ML20117P886
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i AUG 0 91988 MEMORANDUM FOR:
William F. Kane, Director Division of Reactor Projects, Region I FROM:
Bruce A. Boger, Assistant Director for Region I Resctors Division of Reactor Projects I/II Office of Nuclear Reactor Regulation
SUBJECT:
NRR REVIEW 0F REGION I CONCERNS REGARDING LOSS OF CONTROL ROOM ANNUNCIATOR EVENTS
REFERENCES:
1.
Memorandum, Kane to Miraglia April 8, 1988 PROPOSED TASK INTERFACE AGREEMENT REGARDING REVIEW OF LOSS OF CONTROL ROOM ANNUNCIATOR EVENTS 2.
Memorandum, Roe to Boger, June 22, 1988 PROPOSED TASK INTERFACE AGREEMENT REGARDING REVIEW 0F LOSS OF CONTROL ROOM ANNUNCIATOR EVENTS 3.
Memorandum, Congel to Boger, June 23, 1988 LOSS OF l-CONTROL ROOM ANNUNCIATOR EVENTS l
In your April 8,1988 o morandum (Reference 1), you proposed that a Task Interface Agreement be established between NRR and Region I to resolve Region I concerns identified during the review of the less of control room annunciator events at l
l Beaver Valley 2 and Calvert Cliffs 2 plants. These concerns were associated with the guidance currently provided in NUREG-0654, Rev.1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants", regarding the emergency classification of this type of l
event and the extent of procedural coverage for these types of events at reactor sites. Your concerns were passed to two Divisions of NRR for comment, the Division sof Licensee Perfomance and Quality Evaluation (DLPQ), for the procedural issue, and the Division of Radiation Protection and Emergency Preparedness (DREP), for the NUREG-0654 issue.
With respect to your concern about the lack of abnormal or emergency operating procedures for handling loss of annunciator events, the DLPQ response (Reference 2) 2 stated that there are no requirements for licensees to have an abnormal or emergency Most licensees commit operating procedures to handle loss of annunciator events.
to having procedures.that are referenced in RG 1.33, which in turn endorses ANSI N18.7/ANS 3.2, which deals with the administrative controls for the operation of nuclear power plants. DLPQ also notes that ANSI /ANS 3.2 is being revised this year and may be endorsed by the NRC by a revised RG 1.33 (time table for completion of I
this revision is unclear). DLPQ is of the " technical opinion that a procedure P g} l for handling loss of annunciator events is necessary..." and that " the (ANSI /ANS However. 6 3.2 and RG 1.33) revision process will address the issue for all pla
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. staff will backfit the revised version of RG I.33 on those facilities who do not voluntarily upgrade to this revision.
Intheirresponse(Re'ference3),DREPagreedwiththeRegionIassessment
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regarding the overclassification of the loss of annunciators Emergency Action DREP further felt that retaining l
Level (EAL) at the Site Area Emergency level.
the loss of annunciators event at the Alert level is prudent because of the l
valuable augmentation of orsite resources that accompanies that classification.
Although they will considce your concerns in future revisions, they believe that an interim revision of NUREG-0654 is unnecessary because the EAL listings provided in NUREG-0654 are intentionally conservative and need not be strictly followed by the licensees. DREP further encourages the Regions to look favorably, on a case-by-case basis, upon facility requests to remove loss of annunciator events as a Site Area Emergency, downgrading the event type to an Alert EAL.
It is felt that the implementation of a well thought-out loss of annunciator procedure (upon which operators have been trained) would provide to the NRC the minimum justification necessary to reduce the loss of annunciator event to the Alert EAL.
We trust this is responsive to your needs.02161N O L 4 6t C D ypy a
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CNT Bruce A. Boger, Assistant Director for Region I Reactors Division of Reactor Projects I/II Office of Nuclear Reactor Regulation Attachments:
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MEMORANDUM FOR: FraA.J.J11 rag 11a, Jr., Associate Director for Projects Office of Nuclear Reactor Regulation FROM:
William F. Kane, Director Division of Reactor Projects, Region I
SUBJECT:
PROPOSED TASK INTERFACE AGREEMENT REGARDING REVIEW OF LOSS OF CONTROL ROOM ANNUNCIATOR EVENTS This proposes that a Task Interface Agreement be established between NRR and Region I to resolve concerns identified daring a review of the loss of control room annunciator events at the Beaver Valley 2 and Calvert Cliffs 2 plants.
These concerns are associated with the guidance provided in NUREG-0654, as adopted by facility Emergency Plan Implementing Procedures, regarding the emergency classification of this type of event and the extent of procedural coverage for these types of events at reactor sites.
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On January 23, 1988, Beaver Valley Unit 2 experienced a loss of all control room annunciators as the result of a fire in the annunciator control and power supply panel, a non-safety related system. Following the loss of annunciators, the Itcensee declared an Alert in accordance with their approved Emergency Plan.
Subsequently, a similar event at Calvert Cliffs Unit 2 also resulted in the declaration of an Alert per their Emergent.y Plan. The Beaver Valley Emergency Plan would have required declaration of a Site Area Emergency if the plant had been in Mode 4 or higher (the plant hJd just reached Mode 5 (Cold Shutdown) as a part of a preplanned but unrelated maintenance outage). The Calvert Cliffs plant was at 100T, power and remained at full power untti the annunciators were l
restored and the Alert was terminated. The guidance in NUREG-0654 appears to indicate that if Calvert Cliffs (or any operating plant) had sustained a trans-j ient while the annunciators were lost (which could have been no more than a normal shutdown or tripping of the reactor even with no other complications), a
$tte Area Emergency should be declared.
The above differences in implementation of NUREG-0654 guidance notwithstanding, the declaration of an Alert or higher level emergency for such a casualty to equipment not required for safe shutdown or operatian of the plant appears to be inappropriate when one considers the possible public alarm and unwarranted activation of emergency response facilities and personnel. We have reached this conclusion, based on our evaluation of these incidents including the following pertinent information:
(1) the annunciators are only used as an operator aid to draw operator attention to individual of f-normal conditions; (2) the information provided by the annunciators is generally provided by other control room equipment (safety-related instruments, plant computer, alarm printer, SPOS, etc.), (3) neither Emergency Operating Procedures nor operator training and response depends upon annunciators to trigger further actions, and (4) in the event of a reactor trip or other transient that challenges the plant, so many annunciators alarm within a short period of time that operators do not try to respond to annunciators.
Instead, they rely upon control room instrumentation to monitor the functioning of safety related systems as well as deciding which, if any, operator actions to take.
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APR P81988 Memorandum for Frank J. Miraglia, Jr.
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l-Consequently, it is requested that a review of NUREG-0654 be conducted by NRR with particular emphasis on the emergency action levels associated with loss of annunciator events to assure the guidance provided is consistent with the i
potential safety impact of these events.
In addition, during inspection of circumstances surrounding the two events, it was noted that neither Itcensee had abnormal or emergency operating procedures I
for loss of annunciators. Resident inspector follow-up at all Region I sites confirmed this to be the situation at other sites also. This issue should also be addressed under this TIA.
Region I is following up on licensee corrective actions. An Information Notice has been issued to alert industry to aspects of these events.
Region I
point of contacts will be William Lazarus,
- Chief, Emergency Preparedness Section (FTS 346-5208) for the Emergency Planning issue and l
David Limroth, Project Engineer (FTS 346-5121) for the procedural coverage issue.
William F. Kane, Director Olvision of Reactor Projects l
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