ML20116L286
| ML20116L286 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/10/1992 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NSD921098, NUDOCS 9211180234 | |
| Download: ML20116L286 (3) | |
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GCNERAL OFFICE is6f'3] Nebraska Publ!c Power Dis;rict -.
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NSD921090 November 10, 1992 U.S.
Nuclear Regulat ory Commissicn Attention:
Document Control Desk Washington, DC 20555
Subject:
Reactor Du11 ding Reentry for Emergency Support Procedures Cooper Nuclear Station NRC Docket No. 50-298, Licence No. DPR-46 Gentlement In response to as, item discussed in Inspection Report Numbe'; 50-298/92-1), the following information is belag provided by the Nebraska Public Power District (District) regarding reentry into the Cooper Nuclear Station (CNS) reactor building as a result of the use of the CNS Emergency Operating Procedures (BOPS),
and the u. u of the Emergency Support Procedures (ESPs) to carry out specific EOP actions. This letter contains information previously provided during a November 2,1992, telephone conversation between the District and members of the NRC staf f in which the District was requested to respond to a series of statements.
1.
1,LR_C Item.
Confirmation that no personnel reentry into the reactor building is required for any design basis accident.
NPPD Resr>ongfg.
Reentry into the reactor building is not required for the CNS design basis accidents as described in the CNS Updated Safety ' alysis Report.
2.
NRC Item.
For heyond design basis conditions in which the EOPs direct local operatoe actions, procedures are in place to ensuce that a health physicist would accompany the response team to assess radiological conditions.
NPPD Response.
The present implementing procedures for the CNS Emergency Plan require a health physics technician to accompany teams that are aent out in the field.
As a further enhancement, the procedures that direct EOP actions at local areas (e.g.,
reactor building) will be revised to require a health physics technician to accompany the response team when radiation QQ1 levels are olevated or unknown. These procedures will be revised prior to startup from the 1993 refueling outage.
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Nuclear Regulatory Commission NSD921098 Page 2
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NPC 7t.em.
e ESPs have been reviewed and evaluated to identify local ~ action steps which-could 'be prohibited due to high radiation levels to ensure that prioritized, alternative success paths exist and appropriate caution statements are properly located in the ESPs.
NPPD Response.
The CNS ESPs are presently undergoing an enhanced Verification-- and.
Validation (V&V) effort to identify local action. steps which could be prohibited due to high radiation levels to ensure that " success paths" are appropriately-categorized and prioritized, and that appropriate caution statements are located in the ESPs.
This enhanced. V&V - ef fort - ano '.
subsequent ESP revision approval will be completed prior to startup from the 1993 refueling outage.
NPPD notes that the term " success path" is normally associated wLth the EOPs used for pressurized water reactors.
The'CNS EOPs. follow the BWR Owners Group Emergency Procedure Guidelines philosophy. An ESP _provides the detailed inetructions used by an operator to achieve an EOP action.
The. ESP.may have-instructions for severc.'. dif ferent methods which will-achieve the desired action.
Should circumetancesiprevent the completion of the required action of that EOP step, the EOPs have~ succeeding.
contingency steps which direct additional actions to be taken to prevent' or mitigate further degradntion of plant conditions. NPPD considers-the combination of the instructions within the ESP used to_ accomplish a COP action and the succesding EOP actions to constitute a complete " success patn."
4.
HItc Item.
Personnel who would perform -the - aforementioned local' actions - receive.
appropriate training in this regard.
N"PD Responso.
Personnel-Qve been trained to require a health physics technician ~to accompany teamo that are sent cut: into the field per.the CNS Emergency-Plan implementing procedures'. -Personnel will'be trained'on the revised <
procedures discussed in the response to iten 3.
This training will be completed' within one - full. nix week operator training ' cycle following g
startup from the 1993 refueling' outage.
S.
NRC Itam.
A detailed Verification 'and Validation of the EOP and ESP steps which-could be prohibited due-to hLgh ' radiation --levels andJ the associated alternative action. steps has been completed.
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U.d.-Nuclear Regulatory Commission tiSD921098-
-Page 3 NPPD ResD9DR2 The VLV ef fort discussed in the response to ite:13 will addresJ this item.
The completion schedule for this V&V is also provided in that response.
Copies to the NRC Region IV Of fice and the CNS Resident Inspector are also being provided in accordance with 10 CFR 50.4(b)(1).
Should you have any questions or require any additional information regarding this oubmittal, please contact me.
S ir.
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G4 R.
llorn Nun ear Power Group Manager CRil/ MAD Attachments cc:
NRC Regional Office Region IV Arlington, TX NRC Resident Inspector Cooper Nuclear Station i
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