ML20058C897

Submits Request for Addl Info Re Proposed Emergency Action Levels of Site Emergency Plan for Plant

ML20058C897
Person / Time
Site:	Calvert Cliffs
Issue date:	11/17/1993
From:	Mcdonald D Office of Nuclear Reactor Regulation
To:	Denton R BALTIMORE GAS & ELECTRIC CO.
References
TAC-M87080, TAC-M87081, NUDOCS 9312020615
Download: ML20058C897 (16)

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November 17, 1993 Docket Nos. 50-317 and 50-318 Mr. Robert. E. Denton Vice President - Nuclear Energy Baltimore Gas & Electric Company Calvert Cliffs Nuciear Power Plant 1650 Calvert Cliffs Parkway Lusby, Maryland 20657-4702

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED EMERGENCY ACTION LEVELS OF THE SITE EMERGENCY PLAN, CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT I (TAC N0. M87080) AND UNIT 2 (TAC NO. M87081)

By letter dated July 20, 1993, Baltimore Gas and Electric submitted proposed changes to Calvert Cliffs emergency. action levels (EAls) for the staff's review and approval.

The NRC staff has completed its initial review of the proposed EALs and, as a result, a number of EALs were identified which require additional information in order to determine whether the EALs conform with applicable guidance and requirements.

The proposed EAls are being reviewed against the guidance in NUMARC/NESP-007, Revision 2, " Methodology for Development of Emergency Action Levels."

NUMARC/NESP-007 has been endorsed by the NRC in Regulatory Guide 1.101,

" Emergency Planning and Preparedness for Nuclear Reactors," as an alternative means by which licensees can meet the requirements of 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50.

Enclosed is the staff's request for additional information (RAI). We request that your response to the RAI, both the general comments and plant specific comments, be provided in a timely manner to allow the staff to complete its review.

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Mr. Robert E. Denton

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November 17, 1993 This request affects one respondent and, therefore, is not subject to the Office of Management and Budget review under P.L.96-511.

Sincerely, Daniel G. Mcdonald, Senior Project Manager Project Directorate I-l Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Enclosure:

RAI cc w/ enclosure:

See next page

4 Mr. Robert E. Denton Calvert Cliffs Nuclear Power Plant Baltimore Gas & Electric Company Unit Nos. I and 2 cc:

Mr. Michael Moore, President Mr. Joseph H. Walter Calvert County Board of Engineering Division Commissioners Public Service Commission of 175 Main Street Maryland Prince Frederick, Maryland 20678 American Building 231 E. Baltimore Street D. A. Brune, Esquire Baltimore, Maryland 21202-3486 General Counsel Baltimore Gas and Electric Company Kristen A. Burger, Esquire P.O. Box 1475 Maryland People's Counsel Baltimore, Maryland 21203 American Building, 9th Floor 231 E. Baltimore Street Jay E. Silberg, Esquire Baltimore, Maryland 21202 Shaw, Pittman, Potts and Trowbridge 2300 N Street, NW Patricia T. Birnie, Esquire Washington, DC 20037 Co-Director Maryland Safe Energy Coalition Mr. G. L. Detter, Director, NRM P.O. Box 33111 Calvert Cliffs Nuclear Power Plant Baltimore, Maryland 21218 1650 Calvert Cliffs Parkway Lusby, Maryland 20657-47027 Resident Inspector c/o U.S. Nuclear Regulatory Commission P.O. Box 287 St. Leonard, Maryland 20685 Mr. Richard I. McLean Administrator - Radioecology Department of Natural Resources i

580 Taylor Avenue Tawes State Office Building B3 Annapolis, Maryland 21401 Regional Administrator, Region I U.S. Nuclear Regulatory Commission i

475 Allendale Road King of Prussia, Pennsylvania 19406 Y

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+o OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF RADIATION SAFETY AND SAFEGUARDS EMERGENCY PREPAREDNESS BRANCH RE:

REQUEST FOR ADDITIONAL INFORMATION CONCERNING THE PROPOSED REVISION TO CALVERT CLIFFS NUCLEAR POWER PLANT EMERGENCY ACTION LEVELS TAC NUMBERS: M87080 and M87081

1. INTRODUCTION The NRC has completed its initial review of the proposed emergency action levels (EALs) in Revision 0 to the Calvert Cliffs Nuclear Power Plant EAL Basis Document.

The proposed EALS were reviewed against the guidance in NUMARC/NESP-007,

" Methodology for Development of Emergency Action Levels." NUMARC/NESP-007 has been endorsed by the NRC in Regulatory Guide 1.101, " Emergency Planning and Preparedness for Nuclear Power Reactors," as an alternative means by which licensees can meet the requirements in 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50.

Because of the staff's previous endorsement of the guidance in NUMARC/NESP-007, the review focused on those EALs that deviated from the guidance and those EALs that required the development of site-specific thresholds. As a result of the initial review a number of EALs were identified which required additional information in order to determine whether the EALs conform with NUMARC/NESP-007. Please provide this additionalinformation as discussed below.

GENERAL COMMENT

S A.

The licensee has referenced several Abnormal Operating Procedures (AOPs) and Emergency Operating Procedures (EOPs) that are not yet approved and implemented. Discussions with emergency planning personnelindicated that these would be approved and implemented prior to implementation of the revised EALs.

B.

Several EALs utilize thresholds based upon imolementation of a specific AOP or EOP. The licensee should define the term

" implementation" or " implemented".

111.

PLANT SPECIFIC EMERGENCY ACTION LEVELS - REV. O j

i A.

RADIOACTIVITY RELEASE i

1. RU2 - Unexpected increase in Plant Radiation l

e EAL 2 reads:

Valid Unexpected Rad Monitor Reading Offscale High OR 1000 Times Normal Reading for GREATER THAN 5 Minutes l

The licensee has included a 5 minute time requirement for the l

existence of the high radiation level to preclude emergency declarations for events such as resin transfers'or controlled movement of radioactive sources. However, these events are expected and, j

therefore, are explicitly excluded from this EAL without consideration j

to a time requirement. Thus, the time requirement is redundant and i

should be removed, or further justification for its inclusion should be l

provided.

2. RA1 - Unplanned Radioactive Release Exceeding 200 X Tech Spec j

Limits for AT LEAST 15 Minutes.

• NUMARCiNESP-OO7 initiating Condition (IC) AA1, EAL #3, states:

A valid reading on perimeter radiation monitoring system greater than i

10.0 mR/hr sustained for 15 minutes orlonger.

Calvert Cliffs has excluded this EAL from its classification scheme based upon the lack of a perimeter radiation monitoring system.

NUMARC's questions and answers on implementation of NESP-007, l

dated June 1993, states that "if an EAL does not apply because of its wording (e.g., valid reading on perimeter radiation monitoring system l

greater than 10 mRihr sustained for 15 minutes or longer), the licensee is expected to use other means, if available, for entry into the IC. In other words, for [this EAL), it may not be enough to state that j

this EAL does not apply because the licensee does not have a

-l perimeter radiation monitoring system. The intent is to use all i

available data to determine whether the IC should be entered."

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The licensee should determine if there are additional sources of i

information for evaluating entry into this IC (i.e., dose rates exceed 10 j

mRihr at site boundary for greater than 15 minutes), and include them j

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1 as applicable. Sources of information could include, but may not be I

limited to, field surveys.

This comment also applies to initiating condition RU1.

3. RA3 - Radiation increases That Impede Safe Plant Operation

• EAL 2 states:

Exposure Rate of AT LEAST 250 R/hrin Areas Required to Achieve or Maintain Safe Shutdown

• NUMARC/NESP-OO7 IC AA3, EAL #2, states:

Valid (site-specific) radiation monitor readings GREA TER THAN (site-specific) values in areas requiring infrequent access to maintain plant safety functions.

(Site-specific) list NESP-OO7 states that the site-specific value(s) should be based upon radiation levels which result in exposure control measures intended to maintain doses within normal occupational exposure guidelines and limits (i.e.,10 CFR 20), and in doing so, will impede necessary access. The intent of this IC is to show impeded access, not access exclusion. Thus, the 250 R/hr threshold in this EAL is non-conservative in relation to the intended threshold in NESP-007. The licensee should, therefore, reevaluate this EAL for an exposure rate threshold that corresponds to administrative limits for worker exposure control or provide further justification for the 250 R/hr value.

B.

FISSION PRODUCT BARRIER DEGRADATION

1. BU2 - RCS Leakage

• The Calvert Cliffs EAL is written as:

AOP 2A, Excessive Reactor Coolant Leakage, is implemented For RCS Leakage Exceeding the Capacity of O.ne Charging Pump AND Reactor Shutdown is Required e NUMARC/NESP-007 IC SUS, EAL #1, states:

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I The following conditions exist:

a. Unidentified or pressure boundary leakage greater than 10 gpm.

OR

b. Identified leakage greator than 25 gpm.

NUMARC's questions and answers on the implementation of NESP-007 states that "the threshold for [the Unusual Event] has been significantly raised from typically 1 gpm to 10 gpm unidentified leakage and 10 gpm to 25 gpm identified leakage. A leak of such magnitude is consistent with an Unusual Event and should be declared immediately. Credit for the action statement time in deferring an emergency declaration should only be given when leakage exceeds technical specification limits but has not yet exceeded the Unusual Event thrashold."

The licensee should eliminate the requirement for a reactor shutdown in this EAL or provide further justification for its inclusion. The licensee should also provide information on how their EALs address identified leakage.

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2. BU3 - Fuel Clad Degradation e NUMARC/NESP-007 IC SU4, EAL #2, states:

(Site-specific) coolant sample activity value indicating fuel clad degradation greater than Technical Specification allowable limits.

The standardized Technical Specifications for Combustion Engineering plants, dated September 28,1992, define RCS specific activity limits as:

A.

DOSE EQUIVALENT l-131 > 1.0 yCi/gm for greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, or 8.

DOSE EQUIVALENT l-131 in the unacceptable region of Figure 3.4.16-1, or C.

Gross specific activity of the reactor coolant :s 100/G pCi/gm.

e The Calvert Cliffs EAL is written as:

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Dose Rate at One Foot from RCS Sample of AT LEAST 6 mrem /h The licensee has developed a dose-rate-equivalent EAL based upon RCS sample activity that exceeds the lower limit of figure 3.4.16-1.

This adequately addresses the limit in Part B of the technical specifications, however, no EALs were developed for Parts A and C.

The licensee should develop EALs that address all the applicable technical specification limits or provide justification for their omission.

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3. FCB3 Radiation

• NUMARC/NESP-007 defines the loss of the fuel clad barrier, based r

upon Primary Coolant Activity Level, as:

Coolent Activity GREA TER THAN (site-specific) value in accordance with NESP-007, the site-specific value should correspond to 300 Ci/cc l-131 equivalent. This amount of coolant activity is well above that expected for iodine spikes during normal plant operation (about 60 pCi/cc) and corresponds to 2-5% fuel clad damage.

• Calvert Cliffs EAL 1 is written as:

Dose Rate at One Foot from PASS Sample of A T LEAST 40 mrem /h The dose-rate-equivalent EAL was determined from a PASS sample composition that corresponds to 1500 pCi/cc l-131 equivalent. The licensee justified this higher equivalent based upon the maximum iodine technical specification limit in Figure 3.4.16-1 of 270 Ci/cc

@25% of rated thermal power.

Although according to your technical specifications low-power conditions can produce higher iodine spikes in the RCS, the length of i

time the reactor operates in that range of thermal power where the limit for 1-131 is higher, represents a small fraction of total plant operating time. Also, as EALs are designed to address a range of plant conditions, thresholds must be developed that will also account for the more restrictive conditions within that range. Therefore, the licensee should reevaluate this dose-rate threshold based upon an l-131 equivalent activity level of 300 pCi/cc or provide further justification for the EAL as written.

4. RCB3 - Radiation l

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• Calvert Cliffs EAL for loss of the RCS barrier is written as:

Valid RI-5317A/B Reading of AT LEAST 5 R/h Within 2 Hours After Reactor Shutdown NESP-OO7 states that this monitor reading should be based upon an instantaneous release of the RCS noble gas and iodine inventory, associated with normal operating concentrations, into the containment l

atmosphere. The licensee does not reference any calculation as a basis for the 5 R/hr threshold in their site-specific EAL. Additional information should be provided by the licensee to support the 5 R/hr threshold.

5. CNB1 - Safety Function Status / Functional Recovery

• NUMARC/NESP-OO7 defines a potentialloss of the containment, based upon Critical Safety Function Status Tree (CSFST) monitoring, as:

Containment - RED

• Calvert Cliffs EAL based upon Safety Function Status Checks is written as:

EOP-8, Functional Recovery Procedure, is Entered AND Containment Environment Acceptance Criteria Can NOTBe Met The acceptance criteria are related to specific conditions as follows:

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Containment Environrnent Acceptance Criteria No CIS Containment isolated Containment Spray Containment pressure is less Containment pressure is less All available Containment than 2.8 PSIG than 4.25 PSIG Coolers are operating Containment temperature is Containment temperatures Containment Spray flow is less than 220*F and pressures are constant or creater than 1350 GPM per lowering pump, if operating Containment temperatures and All containment penetrations Containment temperatures and pressures are constant or required to be shut have an pressures are constant or lowering isolation valve shut lowering Containment radiation alarms All available Containment Air are clear (6)

Coolers are operating with Intentionally Blank maximum SRW flow 6

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Hydrogen concentration is Hydrogen concentration is less less than 0.5% 17) than o.5% (7)

OR OR l

All available hydrogen All available hydrogen l

recombiners are energized recombiners are energized with

. j with Hydrogen concentration Hydrogen concentration less t

less than 4.0% (7) than 4.0% (7) i OR OR 4

Hydrogen purge system is Hydrogen purge system is operating PER 01-41B, operating PER 01-41B, Hydronen Purce System Hydronen Purce System Ooeration (7)

Operation (7) i (6)

Not applicable while non-vital 480V Buses are de-energized.

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Hydrogen Concentration Acceptance Criteria may be omitted i

until Chemistry has been able to place the hydrogen monitors in i

service.

These acceptance criteria do not appear to be equivalent to the

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Westinghouse Containment RED path which defines a potential loss of the containment at containment pressures exceeding design pressure.

q The licensee should revise or dalete this IC or provide additional l

information to justify it as written.

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6. CNB4 - Coolant Leakage

• Calvert Cliffs EAL 2 for loss of the containment barrier is written as:

SG Tube Rupture in Progress AND Both of the Following:

• Affected SG Level Can NOT Be Maintained LESS THAN + 50 Inches AND e Affected SG Pressure GREATER THAN 900 PSIG -

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• NUMARC/NESP-007 EAL #4 for loss of the containment barrier l

states Release of secondary side to atmosphere with primary-to-secondary

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leakage GREATER THAN tech spec allowable.

In accordance with NUMARC's Q&As, the primary intent of this indicator is to address -steam generator tube ruptures (SGTRs) that constitute a loss of both the RCS and the containment barriers. This l

indicator should be used in conjunction with the SGTR indicators l

under the RCS barrier. The threshold for establishing the bypass of

. i containment was intended to be a prolonged release of radioactivity I

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from the ruptured steam generator directly to the environment. This can be expected to occur when the main condenser is unavailable to accept the contaminated steam (i.e., SGTR with concurrent loss of off-site power and ruptured steam generator b required for plant cooldown). When the main condenser is available, and no other pathways exist for release, the main condenser air ejector is, by itself, a path for release of radioactivity to the environment; however, it is generally a controlled and/or monitored path as the question notes.

As such, a SGTR, with release via the main condenser, does not meet the intent of a prolonged release directly to the environment and does not require the escalation of the event to a SAE via this EAL. Other examples of prolonged releases are (1) unisolable failure, outside of containment, of a secondary line on the ruptured steam generator, or (2) a stuck open relief valve on the ruptured steam generator.

The wording of this indicator sizes the primary-to secondary leak at rates greater than technical specifications (typically 1 cpm). The threshold for potentialloss of the RCS barrier during a SGTR is set at leak rates comparable with the capacity of a single charging pump. If a prolonged release occurs from a steam generator during a leak, only an Unusual Event would be declared based upon the potential loss of the containment barrier. If the steam generator was ruptured without -

a prolonged release occurring, an Alert would be declared based upon the potential loss of the RCS barrier. If a prolonged release is occurring or expected in conjunction with the SGTR, a Site Area Emergency is declared based upon the potentialloss of the RCS barrier and the loss of the containment barrier. Escalation may also be required if fuel damage were noted.

The licensee should provide additionalinformation on how they addressed the different release pathways from the secondary systems and define the threshold for a steam generator tube rupture.

C.

EQUIPMENT FAILURE QA3 - Unplanned Loss of Safety System Annunciators With Transient in Progress e The Calvert Cliffs EAL is written as:

Unplanned Loss of 75% of Main ControlBoard Annunciators AND EITHER of the Following:

• Plant Transient in Progress e SPDS Or Plant Computer NOT Available 8

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NUMARCINESP-OO7, IC SA4, incorporates a 15 minute time requirement into the Alert class for loss of annunciators events to exclude transient or momentary losses from triggering an emergency declaration. Those types of events do not represent a substantial degradation in the level of safety of the plant and, therefore, do not rise to the level of an Alert. The licensee should include a logic statement in their EAL that addresses momentary losses of annunciators to preclude inappropriate emergency classifications.

NESP-007 defines compensatory indications as all computer-based information such as SPDS and plant computer. "If both a major portion of the annunciation system and all computer monitoring are unavailable to the extent that the additional operating personnel are required to monitor indications, the Alert is required." This implies that with the availability of at least one computer-based information system, an Alert declaration is neither required nor desired. The licensee should revise the logic applied to.the compensatory indications or provide additionalinformation on the EAL as written.

D.

ELECTRICAL EA1 - Station Blackout While On Shutdown Cooling

• Calvert Cliffs' EAL is written as:

AOP-3B, Abnormal Shutdown Cooling, is Implemented Due to Loss of 4 kV Power Supplies For GREA TER THAN 15 Minutes it is not clear as to why the reference to AOP-3B is made in this EAL.

The threshold for the IC is clearly met when there is a loss of the 4 kV power supplies for greater than 15 minutes, regardless of whether or not operators have implemented AOP-38. The licensee should provide additional information for incorporating this reference.

E.

SECURITY TA1 - Security Event in the Plant Protected Area e NESP-OO7, IC HA4, EAL #1 states:

Intrusion into plant protected area by a hostile force.

• The Calvert Cliffs EALs are written as:

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Forced Entry of Unauthorized Personnelinto the Vital Area Affecting

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the Ability to Achieve or Maintain Safe Shutdown l

I and Sabotage of VitalEquipmentin Progress Affecting the Ability to i

Achieve or Maintain Safe Shutdown

]t Forced entry into a plant vital area by unauthorized personnelis a defining threshold for NESP-OO7 IC, HS1, " Security Event in a Plant l

Vital Area," and warrants the declaration of a Site Area Emergency.

The licensee has defined EAL thresholds for IC TA1 that are l

inconsistent with the level of risk associated with an Alert 4

classification and inconsistent with the guidance in NESP-007. The licensee should revise their EALs under ICs TU1, TA1, and TS1 to be consistent with NESP-007 or provide justification for the departure.

F.

FIRE i

IA1 - Fire or Explosion Affecting Safe Shutdown The licensee's supporting informati,on for this IC states that " damage to one train of safe shutdown equipment when other redundant equipment / trains are operable does not affect the ability to achieve or maintain safe shutdown..." This implies that the threshold for the IC -

i is not reached until redundant trains are affected and the function that l

those trains perform in achieving or maintaining safe shutdown is lost or potentially lost. This condition is already covered under Equipment i

Failure IC, OS2.

NUMARCiNESP-OO7 Q&As state:

It is important to note that this EAL addresses a fire and not the degradation in performance of affected systems.

System degradation is addressed in the System i

Malfunction EALs. The reference to damaae of systems is used to identify the magnitude of the fire and to i

discriminate against minor fires. The reference to safety.

j systems is included to discriminate against fires in areas having a low probability of affecting safe operation. The significance here is not that a safety system was degraded but the fact that the fire was large enough to cause damage to these systems.

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Event-based EALs, such as those associated with fires, are desigr.ed to provide for timely classification and emergency plan implementation, recognizing the potential for further degradation in plant conditions. The judgement of the SEC should be utilized to determine if this IC is met based upon the potential irnpact of the fire on the plant. It should be noted that this IC is not expected to be entered for isolated fires in breakers, motors, etc. However, raising the threshold of this EAL such that a declaration would not be made until redundant trains / equipment were affected defeats the anticipatory intent of the IC. The licensee should revise their plant specific information supporting this EAL so that operators will appropriately evaluate this IC in the context that was intended.

G.

OTHER HAZARDS

1. OA3 - Destructive Phenomena Affecting Safe Shutdown As stated in F. above, event-based ICs are designed to provide for timely classification and emergency plan implementation, recognizing the potential for further degradation in plant conditions. Raising the threshold of these EALs such that a declaration would not be made until redundant trains / equipment were affected defeats the anticipatory intent of the IC. The iicensee should revise their plant specific information supporting these EALs so that operators will appropriately evaluate this IC in the context that was intended.

2. OS2 - Control Room Has Been Evacuated AND Timely Plant Control Can NOT Be Established e NUMARC/NESP-007's EAL is written as:

Controlroom evacuation has been initiated.

c AND Control of the plant cannot be established per (site-specific) procedure within (site-specific) minutes.

e Calvert Cliffs' EAL is written as:

Control Room Evacuation Initiated AND Either of the Following:

e Inability to Establish Auxiliary Feedwater to A T LEAST One Steam Generator Within 30 Minutes 11

inability to. Establish Reactor Coolant Make-up (Charging e

Pump Flow) Within 60 Minutes The guidance in NUMARC/NESP-OO7 states that the site-specific time for verify control of the plant should not exceed 15 minutes. The Q&As on NESP-OO7 clarify this time limit by allowing maximum times greater than 15 minutes with additionalJustification. The licensee has provided some justification for the additional time allowed but it is insufficient to evaluate the validity of the EAL as written. The licensee should provide additionalinformation on the RETRAN modeling code, including all assumptions and code limitations.

Informt. tion should also be provided that justifies the 60 minute time limit for RCS inventory control. This should include scope of scenarios, assumptions of equipment availability, and documentation on the code that was utilized.

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Mr. Robert E. Denton November 17, 1993 This request affects one respondent and, therefore, is not subject to the Office of Management and Budget review under P.L.96-511.

Sincerely, Original signed by:

Daniel G. Mcdonald, Senior Project Manager Project Directorate I-I Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Enclosure:

l RAI i

cc w/ enclosure:

See next page Distributica.

Docket File JCalvo OGC SBoynton, 9/H/15 i

NRC & Local PDRs RAcapra ACRS (10)

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0FFICIAL RECORD COPY FILENAME: CC87080.LTR I

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