ML20125D375

Responds to Weaknesses Noted in Insp Rept 50-285/92-20 on 921013-16.Corrective Actions:Review Group Will Be Established to Evaluate Conflicting Criteria Re Emergency Detection & Classification

ML20125D375
Person / Time
Site:	Fort Calhoun
Issue date:	12/07/1992
From:	Gates W OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LIC-92-337, NUDOCS 9212150148
Download: ML20125D375 (4)

Text

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Omaha Public Power District 444 South 16th Street Mall Omaha, Nebraska 68102-2247 402/636-2000 December 7, 1992 LIC-92-337 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station PI-137 Washington, DC 20555

References:

1. Docket No. 50-285

2. Letter from NRC (A. B. Beach) to OPPD (W. G. Gates) dated November 2, 1992 Gentlemen:

SUBJECT:

NRC Inspection Report No. 50-285/92-20, Response to an Identified Weakness The subject report transmitted an emergency exercise weakness resulting from an NRC inspectic7 conducted October 13 through October 16, 1992 at the Fort Calhoun Station. Attached is the Omaha Public Power District response to this weakness.

If you should have any questions, please contact me.

Sincerely, i

W. 5 W. G. Gates Vice President WGG/grc Attachment c: LeBoeuf, Lamb, Leiby & Nuae J. L. Milhoan, NRC Regional Administrator, Region IV R. P. Mullikin, NRC Senior Resident Inspector S. D. Bloom, NRC Project Manager l

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' Attachment 1: LIC-92-33/

l Page 1 1

i RESPONSE TO AN ENERGENCY EXERCISE WEAKNESS WEAKNESS l The inspectors noted a problem with~ emergency detection and classification ~when j the staff did not promptly recognize l that conditions existed for a Site Area j- Emergency classification. At 9 a.m.~, the Technical : Support Center staff was L aware that containment spray and ventilation coolers were lost and that a primary l coolant leak existed. These conditions indicated a-challenge- or loss- of the L containment and reactor coolant system fission product barriers:as defined in.  ;

EPIP-0P-1, " Emergency Classification" and, therefore. should 'have: been classified as a Site Area Emersancy. At about 9:20 a.m., the Technical. Support Center controller issued-a cantingency message to the Site Director to declaae a Site Area Emergency. - Failure to promptly classify this- event promptly in accordance -with the emergency clarsification procedure was ' identified as an exercise weakness (285/9220-01).

' Response

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Omaha Public Power District (OPPD) has completed-a review to detarmine the cause

, of the weakness identified during the 1992 NRC Evaluated Exer ise on October 16, l 1992. The following information was identified:

l 1. EPIP-0SC-1, " Emergency Classification," Revision 21, Section 4.0 defines j a Challenged Barrier as:

4.1 CHALLENGED BARRIER - A challenge tc a-barrier is defined as one of the following conditions:

4.1.1 Inability to maintain a critical safetyxfunction which protects that barrier.

4.1.2 A situation exists which will ~cause the failure of the barrier-

[ within a predictable time period unless successful corrective action occurs.

4.1.3 An event has occurred which has-a high probability of having damaged a- fission product barrier but tima has not yet permitted verification of the' failur,e. ~

2. E0P-20, " Functional Recovery Procedure," st'ates the following instructions under Section 7.0, " Safety Function Status Check":

The purpose of this section is~ to provide.a form which enaoles the operators to continually verify that the actions:they are taking are adequate to satisfy' the Safety' Function Acceptance Criteria.

-Satisfying the acceptance criteria assures that the actions-being taken are maintaining- the plant in a safe condition and 'also verifies by independent assessment- (perforced by .the-STA)- that the L operator has implemented the correct. procedure.

Attachment LIC-92-337 Page 2 Under the specific safety function for-Containment Integrity (6.), the following acceptance criteria are preser.ted:

[ondition 2:._Ereak Inside Containment

a. Each Containment penetration not requirer' to ',e open has at least one isolation valve closed. (ERF pyr 560 76),

b. Hydrogen concentration <!3.0% or Hydrogen' Purge in progress,

c. Containment Spray flow rate > 2400 gpm total. or Containment pressure s 5 psig.

3. The Emergency Action Level .(EAL in EPIP-0SC-1, " Emergency-Classification," which was prompted by) an exercise controller was EAL 1.16, which states the following:

FAILURE / CHALLENGE TO TWO FISSION PRODUCT BARRIERS

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VERIFICATION CRITERIA:_

1. This event is not covered by any other EAL.

AND

2. The event is a failure or challenge to ANY two (2)- fission ..

product barriers listed below (Att chment 6.1).

.{

A. Fuel Cladding B. Reactor Coolant System C. Containment

4. Attachment 6.1 of EPIP-OSC-1, states the following for Containment:

C. Containment Failure or Challenge

1. Containment Hydrogen Concentration greater than.3%.

2. Containment pressure greater thars 50 psig 93 rising at-a rate that will exceed 60 psig before corrective action can halt or reverse the pressure incr<-se.

3. Containment Integrity. at . de fined - by Technical Specifications is. not 'present during an unplanned transient AN_Q the )otential exists for loss of one- of the other two fiss'on-product barriers.

' Attachment LIC-92-337 Page 3

5. The FCS Technical Specifications state the following pertaining to containment integrity:

Containment integrity is defined to exist when all of the following are met:

(1) All nonautomatic containment isolation valves which are not required to be open during accident conditions and blind flanges are closed.

(2) The equipment hatch is properly closed and sealed.

(3) At least one door in the personnel air lock is properly closed and sealed.

(4) All automatic containment isolation valves are operable or locked closed (or isolated by locked closed valves or blind flanges as permitted by limiting condition for operation).

(5) The uncontrolled containment leakage satisfies Specification 3.5.

The OPPD review identified that by the strict guidance provided in EPIP-0SC-1,

" Emergency Classification" (item 4, page 2), the plant conditions did not meet the criteria of a Failure / Challenge to Two Fission Product Barriers. As a result, an escalation to a Site Area Emergency classification was not required.

However, based upon the definition of a challenged barrier in Section 4.1 of EPIP-OSC-1, item 4.1.1 (item 1, page 1), the critical safety function for Containment was not maintained per the requirements of the Safety Function Status l Checks in E0P-20 (item 2, page 1). Therefore, this condition could have been  :

! considered to be a challenged barrier. This condition, along with a known primary to secondary leak, would have satisfied the requirements of EAL 1.16 (item 3, page 2).

OPPD has determined that these conflicting criteria contributed to the weakness, )

and proposes to perform a multi-discipline review of the appropriate procedures.

Corrective Actions and Schedule OPPD will convene a review group to evaluate the conflicting criteria discussed above, as well as _other EAL criteria currently in use, and initiate procedure changes as necessary. The group will be composed of personnel from areas that typically use the procedures / documents. Training will be provided to affected personnel on any changes initiated by the review process. These actions will be completed by April 16, 1993.

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