Citizens Action for Safe Energy, Inc.

U.S. Nuclear Regulatory. Commission, P.O. Box 754 Region IV Springfield, Missouri 65801 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Ms. Carrie Dickerson Citizens Action for Safe Energy, Inc.

P.O. Box 924 i

Claremore, Oklahcra 7a107 1

1 l

4 9

b ALLENS CREEK Mr. J. H. Gol'dberg Vice President Nuclear Engineering and Construction Houston Lighting & Power Conpany P.O. Box 1700 Houston, Texas 77001 cc:

R. Gordon Gooch, Esq.

D. Marrack Baker & Boots 420 Mulberry Lane 1701 Pennsylvania Avenue, N.W.

Bellaire, Texas 77401 Washington, D. C.

20006 Mr. Wayne Rentfro J. Gregory Copeland, Esquire P.O. Box 1335 Lowenstein, Newman, Reis & Axelrad Rosenberg, Texas 77471 1025 Connecticut Avenue, N.W.

Washington, D. C.

20036 Rosemary N. Lecmer 11423 Oak Spring Mr. P. A. Horn Houston, Texas 77043 Project Manager, ACNGS Houston Lighting & Power Conpany Leotis Johnston P.O. Box 1700 1407 SceMc Ridge Houston, ' Texas 77001 Houston, Texas 77403 Mr. Ray Matzelle Mr. William J. Schuessler Project Manager, ACNGS 5810 Darnell Ebasco Services, Inc.

Houston, Texas 77043 19 Rector Street New York, New York 10005 Margaret & J. Margan Bishop 11418 Oak Spring Mr. Ray Lebre Houston, Texas 77043 Project Manager, ACNGS General Electric Stephen A. Doggett, Esq.

175 Kurtner Avenue Pollan, Nicholson & Doggett San Jose, California 95125 P.O. Box 592 Rosenberg, Texas 77471 Susan Plettman, Esquire Davic Preister, Esquire Bryan L. Baker Texas Attorney General's Office 1923 Hawthorne P.O. Ecx 12548 Houston, Texas 77098 Capitol Station Auston, Texas 78711 Rooin Griffith 1034 Sally Ann Mr. and Mrs. Robert S. Framson Rosenberg, Texas 77471 4822 Waynesboro Drive Houston, Texas 77035 Mr. William Perrenad 4070 Merrick Mr. F. H. Pctthoff, III Houston, Texas 77025 1814 Pine Village Houston, Texas 77050

3 p" "%g

,o, UNITED STATES

( 'g NUCLEAR REGULAT,ORY COMMISSION N*

WASHINGTON. D. C. 20555 E

%.C/j JAN 15 1982, MEMORANDlM FOR: Roger J. Mattson, Director Division of Systems Integration Themis P. Speis, Assistant Director for. Reactor Safety FROM:

Division of Systems Integration ERRORS IN BWR VESSEL WATER LEVEL INDICATION '

SUBJECT:

Attachment A provides a summary of the results of work done to date in the RSB and ICSB under Task Interface Agreement 81-21 " Pilgrim 1, Water Level-Instrumentation Oscillation."

It is emphasized that review of this issue is not complete, even though we have proposed some short and long-term By copy of this memo, I am requesting that comments or recommendations.

other relevant feedback on the contents of this memo, and especially the proposed recommendations, be provided to C. Graves,by 1/27/82.

hk h.

Themis P. Speis, A:;sistant Director for Reactor Safety Division of Systems Integration

Enclosure:

As stated cc:

H. Denton W. Hodges J. Rosenthal G. Lainas C. Graves T. Ippolito S. Rubin B. Sheran L. Rubenstein G. Mazetis C. Berlinger H. Thompson V. Thomas L. Phillips' D. Ziemann W. Mills T. Dente. (B'..'R Owners Group)

D. Eisenhut 7f T. Novak

}

?

F. Rosa S. Hanauer E. Rossi CONTACT:

C. Graves (x29404) rI J. Rosenthal (x29459)

{

o.

ATTACHMENT A s

BWR WATER LEVEL > INDICATION ERRORS I.

INTRODUCTION On ~ September 26, 1981, during a routine reactor shutdown _and cooling operation at Pilgrim 1, there were several large oscillations.of Yarway level detection

- indication (reference.1). The first oscillation caused high level isolation followed by low level scram.

The oscillations were attritiuted to high con -

tainment temperatures, which caused flashing in the heated reference legs of the Yarway instruments.

At the time, the reactor coolant temperature was about 220*F while the temperature in the upperspart'of the drywell was 240 F.

4 In 3 Task Interface Agreement of October 1981 (reference,2), NRR was assigned f

the folicwing action plan

~:

1.

Revies event to _.ablish the pene,ric licensing implications;

'(DSI/RSB & ItSB)

-2.

Review adequacy:of Pilgrim Tecn =5pec on igh containment temperature;

( DSI/RSB)

.s w

3.

Determine acceptability of oscillations in safety related instruments; (OSI/RSB & ICSB)

This ' memorandum summarizes the results of work in RSS and ICSB qo date, provides I

-;;reliminary responses to the Task Interface 'greement action items and lists some possible short and lon'g-term solutions.

It is emphasized that the in-fornation in this memorandum is preliminary since the review is not complet3,. A report dealing with the problem which was prepared for the BWR Owriers was ob-tained from General Electric on"i2/31/81 and has been givekonly a cursory review I

s thus far.

Detailed discussions with General Electric personnel vlfil be held after staff review of the GE rcport.

4

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II. BACKGROUND As the-result of the TMI-2 accident in March 1979,'both the staff and industry

+

have reviewed the adequacy of level detection instrumentation under accident conditions.

In April,1979, IE Bulletin 79-08 (reference 3) requested information from each licensee. on ves,sel level indication.

IE Bulletin 79-21, "Temperatu' e i

Effects on Level Measurement" (reference 4) was issued in August,1979.

This bulletin addressed errors in steam generator water level resulting from hichenergylinebreaks,includingLOCA,insidecontainmentandconsequentiai i

high containment temperature which caused temperature increases e.nd possible flashing of water in the reference leg of the level indicator.

The problem was identified in a Westinghouse letter of June 1979'. Although the bulletin required actions from PWR operators, it was also sent as information to all BWR operators.

A staff letter (reference 5) addressing this problem was sent to all BWR licensees in July 1979.

In July,1979, General Electric notified its customers of false level indication caused by high temperatures and.possible flashino of water in the reference legs of Yarway level instruments under post-LOCA conditions (reference 6).

In September,1980, General Electric again notified its customers of the importance of compensating for these false level indications in Yarway instrurients and described false level indications in cold reference leo instruments caused by flashing in the sensina lir.es (reference 5).

i A staff review and evaluation of level instrumentation errors for SWRs, basec on a review of GE information provided in Aucust 1979 in NED0-24708 (reference

7) is presented in NUREG-0626 (re'ference 8).

4 i

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i-Additional information on the safety significance of errors 'in or total' loss I

of level indication was provided during 1980 in NEDO-24708A (reference 9) and i

NEDO-25224 (reference 10). Some current information is available in the proposed i

ll emergency procedure guidelines for BWRs which are presently under staff review (see reference 11 and recent revisions) and in the Shoreham docket (referes.ce 12).

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WATER LEVEL INSTRUMENTATION All level measurement systems in BWRs employ differentia 1 ' pressure transmitters, a reference leg connected to a condensing pot and in turn to the reactor vessel steam space, and a variable leg connected to the vessel at a lower elevation.

Several differential pressure cells share common impulse legs.

Temperature Those level measure-ccmoensated and uncog.pensa,ted reference legs are employed.

ment systems which use a temperature compensated reference leg'are called Those level measurement systems which use an uncompensated reference Yarways.

leg are called cold leg instruments or, often, GEMAC.

BWR 1, 2, 3 and some d's use two redundant Ya'rways to ge'nerate engineered safety feature actuation signals and cold reference leg instruments for indication and control. The remaining BWR 4's and all 5 and 6's use redundant cold reference leg systems exclusively.

4 O

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. 1 4

1 A.

Yarway (Heated Reference Leg) Instrument A schematic of a Yarway level detector is presented in Figure 1.

Steam condens'ed

• in the condensing chamber maintains the reference legIwater. level by overflow to the variable leg. The condensate heats the variable leg which, in turn, heats the reference leg. A thermal shield is provided to reduce heat loss to containment

~

- and to maintain relatively high reference leg temperatures.

For short column Yarways,

metal clamos have also been used to improve heat transfer between the legs.

Information in reference 9 indicates that the reference leg temperature is roughly equal to local containment temperature plus 40 percent of the difference between reactor steam temperature and. local containment temperature.

For example, a local containment temperature of 135*F and steam temperature of 546* (Tsat at 1000 psia)

~

would ' result ip a reference leg temperature of 300* F. '

The sens ng lines leading from the Varway to the differential pressure cell outsidh of the drywell are 1" schedule 80 stainless steel piping.

Flow in these lines is blocked by the differential pressure cell.

During normal operation, the stagnant water in these lines should be approximately at local conta1nment temperature.

If the lines are installed close to each other in containment,.they should have

~

i about the same elevation change and local temperature, Hence, the effects of water density 'ariations along the lines should be cancelled and have a minor effect l

v on level measurement.

The Yarway level detector, which measures the collapsed water level in the outer annulus region of the reactor vessel, is subject to a number of uncertainites.

Those resulting from differences between actual and assumed values of average coolant density in the annulus (affected by system pressure, subcooling and carryuncer) were shown to be small in reference 9.

However.in 1979 the General Electric Company identified rather large uncertainties associated with nigh reference leg temperatures that could occur under some accident conditicns (steam line creaks) for whicn local containment temperatures up to 240*F are predicted.

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The high reference leg temperatures would result in false high water level signals.

,In addition, a constant indi~cated lower water lev'el cbuld be reached even though 1

1 the actual water level has dropped well below the low level. tap at the reactor I

i vessel.

Hence, GE recommended that its customers review calibrat' ion of the Yarway instruments, increase certain trip points and take other corrective actions to com-g pensate for this effect.

High containment temoerature combined with reactor depressurization can also lead to false wa'ter level readings because of flashing or boiling in the reference leg L

or the sensing lines within containment leading to the differential pressure sensor.

Flashing in the lines might occur during depressurization if the local containment H

l temperature exceeds the saturation temperature corresponding to vessel pressure.

Flashing, in the reference leg might be expected earlier in the transient because of the higher. initial temperatures in the reference leg.

The GE communication of 1979 was

)

concerned only with the effects of flashing in the reference leg of Yarway instruments.

Apparently, flashing in cold reference. leg instruments was considered to be of minor importance at the tine.

In a later communication (September 1980), fiashing in the sensing lines of cold reference leg instruments was also considered.

Flashing in the reference leg or lines could occur during normal system depressuriza-tien in oreparing for initiation of RHR cooling or under accident conditions ~.

During the c sid:wn event a: Pilgrim on 9/26/S1 (see reference 1),' flashing of the reference legs in the Yarway' instruments was indicated by several oscillations in the level readings.

At the time, the reactor coolant temperature was 220 F and peak local I

containment temperatures were about 240* F. ' Under accident conditions such as a steamline break, local centainment temperatures can reach 340 F.

Hence, when vessel i

pressure drcos below about 112 psig (p at 340* F) flashing could occur in the sa lines.

If it is assumed that the reference leg temperature rapidly increases to the steady state value for a containment tenperature of 340*F and RCS temoerature of I

l 546 F. flashinc in the reference leg micht cccur wnen vessel pressure crees belew l--

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Another scenario involving flashing in the reference leg could occur for larger f

breaks and times such that the vessel pressure is about equal. to containment pres-In this case, as discussed in reference 13, the rapid reduction in containment sure.

l pressure following initiation of the containment spray, combined with the delay in Tests

~

duction 'of metal temperatures, could'cause flashing in the reference leg.

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The were conducted to confirm that large errors in 1evel indication could occur.

solution to this flashing problem involved installation of a cooling jacket around the 1

reference leg which was supplied with water from the containment spray line.

Even without a break, loss of the non-safety grade containment coolers would cause the containment to heat up and could cause flashing upon depressurization.

With respset to the flashing problem it should be noted that there would be a time delay involved in the heating of the reference leg and lines under accident condi-A delay in heat transfer would be expected because of the relatively large tiens.

accunt of metal in the walls of the reference leg and lines and the relat,ively low beat transfer coefficients expected for surfaces in contact with the containment atmos-In reference 9, the thermal time constant for the Yarway detector was estimated phere.

This value may have been calculated assuming only high to be about 20 minutes.

For steam-air mixtures, the. condensation on cold surfaces results te oerature air.

j in appreciably larger heat transfer coefficients than those for air et the se e temp-It should also be noted that water expelled by flashinc in the heated erature.

reference leg and corresponding line to the differential pressure sensor may-not be replaced cuickly.

At the high containment temperatures and lower vessel pressure expected under accident conditions, the condensing chamber could cease to function.

Hence, refill would be delayed until sometime after the vessel water level increases Even under tnese cir-to a point above the tap leading to the condensing chamber.

cur: stances, boiling could occur for a while in the reference leg and lines as the re-In the case of cegraded core sult of centinued high local containment temperatures.

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~

cooling when water level remains well below the tap to? the condensing chamber and noncondensible gases and superheated steam could be present, there could be extended time periods with large false indications of vessel water level.

In fact, purging

- of the lines could be required to remove non-condensibles.

B.

Cold Reference Lea Instruments A schematic 6f a cold reference leg instrument is presented in Figure 2.

In this case, the reference leg upper level is maintained by overficw of condensate in the condensing chamber back through the tap to the vessel.

Water density effects and flashing in the lines within containment which lead to the differential pressure sensor could be of concern.

Changes of elevation in the lines inside of containment range I

from 1 to 40 feet in operating plants. Hence, flashing in the lines under accident conditions could cause false water level indications and delay in refill problems such as those discussed in Section A.

flashing in cold reference leg level instru-ment lines was recognized in the guidtlines developed by GE,(reference'll). This situation (loss of reliable level indication for both heated and cold reference leg

. detectors) was treated by operator instructions to initiate ADS and ECCS actuation to fill the vessel and overflow to the suppression pool via the S/R valves.

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I V.

RESPONSE TO SPECIFIC ACTION ITEMS:

^

1.

Review event to establish the generic licensing implications; All BWR vessel level instrumentation, to some degree, is susceptible to reference 1.eg flashing and consequential loss of level indication following rapid vessel depressurization such as observed at Pilgrim The generic EWR emergency procedure guideliner* include caution and action statements related to loss of level indication.

The suscepta-bility of the level indication system to substantive non-conservative errors during event sequences which include depressurization, and the

' adequacy of emergency procedures is discussed below.

2.[ReviewadequacyofPilgrimTechnicalSpecificationonhighcontainment temperature.

The Pilgrim Technical Specifications do not include drywell temperature as a lir.itino condition for operation. We believe such a specification would be crudent to prevent undue equipment aging. However, a LCO on the pre-acciden't drywell temperature will not orecluce post accident loss of vessel level indication.

3.

Determine acceptability of oscillation in safety related instruments.

Engineered safety feature actuation signals are generated using the following process variables:

High pressure core spray (HPCS) - vessel level or drywell pressure Low pressure core soray (LPCS)

- vessel level or drywell pressure to date,

• These guidelines are presently under re. view by the staff and are not, employed at Operating Reactors.

j I

Low pressure coolant injection (LPCI) - vessel level or drywell pressure Automatic depressurization system (ADS) - vesse1. level and drywell pressure

~

Containment Spray.(CS) - vessel level and drywell pressure.

Reactor Core Isolation Cooling (RCIC) - vessel level only.

~

Delays in initiation of engineered safety features.due to reference leg heatup and boiloff have been considered in response to IE Bulle' tins 70-0S The staff concluded in illREG-0626 th'at for all break sizes, the and 79-21.

reactor either depressurizes fast enough to allow timely initiation of the low pressure system on high drywell pressure, o'r the breaks are small enough that (at worst) ECC' functions occurred before the potential boiling of the reference leg fluid.

FUrthermore, ESFAS systems employ latching circuitry except on the ADS

/

level permissive to ensure that safety actions, once initiated, go to completion (IEEE 279).

Hence, concerns related to initiation accuracy for automatic safety systems due to reference leg heatup and/or flashing and concerns related to potential l

reference leg fluid oscillation have been previously and adequately addressed l

for design basis events; however, there are event sequences involving I

..altip.e equipment failure which will require manual i'nitiation of engineered safety features.

For some accident scenarios involving a break inside containment, adequate indication of actual vessel water level could be lost for all pertinent level instruments as the result of flashing and boiling in the reference legs.

The emergency guidelines (reference 11 and revisions) consider tne case

- i 4

where,the operator has recognized that vessel level cannot be determined.

For this case, the guidelines involve actions to deprbssurize the reactor and to refill the system until it overflows to the suppression pool via the S/R valves.

However, if the operator fails to recognize that he has

' lost level indication and has a false high reading of water level, he mbnt f

take action to throttle or stop ECCS systems in order to avoid filling steam l

lines or to reduce load on emergency power systems.

In this case, the flash-f f

ing or boiling in the reference legs could lead to operator actions prejudicial i

to. plant safety.

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V.

RECOMMENDATIONS Once we have received feedback from people on the distribu-These are preliminary.

~ tion list and met with the BWR Owners Group, they will be finalized.

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t A.

Short-Term Recommendations l

Operators should be warned that all level indication is susceptible to (1)

We are concerned that. operators may have been trained large inaccuracies.

to unduly depend upon cold leg instrumentation should. they recognize errors in Yarway reference leg instrumentation.

A cursory examination of plant procedures at Pilgrim 1 and Browns-Ferry show that concerns related to cold leg instrumentation inaccuracies have not been incorporated in their procedures. The operators may have been warned of these concerns by other mechanisds sdch as training sessions.

We believe that utilities are aware of potential water' level inaccuracies in Yarway and cold leg instrumentation based on staff review of GE docu-Early ments prepared for the staff and documents prepared for GE owners.

Later docu-documents recommended reliance on cold leg instrumentation..

ments warned that these instruments, depending on the plant specific in-We do stallation, might also exhibit substantive indicated level errors.

not know whether'or not these concerns and corresponding warnings and actions have been communicated to the control room operators.

Plant specific emergency procedures should be confirmed and/or modifiec to:

(2)

Clearly identify which level indicators in the control room employ (a)

Yarway reference legs and which employ cold reference legs, and direct the operator to the appropriate indicators.

Include procedures to help the operator decide when level instru-(b) mentation is to be mistrusted.

Relate specific drywell temoerature indication, readily and reliably available to the operator in the centrol room, to reference leg temoerature.

____-_____a

2

o...

(c)

Include procedures to help the operat'or recognize those plant -

conditions and observed instrument responses which indicate successful refilling of reference legs following flashing.

(3) Operability limits of the temperatare se.nsors used in (2)(b) above should be included in the plant Technical Specifications.

B.

Lono-Term Recommendations We believe that it is prudent to provide the operator with continuous reliable Event sequences have been identified during which reliable level information.

indication will bs temporarily lost.

This potential is addressed in the Hardware modi-

" emergency procedure guidelines now under review by the staff.

fications should be sought to address this problem.

he believe that operator recognition of loss'of accurate level information as The addressed in the emergency procedure guidelines is cumberseme at best.

operator is to relate indicated water level and drywell temperature using a Indicated table contained in a caution statement of the emergency procedures.

water level values beyond the ranges shown in the table are.to be mistrusted.

Automation of these actions and decisions seems in order.

l Should the operator decide that the water level indicators are to be mistrusted, the operator is to fill the vessel.

Supposedly reference legs would ultimately At some point in the event sequence, the operator should be previded refill.

with positive means to confirm that reliable water level indication has been This problem may not be adequately addressed in the emergency guide-restored.

line procedures which are presently under staff review.

Several potential plant modifications are being considered by the staff.

It is not our intent to dictate hardware fixes.1 Rather, we give the below recommendations as illustrations that reference leg flashing'is a tractable probl em.

(1)

Perform plant specific analysis of susceptibility of cold leg level in-strumentation to reference leg flashing and/or local heatup and corres-p,onding water expulsion.

Those plants which are designed with small vertical drops of reference legs inside the drywell should be satisfactory i

as designed.

(2)

Consider rerouting of reference legs to meet condition (1) above.

s

( 37. Install temperature measurement of the reference leg. Such measurements could be used to confirm operability following a drywell temperature excursion and subsequent cooldown. The measurement w,uld be of little use should high drywell temperatures be sustained.

~

(4)

Develop means to cool the reference leg by establishing flow wi. thin the leg. Two techniques have been suggested:

(1) the temporary opening of equalization valves and/or drain valves, and (2) pumping water with a 7

positive displa' cement pump. from outside the drywell, 'up reference lines I

anc into the vessel. Equalization and drain valves are local manual The valves.

They are hypothetically accessible following an accident.

drain lines are routed to the waste treatment system.

Fo'llowing vessel depressurization, reference leg flashing and subsequent vessel filling in accordance with emergency procedures, temporary opening of the valves could be used to ensure reference leg filling. No hardware modifications

~

would be required. Should a sufficiently large LOCA occur, or should an event sequence involving multiple equipment failure occur, such that the

s r

vissel cannot be filled above the reference leg taps, this technique 4

would be of little use. Pumping water up reference legs would ob-

+

viously reqJire hardware modifications. The flowrate need only be high enough to overcome the heat load on the reference legs inside the drywell under accident conditions. This techniq'ue would permit refer-ence leg filling even if high drywell temperatures existed and the vessel 4

could not be filled to the reference leg tap.

t (5) Develop means to cool the reference leg by using a coolant jacket and diverted ESF flow.

g 9

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REFERENCES 1.

Licensee Event Report 81-055/0lT-0,, "High Drywell' Temperatures".

Pilgrim Nuclear Power Station,10/15/,1.

7 8

2.

Task Interface Agreement, Task No. 81-21, " Pilgrim 1, Water Level Instrumen-

-tation Oscillation", October,1981.

~ 3.

IE Bulletin 79-08, " Events Relevant to Boiling Water Power Reactors Identi-fied During Three Mile Island Incident", April 14, 1979.

4.~

.IE Bulletin 79-21, " Temperature Effects on Level Neasurements.", August 9,1979.

5.

Letter from T. Ippolito, NRC to C. Reed, Commonwealth Edison Company, "Addi-tional Information Required for NRC Staff Generic Report on Boi, ling Water Re-actors", July 13, 1979.

~

6.

Telephone conversation with General Electric Company personnel, December,1981.

7.

NED0 24708, " Additional Information Recuired for NRC Staff Generic Report on Boiling Water Reactors", August,1979.

8.

NUREG-0626, " Generic Evaluation of Feedwater Transients and Small Break Loss-of-Coolant Accidents in GE-Designed Operating Plants and Near-Term Operating License Applications", January,1980.

9.

NED0 24708A, Revision 1, " Additional Information Required for NRC Staff Generic Report on Boiling Water Reactors", December,1980.

10.

NEDO 25224, "GESSAR Assessment Report, Review of BWR/6 Protection In-Depth for Transient and Accident Events", June,1980.

l l

11.

NEDO 24934, " Emergency Procedures Guidelines - BWRl-6", January,1981.

12.

Attachment to letter from B. McCaffery of Shoreha'm Nuclear Power Station to H. Denton, NRC, August 18, 1981.

i i

to Carl Berlinger, CPB, NRR, and Faust Rosa, ICSB/NRR, from N.

13.

Memorandum Kondic ICB, DF0, "Two Phase Fluid Water Level in Nuclear Vessels (Reactor SG, PZR),

November 23, 1981.

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'M' f',/f/) = ,/ i Ficure 1. Yarway (Heated Reference Leg) Level Detection Instrucment (FromtiED0-24708A) 6

3 . Ory wN W s // N Cai,Ja bsf, Va.s.se/ 'CA eo-. b e p N l a A fu < r ce Y~ % / Le2 ~# L 7 s e 1 8 d.otuce i gp '*P Cc// d i ? Va ria 4 4 43 Figure 2. Cold Reference Leg Level Detection Instrument

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.... ~ _ s l ENCLOSURE 5 1 l f I I --,-r,,, wy-.-- ,w- - - - -- -, +- - -,..,,,,...-- --.v --.---,-rw,-- e-

f t y ..e January 8. 1982 . Mi t ,A,. ~ ~ ~r.Jj_\\,

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v\\ Docket No. 50-341 7 'g The Detroit Edison Company l' f ATTN: Mr. Donald A. Wells i JAN ISUO2> -a Manager, Quality Assurance . At rrr-a 2000 Second Avenue ~ ~" ?. "' D +, Detroit, MI 48226 \\ ,3.. _,T .\\ e is Gentlemen: By. letter dated September.7,1981, Mr. James L. Matt requested that his letter of March 7, 1981, related to Inspection and Enforcement Investiga - tion Report No. 50-341/80-22 be made a public document. Region III has agreed to this request, and this letter is enclosed. To insure that the public record is compl6te, Mr.' Mat't's letter of September 7, 1981, our response, dated November 2, 1981, and a letter to Mr. Matt from Region III dated April 13, 1981 are also enclosed. You may want to attach these letters to your copy of the Investigation Report. No further action on our part is contemplated. s We will gladly answer any questions you may have regarding this action. Sincerely, l l l R. F. Warnick, Director j Investigation & Enforcement Staff

Enclosures:

1. Ltr to Foster fm Matt dtd 3/7/81 2. Ltr to Matt fm Foster l l dtd L/13/81 l 3. Ltr to Foster fm Matt. dtd 9/7/81 4 Ltr to Matt fm Foster dtd 11/2/81 ec w/encls: l DMB/ Document Control Desk (RIDS) l Resident Inspector, RIII Ronald Callen, Michigan i Public Service Commission Eugene 3. Thcmas, Jr., Attorney l RIII ~ RIII h 8 2 RFID VF/ 1 FVr'ev/fp Warnick l ,W t-S* 12

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h i / b NITED STATES o NUCLEAR REGULATORY COMMISSION y.. g REGION lil l J' ~ c no moossvaLT noAo %g.....,/ l GLEN ELLYN. ILUNol$ S0137 April 13, 1981 1 Mr. James L. Matt 1405 A Nolan River Road Cleburne, TX 76031

Dear Mr. Matt:

Thank you for your letter of March 7, 1981. While I try to perform as complete an investigation as possible in each case, the very nature of most NRC investigations make "thank you" letters rare and unique. Yours - is very much appreciated. Regarding your suggestions concerning " pre-dispositions" of Deviation Disposition Requests (DDR's), I am not sure that you understand the. system fully. Only those individuals who have signature authority and sign concurrences for DDR dispositions have any responsibility for the accuracy and acceptability of the dispositions involved. Under the Fermi system, even those contractor personnel who sign for the " field proposed disposition" do not have responsibility for the acce, illity of the final disposition. Utility personnel, as representativs. of !he " owner," have responsibility for all Code-related matters, and they have the ultimate responsibility for DDR resolution acceptability. Once an NRC investigation or inspection report is issued, it is not changed, and your requested addition to page twelve would not change the substance of the report. However, if you wish, we can make your letter a part of the public record by sending it to our Public Document Room and distributing it to recipients of the investigation report. This will be done -at your request only, as we have not previously used your name in a public document. Please feel free to contact me in the future. l Sincerely, l M James E. Foster Investigator cc w/lt: dtd 3/7/81: Paul Barrett Bruce Little 1 EEO!!"O'02-820108 FCR ACC K 05000'341 Q PDR

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s .t._ t a... s ( ~ ,, ~ s,, \\ ~ November 2, 1981 s b g ) s, s 3 f Mr. James L. Matt 1405A Nolan River Drive N f s f Cleburne, TX 76031 ~ \\ 's~

Dear Mr. Mat.:

h4 This enfers to your letter to ne dated.Septerber 7', 1981. As you requested your Iceter dated March 7,1981, to me trill recieve the same distribution 1 originally made of IE Investigation Report No. 50-341/80-22. In addition, =y letter to you dated April 13, 19S1, your September 7, 1531 letter and, this letter t:111 also receive the same distribution. If this is not in accordance with your trishes, planse notify me trithin seven days of the date of this letter. You =ay do so.by calling na collect at 312-932-2500. Renarding the subject of harnssnent, enclosed is a Upy' of Section 210 Employee Protection of the Energy Reorganization Act',,Public Lat: 95-601. This section prohibits discricinntory acts against employees be'cause they assisted in any action to carry out the purposes of the Energy Reorgani:stion Act or the Atomic r.nergy Act of 1954, as amended. The investigation of couplaints filed under d.' tis section are the responsibility of the Ecpar*.ent of. Labor. If you trish to file such a complaint, I suggest you contact the Depart =ent.of Labor office nearest you. Sincerely, \\. N James E. Foster v Investigator 2nclosure: As stated ~

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p\\ g 2 6 J A N 1982 30Ma ks MEMORANDUM FOR: Brian K. Grimes ] IS82sh Tb.~ES.$:R T: }E Director Division of Eme'rgency Preparedness C. M ~ N U..S. Nuclear egul t ry Commission 7 FROM: . Krl... ~ Assistant Associate Director Office of Natural and Technological Hazards

SUBJECT:

Interim Findings on the Offsite Emergency Preparedness for the.Enrico Fermi Atomic Power Plant, Unit 2 The Michigan State and the Monroe County and Wayn.e Courity site specific plans are still being screened by the Federil Emergency Management Agency (FEMA), Region V, and the Regional Assistance Committee (RAC). An evaluation of planning standards A-P will be submitted to the Nuclear Regulatory Commission by March 15. 1982, following the RAC review of the plans and the evaluation or tne recruary 2,1982, exercise. Attached are the FEMA Region V interim findings and their letter of January 8,1982, to the State of Michigan. l Attachment I l l l s Effy3Gi-;e 520126 ,/ 5 =CF Acccx 0"CCC341 3DR LL!

l CR9925 i FEDERAL EMERGENCY MANAGEkSENT hGENCY Region V Federal Center r l Battle Creek, Michigan 49016 JAH 2 1 1922 r ll JuBZ li 43r M&ORANDUM FOR: Acting Chief, Natural and Technological Hazards Division j Attention: H. Gaut, Technological Hazards Branch l I FROM: Regional Director, FDA Region V l

SUBJECT:

Interim Report - Enrico Fermi Atmic l Power Plant, U:.it 2 1 In response to your request, attached ar's tneTnterim Findings of ~ l State and local readiness for off-site radiological emergency preparedness for the Enrico Femi Atmic Power Plant, Unit 2. An evaluation of planning' standards will be submitted as part of this Interim Report once the Regional Advisory Comittee has cocoleted its review of the recently subciitted.tnroe and Wayne Counties local off-site plans and an evaluation has been completed of the Enrico Femi Atomic Power Plant. Unit 2 scheduled for February 2,1982. The State will be notified of a 30-day period from receipt of the RAC plan review and the post-exercise evaluation in which to ccrnent [ on any deficiencies. i s

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1,_ dann T. Anderscn Etta C."C.en t t,

i r.-: L '- Federal Emergency Management Agency ~ Region V 300 South Wacker,24th Floor, Chicago, IL 60606 (312) 353-1500 l January 8, 1982 Captain Peter Basolo, Deputy DI. rector of Emergency Services Dept. of State Police' 111 So. Capitol Ave. 2nd F1. Lansing, Michigan 48913

Dear Captain 3asolo:

The Federal Emergency Management Agency (FEMA) has requested an interim report on the planning status for Enrico Fermi-Atomic Power Plant, Unit 2. Interim findings may be based on any stage of preparedness rangi=g , from an untried paper plan to a state of preparedness which except for the formalities of the process, could satisfy the condition of 10 CFR 350. The enclosed document is the interim report on Enrico Fermi Ato=ic Power Plant, Unit 2 prepared by FEMA Region 5 staff. l An evaluation of planning standards A-P will be submitted as part of this interim report once the Regional Advisory Co::nittee has ce=pleted its review of the recently submitted Monrot and Wayne Counties local 1 site specific plans and an evaluation has been completed of the Enrico Fermi Atomic Power Plant, Unit 2 scheduled for February 2, 1982. A=y co=ments you may have on this interim finding should be sent to Mr. Dan Sement by February 5, 1982. Sincerely yours, A Q ku2p John T. Anderson Regicnal Director Attach =ents

~ i ~ INTERIM FINDINGS FOR ENRICO FERMI NUCLEAR POWER PLANT, UNIT 2 0FF-SITE RADIOLOGICAL EMERGENCY _ PREPAREDNESS . I. Introduction 1. This document constitutes an interim finding prepared by the Federal Emergency Management Agency (FEMA) Region V on the adequacy of radiological emergency preparedness of the state and local governments within Region V that would have to respond in the event of an accident at the Enrico Fermi Atomic Power Plant, Unit 2. Enrico Fermi Atomic Power Plant, Unit.2 is located in Frenchtown Township approximately 6 miles NE of Monroe, Michigan and is on the western shore of Lake Erie. The plume exposure pathway Emergency Planning zone (EPZ) out to ten (10) miles includes parts of Monroe and Wayne Counties in Michigan and the Southern tip of Essex County, Canada. The affected population within the 10 mile EPZ is 64,546. The ingestion pathway EPZ (50 miles) includes portions of Canada...a,Il af Monroe and Wayne Counties, part of Macomb, Oakland, Livingston, Washtenaw, Jackson, Lenawee, and Oakland Counties in Michigan. As well as-Erie, Fulton, Lucas, Ottawa, Sandusky and Wood Counties in Ohio. The principal technical and planning organizations involved are: The Division of Emergency Services, Michigan Department of State Police. Monroe City / County Office of Civil Preparedness Wayne County Office of E=ergency Preparedness 2. The state plan'and site specific plans for Big Rock Point, D.C. Cook, and Palisades were initially prepared by state and local officials using NUREG 0554/ FEMA REP-1 Interim as a guide. Tbese plans were informally subnitted on. April 21, 1980, for screening by FEMA and the Regional Advisory Committee. The results of this screening was provided to state and local officials in Lansing, Michigan on May 13, 1980. A fuit scale exercise was conducted on June 24, 1980, to test the state plan.and Charlevoix and Emmett Counties site specific plans for Big Rock Point Nuclear Power Plant. Subsecuent exercises to test the state plan and site specific local plan for D.C. Cook and Palisades was conducted on October 9, 1980,~and December 9, 1980. On February 25, 1981, the Director of the Emergency Services Division, Michigan Department of State Police formally submitted to FEMA Region V for the Regional Director review of the state pian and loc:1 site speci.fic plan fcr Big Rock Point, D.C. Cook, and Palisades Nuclear Power Plants. The Regional Director review is currently in process. ,e-r.m,--9 m --n,wy-wwwa +w.- 4,,---w,,- -,--me--,- y, u-,,e,- =r v - = - - - v.--.m-,,,---4 mm-s- -r

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The state plan, Monroe and Wayne Counties site specific plan for Enrice Femi Atomic Power Plant, Unit 2. was submitted to FEMA Region V for screening by FEMA Region V and th'a Regional Advisory Committee on November 19, 1981. The state and local site specific plans were prepared by state and local officials using NUREG 0654/ FEMA REP-1 revi:ed as a guide. Screening of the state plan and local site specific plans for Enrico Femi ' Atomic Power Plant, Unit 2 is still in process by FEMA Region V and the Regional Assistance Comittee.- A full scale exercise to test the state plan and local site specific plans for Enrico Fermi Atomic Power Plant, Unit 2 is scheduled for February 2, 1982. Public official conference and training drills are scheduled during January to prepare state and local officials for the February 2nd exercise. A significant political event concerns the Emergency Classification system. Temporary rules were initially adopted so that the emergency classification system.used by_ the state and local governments would be consistent with that of the utility. These temporary' rules when fomally considered during the sumer of 1981 were not fomally adopted. Inquiries with the state has not clarified what Emergency Classification system Michigan follows. 3. Materials available for examination that'fom the basis for the findings presented in this document and available for examination include the following plans: Michigan Emergency Prepardness Plan includiilg Radiological Emergency Response procedures. Monroe County Emergency Operation Plan, Appendix 1, Nuclear Facility procedures. Wayne County Emergency Operation Plan, Appendix 1 Nuclear Facility procedures. II. Evaluation Screening o'f the state and local site specific pians for Enrico Femi Atomic Power Plant, Unit 2 is still in process of screening by FEMA Region V and the Regional Advisory Ccmmittee. An evaluation of planning stancards A - P will be submitted after the Regional Advisory Comittee has completed its screening of the state and local site specific plans and an evaluation has been completed of the February 2,1982, exercise.- III. Schedule of Correct' ions Expected date for development of'a schedule of Correction for specific deficiencies is expected to be deveicoed in March, 1982. I

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1. s# ***%'o UNITED 5TATES g

U E ' NUCLEAR REGULATORY COMMISSION REGION Ill

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k 8 799 ROOSEVOLT ROAD ' A f4 GLEN ELLYN. 6LLINOIS 80137 } g g***** p If t-March 3, 1982 r? .f.;.- e e -c 4 n. -li: s Docket No. 50-341 l-6 M t .n </;. n The Detroit Edison Co=pany ATIN: Mr. Donald A. Wells (.~ y? Manager, Quality Assurance 4 2000 Second /, venue Detroit, MI 48226 Gentlecen: This refers to the routine safety inspection conducted by Messrs. M. P. Phillips, P. R. Pelke, and Dr. M. J. Oestmann of this office on February 1-3, 1982, of activities at the Fermi Nuclear Power Station,t.* nit 2, authorized by NRC Construction Permit No. CPPR-87 and to the discussion of our findings with Messrs. W. H. Jens, H. Tauber, E. P. Griffing, and others of your staff at the conclusion of the inspection. The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective excmine.tien of procedures and representative records, observations, and in-terviews with personnel. No iters of ncncompliance with NRC raquire=ents were identified during the course of this inspection. Certain aspects of ycur emergency plan, which include persennel account-l ability c.nd site evacuation, were not tested during this exercise. It will i be necesscry to test these procedures in a drill prior to the issuance of I your operating licansa. Please notify this office prior to this drill. In accordcne with 10 CFR 2.790 of the Cc==issien's re p icticas, a copy of t this htter ;nd the enc ~osed inspection report will be placed in the NEC's l Fn-lic L: cur an Roc =. If this report contains cny inferriatica that you (or your centrac.: ors) believe to be exe=pt fro: disclosure under 10 CTR 9.S(a)(4), it is necess try that you (a) notify this office by telephone within ten (10) days frc the date of this letter of your intention to file a request for withholding; and (b) sub=it within twenty-fiva (25) days from the date of this letter a written application to this office to withhold such information. If your receipt of this letter has been delayed such that less than seven (7) days are available for your review, please notify this office pro:tptly so that a new due date.tay be established. Consistent with Section 2.790(b)(1), any Onenne n -r,

>_/

T 4 L/ / p / Q./ / / 0__

' op Detroit Edison Company 2 March 3, 1982 such appifcation must be accompanied by an afildavit executed by the owner of .the information which identifies the document or part sought to be withheld,' and which contains a full statement of the reasons which are the bases for the claim that the information should be withheld from public disclosure. This section further requires the statement to address with specificity the con-sider,ations listed in 10 CTR 2.790(b)(4). The information sought to be withheld shall be incorporated as f ar as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, a copy of this letter and the enclosed inspe'ction report will be placed in the Public Document Room. We will gladly discuss any questions you have concerning this inspection. Sincerely, t 6 . A. Idind, irettor Division of Emergeacy Preparedness and Operational Support

Enclosure:

Inspection Report No. 50-3!.1/82-02 cc w/ encl: l DMS/ Document Control Desk (RIDS) Resident Inspector, RIII i Renald Callen, Michigan ( Public Service Cc=missien Harry }i. Voigt, Esq. D. Sc=ent, FEMA Region V Ms. Sheila Baptie Rg RIII RI III I.I RI RIII

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I s i i l U.S. NUCLEAR REGULATORY COMMISSION l REGION III I e Report No. 50-341/82-02(DEPOS) Docket No. 50-341 License No. CPPR-87 Licensee: Detroit Edison Company 2000 Second Avenue Detroit, MI 48226 ~ Facility Name: Fermi Nuclear Power Station Unit 2 Inspection At: Fermi Site, Monroe,'MI Inspection Conducted: February 1-3, 1982 b k'xG J Inspecters: d.P.Phillip - 3[ 79 Team Leader '/ / [//, ,[ ( si, rs.w M. Destmann Y> 3 Y&~' 2e OS[ ulb I,h 3/t t ls t T P. R2 Pc n

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Approved By: L. Axcison, Chief Emergency Preparedness Section / / Q 0 .f 0 "5 )-' f J-C<'djPaperiello, ief Emergency Preparedness and Program Support Ersuch Ins c.c ;ian Su- ::-v Inscoction on Februarv 1-3, 1982 (Recort No. 50-341/82-02(DEPOS)) Areas Insoccted: Routine, announced inspection of the Enrico Fermf Atomic Power Plant emergency exercisa involving observatiens of key functions and locations during the exercise. The inspection involved 169 inspector-hours onsite by six NRC inspectors and three consultants. Results: No items of noncompliance or devictions were identified. i i g2n % 2 % n %% 1 l

o A. 1 ?..: i DETAILS = 1. Persons Contacted NRC Observers and Arear Observed P. Pelke; Operational Support Center (OSC), Fire Brigade, and Maintenance Teams

• T. Essig; OSC, Rescue Team, Inplant Health Physics Teams, and Seaway Hospital R. Schullcr; Control Room, Fire Brigade, and Joint Public-Information Center (JFIC)

G. Martin; OSC, Fire Brigade, and Radiation Environmental Monitoring Team F. Kantor; Control Room, Technical Support Center (TSC), and Emergency Operations Facility (EOF) M. J. Oestmann; Rescue Team and Radiation Environmental Monitoring Team B. Little; Control Room, Floater P. Byron; Controi Room, TSC, and Floater M. Phillips; Control Room, TSC, and EOF ~ Detroit Edison and,Ar,eas. Ob, served V. Jens, Emergency Officer, EOF M. Vermeulen, EOF Coordinator, EOF H. Tauber, Vice President, Engineering and Construction, JPIC E. Griffing, Emergency Director, TSC J. Clark, Nuclear Shift Supervisor, Control Room L. Trapp, OSC Coordinator, OSC E. Preston, Controller, Control Room P.. Sore: son, Controller, OSC S. Stadler, Controller, TSC E. Madsen, Controller, EOF The above personnel attended the exit interview on February 2,1982. 2. Licensee Action on-Previously Identified Items Related to Emergency Preparedness (Closed) 341/S0-07-02, Audit regarding the operation of the meteorology tower; 14;/60-07-05, Emergency planning - Paragraph 8; 341/00-07-07, Emergency Facilities; 341/80-07-03, Emergency Training; 341/30-07-09, Emergency Plan Implementing Procedures; 341/80-07-10, Review of Emer-gency Planning Program; and 341/80-07-06, County Emergency Plan. All of the above Open Items were identified prior to the Commissioc's enactment of rulemaking related to emergency preparedness in November 1980. These items are considered closed, as the detailed review of the licensee's emergency preparedness program will be examined during the emergency preparedness implementation appraisal. Offsite preparedness will be reviewed by the Federal E=ergency Management Agency (FEMA). J. -s- +

i-3. General An exercise of the licensee's Radiological Emergency' Response Plan was conducted at the Enrico Fermi Atomic Power Plant on February 1-2, 1982, testing the integrated responses of the licensee, State of Michigan, Province of Ontario, and local organivations to a simulated emergency. The axercise tested the licensee's response to a major noble' gas release. Attachment i describes the scenario. The' exercise was integratcd with a test of the State of Michigan, Province of Ontario, Monroe County, Wayne County, and Essex County Plans. 4. General Observations n. Procedures This exercise was conducted in accordance with 10 CFR 50, Appendix E ree.uirements using the Enrico Fermi Atomic Power P.lant, Unit 2 Radiological Emergency Response Plan (RERP), and the Emergency Plan Implementing Procedures (EPIPs) used by site and corporate personnel. b. Coordination The responst. was coordinated, orderly, and timely. If the event had been rea;, the actions of the licenses would have been suf-ficient to permit State Provincial, and local authorities to take appropriate protective actions. l c. Observers ~ l Licensee observers monitored and critiqued this' exercise along with nine NP.C cbservers sud approxicctely 25 FEMA observers, FEMA observed and will report on the responses of the State and l Iocal gevarnments. d. Critious The license.e held a critique i= cdiately folicwing the exercise the evening of February 2, 1982. The NRC cud the licensee iden-

fied the deficiencies as discussed in the exit' interview.

S. Specific Deficiencies Noted Proble=s identified by the NRC observers during the exit interview included: (1) poor turnover of con =and and control from the Nuclear Shift Supervisor to the Station Superintendent in the Control Room; (2) offsite ce==unicator was unable to make notifications in the event l her listed phone nu=ber was inaccurate, cad appeared to lack knowledge cencerning the significcace of events; (3) poor preplanning by main-tenanca, rescue, and health physics personnal; (4) information flow regarding offsite activities was lacking in thet the licensee was not i 3

~.. ?... 4 kept informed of actions taken by the State; and (5) at the time of General Emergency declaration, no default protective action recommenda-tions were immediately given, rather these recommendations were.dclayed until offsite dose calculations had been completed. In addition to the above deficiencies, the observers noted that additional training of emergency personnel with regards to health physics activities is needed. This area will be reviewed during the I=crgency Preparedacss Impicmentation Appraisal. 6. Specific observations a. Centrol Room The operators responded well to cues, and made proper and timely classifications. The information flow into and out of the Control Room was adequate, and emergency operating precedures were referenced'and followed. The exercise scenario tested the operators' ability to correct plant malfunctions, and provided.a good technical test of operations personnel, who performed well. The actions of the Station Superintendent-upon his arrival in the Control Room did not appear realistic. Although the RERP does not require the Station Superintendent to become the Emergency Director until an Alert is declared, he is still tbe one individual with overall respensibility for Termi cperations. This is delegated to the Nuclear Shift Supervisor in his absence, but once the Station Superintendent arrives in the Control Roem, he should assume the function of E=crgency Director regardless of what the emergency classification is. Requiring the Nuclear Shift Supervisor to centinue in this responsibility places an unnecessary restriction en his ability to operate the plant end mitigate the consequences of the event. This is especially necessary when operating with =inimum required shift crew. Events were classified and notificctions to the State'and local agencies were made in a timely manner; however, the offsite communications callar was unable to reach the SRC Headquarters l Operations Center and the Sandwich Ve=t Police Department due to incorrect telephone numbers in the e=crgency phona directr.y. Although the licensee's contact with the Sandwich West Police Depart =ent in Essex County, Ontario, would have been strictly a one tira notification at the Alart leval which would not involve protective action recommendations or activation of the pro =pt public notification system, additional efforts (such as checking with the local directory assistance operator) should have baan taken by the offsite notifications caller. The licer.see did contact the NRC through tha Regional Office. Since protective action autherizatiens and the principal cc=sunications ficw for Essex County co=es through the Provincial authorities in Toronto, who were in contact with the State's On Scene Emergency Operations Center as described in their plcn; and since the NEC was notifiad 4

through the Regional Office; the inspectors determined that these notification problems would.not affect the public health and safety. In addition, installation of backup communications equipment such i as the dedicated Emergency Notification System (ENS) between the ; e licensee and all necassary offsite agencies has not been completed. This equipment will be examined during the Emergency l'reparedness - Implementation Appraisal. The offsite notifications caller did not appear knowledgeable concerning the meaning of events. Once an actual emeraancy noti-fication has been made with the NRC, tha communicator is required to re= sin on the phone until instructed by NRC to hang up. During . this time the transmission of technical information should be conducted by a licensed operator or some other individual familiar. with plant operations, normal parameter readings, and the events taking placc. b. Technical Support Center (TSC) Activation of the TSC was orderly and timely, since the TSC was already in the standby mode. Commdnd and tontrol functions performed at the Tsc were very good. Tha TSC was continuously monitored for radiological habitability using a portable particulata, iodine, and noble gas monitor. TSC personnel i responded well to cues regarding mechanical, operational, and technical problems posed as part of tha scanario. Interface between the Emergency Director (ED) and other Key TSC staff was cxeclient. Ad=inistrative Support and Security in the TSC were excellent. Trend analysis *, especially for containment hydrogen cencentra ion, van good; however, there was no way to determine parameter trends from the status boards. When'psrcester values are updated on the status boards, an up or down arrow should be used to indicate whether the value is incres. sing or decreasing. The Emergency Direcror made timely and accarate emergency classi-fications. The assembly /evacuatier siren was activated shortly after the declaration of a Site Area Emergency; however, occountability of personnal was not tasted during this exerciso beccuse the 1,icensee hcs not i=plemented their security program. l j This must be tested in a. drill prior to fuel load. c. Cuerational Support Center (OSC) ( The OSC is the assembly area for health physics, da= age and rescde, maintenance, and fire fighting teams. The OSC was activated at the Unusual Event Classification by the damage and rescue team, and remained staffed for the duration of the exercise. The trcnsmission of radiation data between the OSC and TSC was excellent. Exposure control measures were excellent. Tea =s were afficiently hcadled, well directed, and coordination between the health physics and maintenance personnel was adequate. A.lthough some Piping and Instrumantation Diagrees (PLIDs) were 5 L

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~ I ?, j available at the OSC, teams did not have the appropriate drawing i to locate valve T46-F402. A complete set of P& ids should be I aveflable in the OSC. d. Emergency Operations Facility (EOF) ~ An interim EOF, located on the tu'rbine floor of Fermi Unit 1, was [ activated in accordance with the RERP in a timely manner. Admin-l istrative support, security, and personnel radiation monitoring at i the EOF were excellent. Command and control functions at the EOF were adequate, and it was clear who was in charga. Briafings of [ personnel regard 3ng updated plant conditions were frequently held, and all EOF staff were kept informed of events as they occurred. The interchange of information within the EDF was very good. Status boards and maps were updated in a timely manner. Infor-mation was transmitted to the State and NEC in a timely manner; however, the State iepresentative in the EOF could have been better utilizad! When the EOF Coordinator had difficulty in reaching the State EDC to inform them of the General Emergency dociaration, the Stato representative was not Laformed and asked to make this notification. There was no meaningful exchange of protective action information from the State EOC to the EOF. The EOF managers were continually being surprisad by Stata actions, learning about them after the fact. The Radiation Protection Coordinator did not communicate directly'with the State Depart-ment of Health dose assessment personnel, instead infor=ation was passed through co=municators. This could lead to the possible transmission of misinformation. No default protective action recommendations were given to the State when the General Emargency daclaration was transmitted, since no offsite release had occurred. Since a General Emergency by dnfinition mecns that releases can be reasenchly expected to exceed protective action guidelines offsite, the licensec should .recom= cad sheltering for a two mile radius and five miles dcwnuind as a mini =um for any General Emergency classification, sven if no release is taking place. a. Joint Public Infor=ction Conter (JPICJ .ne arIC was establinhad in the student services-caninistration building at Monroe County Co=munity College. News briefings were well coordinated, and were held in a timely manner. Detroit Edison previded the Vice President for Engineering and Construction as the technical spokesperson. The layout of the facility was very good; however, if this had been a real event some problems with the setup for live radio feeds and television camera hookups would have existed. In addition, the number of security guards initially prenent at the JPIC was excessive. On two occasions, the Detroit Edisen spokesperson did not appear at the news briefing. Although this had been agreed upon by all the news presenters, the lack of 6

a the utility spokesperson at the brief'ing can give a negative not activated until after:a Site Area Emergency.had been declared. ) impression to members of the press. The. rumor control number was i j In a real event, this group should be activated as soon as possible after an emergency condition exists. e 1 f. Environmental Monitoring., Teams The environmental monitoring teams were assambled in a timely mannar at the Newport Service Cantar, and briefed prior to dispatch. Record keeping, data transmission, and radio communi-j cations vara handled well. Due to the severe snow conditions, i team transportation consisted of four-wheel drive vehicles equipped with radios which were not on the same frequency as the EOF base stucion radio. The licensee implemeuted a telephone patch cor.ncetion with another base station, and communications l capabilities between the teams and the Radiation Protection Coordinator at the EOF were not compromised. The teams should have be.en kept better Laformed of events concerning the plant i which could affect them. Teams were not notified of the General Emergency condition. Team members.kept truck.of their own exposure. J Team members demonstrated a lack of consistency in the way offsite surveys were conducted (e.g., probe out.wida window, probe inside vehicle with window down, probe inside vehicle with windou up) and did not make any beta-gamma readings to determine whether or not they were in or out of the plume, or whether the plume was overhead. In addition, no offsite radiciodino analysis was conducted. Since the release was cccurring thrcugh the standby ges treatment system (S3GTS) which normally fil.tcrs out iodine, the Radiation Protection Coordinator did not request that any radiciodine samples be col-lected. This is an errenceus assu=ption, since the air flcwing through the SEGTS contains lots of moisture and is at a flew rate significantly greater than normal. Both of these conditions will significantly reduce the capability of the SEGTS to remove radio-iodinas, and therefore, offsite samples should always be collected to confirm the conclusions reached regurding radiciodines in tha release. These problems indicata that more training is needed to. enhance the efficiency of the of fsite teams. g. Dnsite Health Physics Tects The health physics teams were essc= bled in a ti=ely menner and dispatched from the OSC. The persennel menitoring team, which was activcted at the ti=e the assc=bly/cracuation siren was sounded, did a good job of setting up.

• dowever, the overall training of tha health physics teams needs to be improved based on the following observations:

(1) poor choice of instruments for surveys; (2) poor noble gas sampling technique; (3) failure to continually previde health physics coverage for all teams; and (4) never verifying the source of radiation levels observed. 7

c s ?. ; w Onsite surveys were conducted using an RO-2A rather than a. tale-tector. This requires the individual performing the survey to go into a potentially hiah dose rate area rather than just inserting the probe, and as a-result the team member may receive a relatively high unnecessary exposure. One team attempted to collect a noble gas sample by waving a marinelli beaker around in the air..An evacuated gas marinelli beaker mu'st be used, otherwise the results will be greatly underestimated. On one instance, a maintenance team was dispatched to look at a valve in the SEGT system in the Raactor Building. Since a survey of this area had just,been completed, the team decided that they did not need health physics coverage. This assumption can never be made during an ' accident, as plant conditions are constantly changing..-Had this team been present in the area fifteen minutes later, they would have received excessive exposures from the release due to the time. delay in being notified by the Control Room. At no time did observed health physics teams take any beta gamma readings to see if the radiation' levels detected could be due to the presence of noble gases. This is a very useful technique for determining possible leakage into the rnactor building. Training of health physics teams will be examined during the Emergency Preparedness s Implementation Appraisal. h. Personnel Injury Drill Tha damaga and rescua team was assembled within five minutes of being notified to activate. The initial actions of most team members were to dress up in protective clothing and proceed to tha raported location of the injury; however, one indivi' dual dened gloves and shoe covers only then ran to the injury location without any radiation survey instruments. None of the team members discussed what actions may be necessary, e.g., preplanned activities. Seceuse acergency situations can involve a sudden change in normal radiation or contaminatien levels, radiation survey equipment must be used by the first individucl to arrive at the site of the injury and actient to be taken should be planned prior to entering the aren. Transport and first aid provided to the patient were adequete. Team members and the patient were cenitored for contacination; h:vaver, the cont==instion icvels detected en the patient were very low, and did not warrant offsite deccntamination. Conta=ination and personnel =onitoring activities performed at thn hospital were good. Decontamination and treatment of the patient was handled well. 1. Fire Drill The fire brigsde was activated in a very ti=ely manner and reported to the OSC. They were told the location of the fire, but were not told conditions which could ha expected, such as 8 O .w-g -,_y w +

a 4 general area radiation levels'. None of the brigade members referred to the fire pre plans to datarmjna what type of fire may be encountered. Offsite fire assistance was requested,. notified by the Control Room, and arrived at the. scene in a timely manner. Fire fighters did a fairly good job in exchanging e scott air packs; however, communications among brigade members were extremely difficult. The plant fire brigade has good equipment, but a chemical foam capability would be particularly useful in ecmbating oil and large electrical fires. 7 Exit Tntarview Tha innpactorn held an exit intarview at tha conclusion of the licensee's critique with representatives denoted in Paragraph 1. The licensma agraad to addrass the inspactor's concerns statad in Para-graph 5. The licensee was asked to conduct a site assembly drill to test pnrsonnel accountability and sita evacuation precadures prior to l licensed operation. This is an Open Item (341/82-02.01). i

Attachment:

Exercise Scenario s i 4 1 l 9

k' .s y ?... 10.0 EXERCISE SCENARIO ~ INITIAL CONDITTCf i The reactor has been operating the equivalent of 300 full power days since refueling and is currently at 50% power. The Loose Parts Monitoring System is alarming. Alarms are indicating an abnormality in the vicinity of the Reactor Recirculation Pump 'A' discharge flow element. The RHR Division I check valve inside the drywell failed a routine test and is suspected to be jammed against its seat.in the closed position (Ell-F050A). The Nuclear Shift Supervisor has declared Division I of RHR inoperable and has seven days to i repair per the Technical Specifications. i Plant management has decided to bring the plant down for inspection of the RHR piping inside the Drywell. The Drywell is being deinerted in preparation for the planned shutdown. Electrical load is being reduced.at a controlled rate. The Nuclear Shift Supervisor has received a' call from the System Supervisor requesting that Fermi 2 temporarily remain at 50% load because of froren coal problems at th& Monroe Power Plant. Che. Nuclear Shif t Supervisor hi s ordered the control room opercter to continue to deinert, but not to drop any more ele'ctrical load until further notice. Tre RCIC is out of service for repair; it is not expected to be returned to service for another 72 hours. The Center Station Air Compressor is cut of service for required maintenance. The plant is operating with the reactor coolant system specific ~ activity at its Technical Specification limit of 0.2 microcurie /gm dose equivalent I-131. .;11 other plant systems are considered to be operable. l MITEOROLOGICAL CONDITIONS Initial and subsequent: As advised by controller. During radioactive release: Wind is from 200 at 7 mph. Stability is class "C". l l

.~ e e .. o SCENARIO TTME KEY EVENTS DAY I 12:30 p.m. Initial conditions. 12:45 operator notifies the Control Room that he has slipped and fallen in the Reactor Wator Cleanup Pump 'B' Room and is unable to walk. l approx. 1:00 UNUSUAL CVENT declared. 1:35 Fire alarm for 1st floor turbine building area northwest zone. I:45 Center and East station air. t compressors on fire. Off-site assistance required. l 2:45 Reactor feed pump controller fails l and drives feed pumps to high speed stops. 2:45 Main turbine trips on high reactor vessel water level and causes reactor scram. 2:50 Reactor foed pumps trip when reactor water level is at main steam-lines, i 3:15 Small steam leak in steam tunnel.- 3:35 MSIV's isolate on high area temperature. 3:36 SRV's lift. 3:40 One SRV ruptures and continues to releacc steam to drywell atmosphere. 3:50 Reactor water level is stabilized at normal operating level with HPCI operating. approx. 3:55 ALERT is declared. 5:00 Exercise secured for the day. l I

W .t.

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.D.A._Y_2 Exercise resumes] 7:00 a. n. 7:15 HPCI trips and isolates. 7:30 RHR systczn fails to inject water in reactor vessel. 7:35 Reactor core is unct.ne:vd. 7:40 Beoctor water level is re-established with Core SpIay Systt:m:s. 8:00 Contain: rent Area High Rance j Radiatien Monitor indicates i significant fuel d e. age has l ^~ occurred. I j apprcx. 8:00 SITE AREA D2:RGECf is declared. 1 s 10:15 Primary contairewant isolation valvo. i for SGTS fails and is open. 10:55 SGTS effluent renitcr indicata.s a release of raditactive c.aterial to the envirc:rient. approx. 11:00 GEERAL D*.haGECY is declared. 12:00 .Irb:>ard SMS prira f contai:r-ent i isolat.icn valve is shut. Release is tecd nated. 1:25 Off-site radiation levels return to backg:cun3. c3rcx. 1:30 n:nrgency is de-escalated. .t;prc>:. 1: 30 Rccove:j is initiated. -:00 Exercise is tc=.inated.}}