ML20107D813

Forwards Discussion of Changes,Bases for Changes & 10CFR50,54(q) Evaluation Re Change to Radiation Emergency Plan Which Will Revise Two Notification of Unusual Event EALs

ML20107D813
Person / Time
Site:	Summer
Issue date:	04/15/1996
From:	Gabe Taylor SOUTH CAROLINA ELECTRIC & GAS CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9604190043
Download: ML20107D813 (10)

Text

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. South Carolina Electric & Gas Company Gary J.Vaylor Jenkinsville, SC 29065 Nuclear Operations (803) 345-4344 SCE&G

, ASDUntCdrpany J

April 15, 1996 I

Document Control Desk i U. S. Nuclear Regulatory Commission j . Washington, DC 20555 j

Subject:

VIRGIL C. SUMMER NUCLEAR STATION

DOCKET NO. 50/395 i

OPERATING LICENSE NO. NPF-12 EMERGENCY ACTION LEVEL PROPOSED CHANGE i South Carolina Electric & Gas Company (SCE&G) proposes to initiate a change to the 4 Virgil C. Summer Nuclear Station (VCSNS) Radiation Emergency Plan which will revise

.' two Notification of Unusual Event Emergency Action Levels (EAL).

4 i

SCE&G proposes to change two EALs, originally based u aon the example initiating

, conditions in Appendix 1 to NUREG-0654, to corresponc to the classification scheme i from the guidance in NUMARC/NESP-007. SCE&G further bases this change upon a Branch Technical Position communicated to the regions by letter from James H.

Joyner, dated July 11,1994. SCE&G does not consider the change to constitute a

decrease in the effectiveness of the plan and the plan as revised will continue to i meet the standards of 10 CFR 50.47 and the requirements of Appendix E to 10 CFR Part 50.

The propos,ed change has been discussed with and agreed upon by the state and counties within the primary emergency planning zone (see attached letter).

Attached is a discussion of the changes, the bases for the changes, and the 10 CFR 50.54(q) evaluation for your review and approval prior to impFementation.

Should there be any questions, please call Mr. Victor Kelley at (803) 345-4464.

Ver truly / rs, 9604190043 960415 PDR ADOCK 05000395 RAM /GJT/nkk 190000 Attachments c: J. L. Skolds (w/o attachments) J. B. Knotts (w/o attachments)

R. R. Mahan (w/o attachments) H. L. O'Quinn R. J. White NSRC

5. D. Ebneter (2 copies) DMS (RC-96-0106)

J. l. Zimmerman RTS (EMP 960002)

NRC Resident inspector File (810.10-1) l W. F. Conway

[  ;

f

& NUCLEAR EXCELLENCE- A SUMMER TRADITIONI t

1

• i CHANGE 1 Replace the NUREG 0654 Initiating Condition "lNDICATIONS OR ALARMS ON PROCESS OR EFFLUENT PARAMETERS NOT FUNCTIONAL IN THE CONTROL ROOM TO AN EXTENT REQUIRING SHUTDOWN AS PER TECHNICAL SPECIFICATIONS OR OTHER SIGNIFICANT LOSS OF ASSESSMENT OR COMMUNICATIONS CAPABILITY".

Detection Method:

EITHER 1 OR 2 OR 3:

1. Loss of Radiation Monitoring System requiring shutdown. I OR l

2. EWSS declared inoperable.

OR

3. Loss of all telephone communications to the State AND local governments AND the NRC.

With the NUMARC Initiating Condition " Unplanned Loss of All Onsite or Offsite Communications Capability" Detection Method:

1. Either of the following conditions exists:

a. Loss of all onsite communications capability affecting the ability to perform routine operations.

Internal telephone system, Gal Tronics system, and radio system.  !

OR l

. b. Loss of all offsite communications capability.

l Internal telephone system, Bell lines, FTS 2000 System, ESSX System,

Fiberoptic links, radio systems. '

(When extraordinary means must be used to make communications.)

i i BASIS l The base documents for the formulation of Initiating Conditions for a nuclear i plant are NUREG-0654/ FEMA-REP-1 and NUMARC/NESP-007. Neither j document mentions the Early Warning Siren System (EWSS) as a system

! requiring action if it is inoperable. The Code of Federal Regulations in

! 10CFR50.72 designates the loss of the EWSS as being a one-hour reportable event.

If this Detection Method is deleted, the Utility will cortinue to notify the State and Counties when the EWSS is determined to be inoperable. This requirement will be added to SAP-132, Off Normal Occurrence Evaluation, Reporting, and Resolution, with the existing requirement to notify the NRC.

CHANGE 2 Replace the NUREG 0654 Initiating Condition "EXCEECHNG TECHNICAL SPECIFICATION RCS LEAK RATE LIMIT" Detection Method:

RCS Leak Rate Exceeds Technical Specification 3.4.6.2 Limits:

1. >0 Pressure Boundary

2. >1 gpm Unidentified for >4 hours

3. >10 gpm Unidentified for >4 hours

4. >33 gpm Controlled (@ 22235 i 20 psig) for >4 hours 1

5. >1 gpm Pressure Boundary Isolation Valve (@ 2235 i 15 psig) per Table 3.4-1 fro >4 hours with the NUMARC Initiating Condition "RCS LEAKAGE" Detection Method:

1. Unidentified or Pressure Boundary Leakage greater than 10 gpm.

OR

2. Identified Leakage greater than 25 gpm.

(Only applicable during Modes 1-4.)

l BASIS The Detection Methods associated with the "RCS LEAKAGE" initiating Condition state values that are readily observed by normal Control Room instrumentation. Whereas the " EXCEEDING ...." initiating Condition uses values that must generally be determined through time-consuming surveillance testing.

The higher values in the "RCS LEAKAGE" Initiating Condition remain within the concept of " potential degradation in the levol of safety of the plant" and continues to provide an adequate level of safety.

SOUTH CAROLINA ELECTRIC & GAS COMPANY l EMERGENCY SERVICES I

l

Subject:

Emergency Action Level Date: March 19,1996 l Proposed Revision l To: S. M. McKinney File: CGSS-96-0164 S. J. Threatt 151.20 M. S. Kirkland N. W. Ellis T. P. Barber G. Sox ,

From: V. J. Kelley ,

The V.C. Summer Nuclear Station proposes to revise two Notification of Unusual Event initiating Conditions. We are required to obtain your concurrence before forwarding these revisions to the Nuclear Regulatory Commission for their review.

Below is a discussion of the changes and the basis for the changes. Please note that the Initiating Conditions that we propose to change to are commonly used at other nuclear plants.

If you concur with the changes, signify by affixing your signature in the appiuprialv space below. Any questions can i;e addiewwwd to me at 345-4464.

l Thank you for your cooperation and support.

Concurrence:

5y ~

Date: J'%A 4 2/

Soutt(Carolina Emergency Preparedness Division 6 wAA Date: Zo f4 Ad 4.

South Carolina 0'epartment of Health and Environmental Control Date:

Fairfield County Date:

Lexington County Date:

Newberry County Date:

Richland County NUCLEAR EXCELLENCE A SUMMER TRADmON!

SOUTH CAROLINA ELECTRIC & GAS COMPANY EMERGENCY SERVICES

Subject:

Emergency Action Level Date: March 19,1996 Proposed Revision To: S. M. McKinney File: CGSS-96-0164 S. J. Threatt 151.20 M. S. Kirkland N. W. Ellis T. P. Barber G. Sox ,

From: V. J. Kelley The V.C. Summer Nuclear Station proposes to revise two Notification of Unusual Event initiating Conditions. We are required to obtain your concurrence before forwarding these revisions to the Nuclear Regulatory Commission for their review.

Below is a discussion of the changes and the basis for the changes. Please note that the Initiating Conditions that we propose to change to are commonly used at other nuclear plants.

l If you concur with the changes, signify by affixing your signature in the appropriate space below. Any questions can be addressed to me at 345 4464.

l Thank you for your cooperation and support.

Concurrence:

l Date:

South Carolina Emergency Preparedness Division

(

l Date:

South Carolina Department of Health and Environmental Control J Y  ?

Fairfiel'd County

./ Date:d*2146 NW Date:Y2//f.4

l. Idxin'gt ounty f ]0$ __g rA Dated *Al Sh Newberry. ounty

,!/d Date: 3-3k Richland Cdunty~

~[~

t 4

NUCLEAR EXCELLENCE A SUMMER TRADITION!

2

o ,

- SOUTH CAROLINA ELECTRIC & gas COMPANY EMERGENCY SERVICES CHANGE 1 Replace the NUREG 0654 Initiating Condition " INDICATIONS OR ALARMS ON PROCESS OR EFFLUENT PARAMETERS NOT FUNCTIONAL IN THE CONTROL ROOM TO AN EXTENT REQUIRING SHUTDOWN AS PER TECHNICAL SPECIFlCATIONS OR OTHER SIGNIFICANT LOSS OF ASSESSMENT OR COMMUNICATIONS CAPABILITY".

Detection Method:

EITHER 1 OR 2 OR 3:

1. Loss of Radiation Monitoring System requiring shutdown.

OR

2. EWSS declared inoperable.

OR

3. Loss of all telephone communications to the State AND local governments AND the NRC.

With the NUMARC Initiating Condition " Unplanned Loss of All Onsite or Offsite Communications Capability" Detection Method:

1. Either of the following conditions exists:

a. Loss of all onsite communications capability affecting the ability to j perform routine operations.

Internal telephone system, Gai-Tronics system, and raoio system.

OR

b. Loss of all offsite communications capability. ,

Internal telephone system, Bell lines, Fiberoptic links, radio system. l (When extraordinary means must be used to make communications.)

i BASIS f The base documents for the formulation of Initiating Conditions for a nuclear plant are NUREG 0654/ FEMA REP 1 and NUMARC/NESP 007. Neither document mentions the Early Warning Siren System (EWSS) as a system I requiring action if it is inoperable. The Code of Federal Regulations in J 10CFR50.72 designates the loss of the EWSS as being a one hour reportable event, meaning that the Utility has one hour to notify the NRC after the determination of EWSS inoperability.

If this Detection Method is deleted, the Utility will continue to notify the State and Counties when the EWSS is determined to be inoperabla. This requirement will i

be added to SAP-132, Off-Normal Occurrence Evaluation, Reporting, and Resolution, with the existing requirement to notify the NRC.

NUCLEAR EXCELLENCE - A SUMMER TRADITIONt

SOUTH CAROLINA ELECTRIC & GAS COMPANY

.- EMERGENCY SERVICES CHANGE 2 Replace the NUREG 0654 Initiating Condition " EXCEEDING TECHNICAL SPECIFICATION RCS LEAK RATE LIMIT" Detection Method:

RCS Leak Rate Exceeds Technical Specification 3.4.6.2 Limits:

>0 Pressure Boundary j 1.

2. >1 gpm Unidentified for >4 hours

3. >10 gpm Unidentified for >4 hours j

4. >33 gpm Controlled (@ 22235 20 psig) for >4 hours

5. >1 gpm Pressure Boundary isolation Valve (@ 2235 15 psig) per Table 3.4-1 fro >4 hours with the NUMARC Initiating Condition "RCS LEAKAGE" Detection Method:

1. Unidentified or Pressure Boundary Leakage greater than 10 gpm.

OR i

2. Identified Leakage greater than 25 gpm.

(Only applicable during Modes 1-4.)

BASIS Tile Detection Methods associated with the"RCS LEAKAGE" Initiating Condition state values that are readily observed by normal Control Room instrumentation. Whereas the " EXCEEDING ...." Initiating Condition uses values that must generally be determined through time-consuming surveillance testing.

The higher values in the "RCS LEAKAGE" initiating Condition remain within the concept of " potential degradation in the level of safety of the plant" and  ;

~

continues to provide an adequate level of safety.

f l

)

1 1

NUCLEAR EXCELLENCE - A SUMMER TRADITION!

l 1

, SAP 139

. ATTACHMENT Xill I . PAGE 1 OF 3 REVISION 16 DETERMINATION OF A DECREASE IN THE EFFECTIVENESS OF THE l EMERGENCY PLAN (5)IN ACCORDANCE WITH 10CFR50.54(q) l

! DOCUMENT M-/66 REVISION DATE: 3-JS-9/,

TITLE: lbA%H. (1 $ M M r r? hla h FM 3&ned W+ZMnM Emmae v ms DIRECTIONS FOR COMPLETING THIS ATTACHMENT:

j 1. Review all statements in sub-sections 1.1 and 1.2 ind check applicable boxes if the statement applies.

I 2. Complete one sub-section of section 2.0 for each bex checked in sub-section 1.1 or 1.2. (Additional copies l of page 2 of 3 may be used,if necessary).

3. Complete sections 3.0 and 4.0, sign and date the form oa line 4.4, and attach completed form to revision package prior to forwarding package to the Manager, Nuclear Protection Services for signature.

l 4. Check the appropriate block on the Procedure Development Form (Attachment IV) concerning decreasing the effectiveness of the Radiation Emergency Plan, based on this review.

5. PSRC review is required for the Radiation Emergency Plan prior to approval of the revision.

1.0 Effect of the Chance on the Emeroency Plan (s):

1.1 This changedDUES)DOES NOT) affect SECTIONS under 10CFR50.47(b). The following subject areas

j. of 10CFR50.44o; nave been affected:

! O (1) Assignment of Emergency Response Organization responsibilities.

O (2) Assignment of onshift Emergency Response Organization personnel.

Arrangements for utilizing State or Local resources and staff.

[O(3) (4) Emergency Classification and Action Levels, including f acility system, and effluent parameters.

O (5) Notification of State and Local agencies, the Emergency Response Organizations,and the public.

O (6) Communications between State and Local agencies, the Emergency Response

! Organizations, and the public.

O (7) Coordination with the public through periodic dissemination of information.

t O (8) Adequacy of emergency facilities and equipment.

l O (9) Adequate methods, systems, and equipment for offsite response to a radiological emergency.

O (10) Plume exposure pathway EPZ protective actions.

O (11) Emergency worker's radiological exposure.

O (12) Medical services f or contaminated injured individuals.

O (13) Reentry and Recovery plans.

O (14) Emergency response periodic exercises.

O (15) Radiological emergency response training.

O (16) Plan development, review, and distribution.

1.2 This change ES/ OES NOT) affect SECTIONS under 10CFR50, Appendix E. The following subject are of FR50, Appendix E,have been affected:

O (I),(II),(Ill) Emergency plans as desuibed in the FSAR.

O (IV) A Organization for coping with radiological emergencies.

O IV) B Release of radioactive materials (assessment).

j

/

Ji[ ((IV)C Activation of Emergency Classification and Action Levels and activation of the Emergency Resoonse Organizations.

4

' O (IV) D Notification of Federal, State and Locci anencies, and the public.

O (IV) E Emergency Facilities and Equipment irdhmg communication systems.

O ((V) F Training on and exercising the Emergency Plan.

; (!V) G Maintaining emergency plans and procedures, and the surveillance of equipment and i supplies.

j O (IV) H Reentry of facility and recovery following an accident.

4 i

i

, SAP 139

. ATTACHMENT XIll

. PAGE 3 OF 3 REVISION 16 2.0 Basis for Determination per 10CFR50.54(a):

For applicable item 10CFR50.(V7[h)[4) ) of Section 1.0 above, this change (DOESOOES NOldecrease the effectiveness of the Emergency Plan (s). This change (DOESDOES NO"l) result in information presented in the Emergency Plan (s) being no longer -

true or accurate.

Basis for answer: Hora A L, as zuns m HunA/UA'f~sp-soy mes da striv morro 2r 1s w A n s < a krsanedW Tb Afd d f &' -M.CW '

AicntA. Anf L Tas ~ == s>r DL.ta m. saws n awM na /

nssxansrin a as m svssar dansasurwu nv AM ew2nria r -

For applicable item 10CFR50.(#M4"(N) c ) of Section 1.0 above, this change (DOESK)OES NOTDdecrease the effectiveness of the Emergency Plan (s). This change (DOESIDOES NOWresult in information presented in the Emergency Plan (s) being no longer true or accurate.

Basis for answer: .ft I A m N Mers,eurv/'-

For applicable item 10CFR50.( ) of Section 1.0 above, this change (DOES/DOES NOT) decrease the effectiveness of the Emergency Plan (s). This change (DOES/DOES NOT) result in information presented in the Emergency Plan (s) being no longer true or accurate.

Basis for answer:

l l

l For applicable item 10CFR50.( ) of Section 1.0 above, this change I (DOES/DOES NOT) decrease the effectiveness of the Emergency Plan (s). This change (DOES/DOES NOT) result in information presented in the Emergency Plan (s) being no longer, true or accurate.

Basisfor answer:

For applicable item 10CFR50.( ) of Section 1.0 above, this change (DOES/DOES NOT) decrease the effectiveness of the Emergency Plan (s). This change (DOES/DOES NOD result in information presented in the Emergency Plan (s) being no longer true or accurate.

Basis for answer:

l l For applicable item 10CFR50.( . ) of Section 1.0 above, this change

j. (DOES/DOES NOT) decrease the effectiveness of the Fmergency Plan (s). This change

,' (DOES/DOES NOT) result in information presented in the Emergency Plan (s) being no longer true or accurate.

Basis for answer:

i 1

(

i t

i' .. . , , , ,

SAP-139 ATTACHMENT Xill PAGE 3 OF 3

- REVISION 16 3.0 Determination / Action per 10CFR50.54(a):

3.1 This change (DOES ecrease the effectiveness of the Emergency Plan (s).

(If the change does decrease the effectiveness of the Emergency Plan (s), then the change shall not be implemented without prior NRC approval.)

3.2 This changebOOES NOT1 require a further revision to the Emergency Plan (s) or the implementing Procedures. (10CFR50, Appendix E, does NOT require that the NRC be notified of changes to the Emergency Plan (s) that do not decrease the effectiveness of the plan prior to implementation.)

3.2.1 List any additional Emergency Plan Procedures, forms, or supporting procedures requiring revision as a result of this revision.

J PA-oo/

4.0 Reviewand Approval:

1 4.1 YES O NO decrease the effectiveness of the Emergency Plan?

4.2 YES O NRC approval of document required prior to implementing?

4.3 YES 60 O 15 a change required to Emergency Plan or other procedures?

(if yes, see Section 3.2.1 above for details.)

4.4 Review completed b dM Date: 4' //Od 4.5 Approved by: Ad 2 Date: 9d

/

j VklanafNucle Protection Services'I

5.0 Comments

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