ML20073D075

Seeks to Change Emergency Plan for Plant to Incorporate Lesson Learned from 900403 Declaration of Alert.Change Would Define Terms Loss & Functional Such That Sys Would Not Be Considered Lost Even If Inoperable,Per Tech Specs

ML20073D075
Person / Time
Site:	Perry
Issue date:	03/19/1991
From:	Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:	Hall J Office of Nuclear Reactor Regulation
References
NUDOCS 9104260149
Download: ML20073D075 (2)

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l March 19, 1991 Mr. James R.

Hall, Project Manager j[0- QQO Project Directorate III-3

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Division of Reactor Projects Il/IV/V Office of Nuclear Reactor Regulation l

U.S.

Nuclear Regulatory Commission I

Washington, DC 20555

Dear Mr. Hall:

I am writing on behalf of the Ohio Citizens for Responsible Energy, Inc. ("OCRE") regarding the attached December 19, 1990 letter from Centerior Energy Co.

This letter seeks to change the emergency plan for the Perry Nuclear Power Plant to incorporate " lessons learned" from the April 3,

1990 declaration i

of an ALERT.

The change would define the terms " loss" and 3

" functional" such that a system would not be considered lost, even if it were inoperable according to the plant Technical Specifications, but were still functional, i.e.,

" capable of maintaining respective system parameters within acceptable design limits."

OCRE opposes these changes for two reasons.

First, the licensee appears to have learned the wrong lesson from the April 1990 event.

OCRE agrees that the ALERT was unnecessary and avoidable, but not because of overly restrictive emergency plans and Technical Specifications.

The event could have been avoided had the licensee not failed to properly maintain the "B" ESWS screen wash pump.

This failure resulted in the issuance of a notice of violation by the NRC (Violation 50-440/90014-01).

Second, it is possible that the changes sought will delay the declaration of the appropriate emergency classification. The definition of " functional" is not necessarily unambiguous.

It is conceivable that an engineering evaluation would have to be performed to determine if a degraded system is indeed " capable of maintaining respective system parameters within acceptable design limits."

The very purpose of emergency plans is to provide criteria for making quick decisions using clear, unambiguous guidelines for Emergency Action Levels.- NUREG-06S4, Appendix 1 states that "the rationale for the notification and alert classes is to provide early and prompt notification of minor events which could lead to more serious consequences given operator error or equipment failure or which might be indicative of more serious conditions which are not yet fully realized."

For this purpose, the Technical Specification definitions of operable are appropriate.

It is better to err on the side of caution.

Even " unnecessary" activations of emergency plans may g%$

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have benefits in that they serve as "real-world" exercises which can enhance preparedness by providing additional training and experience for all persor.nel involved (onsite and offsite) and by exposing weaknesses in the planning effort.

The licensee's request should be denied.

'T Respectfully submitted, Susan L.

Iliatt OCRE Representative 8275 Munson Road Mentor, 011 44060 (216) 255-?158 cc:

W. Snell, Chief, Emergency preparedness Section, Region III Jay Silberg, Ecq.

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December 19. 1990 W:f,,ll.h, PY-CE1/NRR-1242 L U.S. Nuclear Regulatory Commission Document Control Desk Washington, D. C.

20555 Perry Nuclear Power Plant Docket Hos. 50-440; 50-441 Proposal to Revise Emergency l

Action Level (EAL) Definition of System / component " Loss" Centlement Based on lessons learned f rom a recent Emergency Plan activation, this letter is being submitted te request prior NRC Region 111 review of a proposed change to the Perry Nuclear Power Plant (PNPP) Emergency Plan. On April 3, 1990, an Alert was declared after a flange gasket leak developed on the discharge strainer for the Emergency Service Water (ESW) "A" pump. Due to the magnitude cad effects of the leak, the "A" ESW system (System designation P45) and the "A" Screen Vash system (System designation P49) were declared inoperable.

Since the "B" screen wash pump (P49) was already out of service for maintet.ance, the on-shift operators made a conservative determination to declara the 8" ESW (P45) loop inoperable per the Technical Specificaticsn d3finition of Operability, even though the "B" ESW system was fully capable of performing its design function without an operable Screen Wash System pump (cad in fact was actually operating at the time). With both ESW systems declared " inoperable" per Technical Specifications, an Alert was formally d:clared based on the concept that a loss of both ESW loops had occurred.

The guidance of NUREC-0654 for Emergency Action Levels (EAL s) utilises the tcres " loss" and " lost" for a number of the example initiating conditions. We believe that for Emergency Plan purposes, basing the _ loss of a system or component on the Technical Specification definition of Op'erable/ Operability is too conservative for all instances, since it does not consider whether the system or component is functional. As a result, the Perry Nuclear Power Plant Alert on April 3 resulted in the unnecessary activation of the Ashtabula County Emergency Operations Center and the staf fing of the utility's i.

Operations Support Center and Technical Support Center. The increased l

activity on the part of the State of Ohio, local counties and media was cavarranted. _due to the f act that the "B" ESW loop remained in operation throughout the entire event and was available to cool the Division 2 diesel generator a'nd other supported safety systems if called upon.

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2-Decotber 19, 1990 I

70 prevent a similar unwarranted declaration of an Emergency Plan event in the future, we propose that a " lose," as defined by the Emergency Plan, should be To achieve tied directly to the functional status of a system or component.

this, we propose that the following definitions of LOSS and FUNCTIO f

identical to the Davis-Besse Nuclear Power Station's Emergency Plen), and to

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3, the corresponding sections of the on-site implementing instruction for the Emergency Action Levels (EAL's):

A system, subsystem, train, component or device, though degraded in equipment condition or configuration, is PUNCT10HAL Functional. -

if it is capable of maintaining respective system parameters within acceptable design limits.

A state of inoperability in which PUNCT10NAL an,d 0PERABLE Ms.s, -

A system, subsystem, train, status cannot be maintained.

component or device is not_ lost if its functio'nality is assured.

The terminology " operable" per the Technical Specifleations will continue to be specified within the EAL's where it is appropriate, and this proposed change will have no effect upon these references.

Although CEI believes this proposed revision will not decrease the effactiveness of its Emergency Plan, CEI requests that NRC Region 111 provide In order to assist the NRC us with a prior review on our proposed revision.

in their review, Attachment i to this letter provides a copy of the proposed page change which would result from implemntation of this change to the In addition. Attachment 2 Emergency Plan and the implementing instruction.

provides copies of the current pages Irom the Emergency Plan EAL's which utt11:e the terminology " loss" or " lost" within the portion of the EAL that the operator references to determine entry into the Initiating' Condition.

If there are any questions, please feel free to call.

Since e y hj}

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Michael D. Lyster HDL BSTinjc cc KRR Project Manager NRC Resident Office USNRC Region 111 W. Snell, Chief, Emergency Preparedness Section, Region,111 J. Poster, Emergency Preparedness Analyst, Region III e

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