ML20058M676
| ML20058M676 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/29/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20058M668 | List: |
| References | |
| NUDOCS 9310060325 | |
| Download: ML20058M676 (4) | |
Text
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'f NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555 4001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ON REVISION 10 TO CLEVELAND ELECTRIC'S EMERGENCY PLAN FOR THE PERRY NUCLEAR POWER PLANT i
THE CLEVELAND ELECTRIC ILLUMINATING COMPANY. ET AL.
DOCKET NO. 50-440
1.0 BACKGROUND
By [[letter::PY-CEI-NRR-1584, Forwards Temporary Change 7 to Rev 10 to Emergency Plan, Table 4-1, EALs to Incoporate NUMARC-based EALs for Comparison Matrix Between NUMARC/NESP-007 & PNPP EALs Also Included|letter dated January 12, 1993]], the Cleveland Electric Illuminating Company submitted Revision 10 to the Perry Nuclear Power Plant (Perry)
Emergency Plan for NRC review under 10 CFR 50.54(q). Specifically, Revision 10 incorporated revised Emergency Action Levels (EALS) based upon NUMARC/NESP-007, " Methodology for Development of Emergency Action Levels." NUMARC/NESP-007 has been endorsed by the staff as an acceptable method for licensees to develop site-specific EALs. The proposed EALs have been discussed by the licensee with the State of Ohio and the local counties of Lake, Geauga, and Ashtabula, and agreed upon.
Representatives from Perry met with the staff on February 5, 1993, to discuss their application of the NUMARC guidance in developing their site-specific emergency classification scheme.
In a letter dated April 20, 1993, the staff requested additional information (RAI) to clarify several of the EAL changes.
Perry provided a response to the staff's RAI in a letter dated May 20, 1993, addressing each of the staff's concerns and recommendations.
2.0 DISCUSSION Emergency Action Level changes associated with Revision 10 to Perry's emergency plan were reviewed against the requirements in 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50.
Part 50.47(b)(4) of Title 10 of the Code of Federal Regulations, specifies that onsite emergency plans must meet the following standard:
"A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee..."
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' Appendix E.IV.C specifies that " emergency action levels (based not only on onsite and offsite radiation monitoring information but also on readings from a number of sensors that indicate a potential emergency, such as pressure in containment and the response of the Emergency Core Cooling. System) for notification of offsite agencies shall be described... The emergency classes defined shall include:
(1) notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency."
The staff, in Revision 3 to Regulatory Guide 1.101, " Emergency Planning and Preparedness for Nuclear Power Reactors," endorsed NUMARC/NESP-007, Revision 2, " Methodology for Development of Emergency Action Levels," as an acceptable method for licensees to meet the requirements of 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50.
The staff relied upon the guidance in NUMARC/NESP-007 as the basis for its review of Perry's proposed EAL changes. The licensee formatted their EAls into fifteen (15) recognition categories, "A" through "O," as opposed to the four (4) recognition categories described in NUMARC/NESP-007, to provide consistency with other site procedures. The staff found that as a result of its interactions with the licensee during the i
development of the NUMARC/NESP-007 methodology and the site-specific EALs for Perry, the majority of the Perry EALs conform closely to the guidance in NUMARC/NESP-007. However, several of the EALs depart from the NUMARC/NESP-007 guidance for site-specific reasons. The staff reviewed each of these EALs in detail and, as discussed below, found them to be acceptable.
(1) NUMARC/NESP-007 Initiating Condition (IC) SU5 states:
The following conditions exist:
Unidentified or pressure boundary leakage greater than 10 gpm.
a.
OR b.
Identified leakage greater than 25 gpm.
Perry's AU2: Reactor Coolant System Leakage states:
Unidentified leakage greater than 10 gpm indicated on recorder IE31-R618, Drywell Floor Drain Sump Fill Rate and Sump Level, on panel 1H13-P642.
i OR Identified leakage greater than 30 gpm indicated on recorder IE31-R619, Equipment Drain Sump Fill Rate and Sump Level on panel 1913-P642.
I
- The threshold for identified leakage in the Unusual Event EAL is slightly higher than the guidance of 25 gpm due to Perry's technical specification limit on identified leakage being 25 gpm.
The staff believes that entering a technical specification action statement does not, by itself, represent an emergency condition.
The threshold for the Unusual Event should, therefore, be somewhat greater than the technical specification limit. Thus, Perry's departure from the NUMARC/NESP-007 guidance for this EAL is acceptable.
(2)
The NUMARC/NESP-007 IC for loss of containment, based upon containment pressure, states:
Containment pressure response not consistent with LOCA conditions.
The licensee states that this EAL is too vague for accurate analysis and, therefore, requires a judgement by the Emergency Director (ED) as to whether or not pressure response is normal.
The licensee contends that this condition is covered under the umbrella of "ED Judgement" and has not included this specific It in their scheme. The staff agrees that the subjectivity in this EAL warrants its elimination as a separate threshold for loss of the containment barrier for Perry.
(3)
The NUMARC/NESP-007 IC for potential loss of the reactor coolant system (RCS), based upon RCS leakage, states:
RCS leakage GREATER THAN 50 GPM inside the drywell.
Perry has replaced this with the following EAL:
Drywell pressure greater than 1.68 psig with indications of a leak inside the drywell.
Licensing engineering calculations indicate that the containment will isolate on high drywell pressure for RCS leak rates less than 50 gpm.
Containment isolation will isolate the area sump pumpout rate instrument and preclude the operator's ability to evaluate an EAL based upon RCS leakage rate. The licensee has, therefore, utilized containment pressure to indicate a significant leak that threatens the integrity of the RCS. Analysis by the licensee shows that the containment isolation setpoint will be reached in approximately four (4) minutes following a 50 gpm leak. Therefore, the Perry EAL meets the intent of the guidance in NUMARC/NESP-007 and is acceptable.
y
. (4)
NUMARC/NESP-007 IC SS4 states:
Complete Loss of any function Needed to Achieve or Maintain Hot Shutdown Perry's equivalent, BS1, states:
Complete Loss of Functions Needed to Achieve or Maintain Hot Shutdown This departure from the guidance is based upon differences in technical specification definitions of modes between PWRs and BWRs.
For a BWR, entering Hot Shutdown merely requires the placement of the reactor mode switch in the " shutdown" position. Therefore, to meet the intent of the NUMARC/NESP-007 IC, the licensee has taken into consideration those functions needed to achieve cold shutdown (e.g., decay heat removal, ultimate heat sink).
The staff finds that the Perry EAL meets the intent of the guidance in NUMARC/NESP-007 and is acceptable.
3.0 CONCLUSION
Based upon a review of the proposed EAL changes in Revision 10 to the Perry emergency plan, the staff concludes that the revised EALs are consistent with the guidance in NUMARC/NESP-007 and, therefore, continue to meet the requirements of 10 CFR 50.47(b)(4) and Appendix E to 10 CFR Part 50.
Principle Contributor:
S. Boynton Date: September 29, 1993
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