ML20126M761
| ML20126M761 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 01/04/1993 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Gates W OMAHA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9301110095 | |
| Download: ML20126M761 (5) | |
See also: IR 05000285/1992020
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NUCLEAR REGULATORY COMMISSION
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Docket No. 50-285
License No. DPR-40
Omaha Public Power District
ATTN:
W. G. Gates, Division Manager
Nuclear Operations
444 South 16th Street Mall
Mail Stop 8E/EP4
Omaha, Nebraska 68102-2247
Gentlemen:
SUBJECT:
NRC INSPECTION REPORT 50-285/92-20
Thank you for your letter dated December 7,1992, in response to the emergency
exercise weakness identified in NRC Inspection Report 50-285/92-20 dated
November 2, 1992. Your response detailed your analysis of the weakness and
identified as a contributing cause the conflicting assessment criteria
contained in your procedures. You also committed to evaluate the conflicting
criteria and initiate procedure changes as necessary.
We have reviewed your response and agree with your analysis that Emergency
Plan Implementing Procedure (EPIP)-OSC-1, Sections 4.0 and Attachment 6.1
appear to permit different interpretations of conditions challenging the
containment fission product barrier. We also agree with your conclusion that
under such conditions, the most conservative assessment and classification
should have been invoked.
This item will remain open until we have reviewed the results of the procedure
evaluations and changes committed to in your response letter.
Should you have any questions concerning this letter, please contact
Dr. D. Blair Spitzberg of my staff at (817) 860-8191.
Sincerely,
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LIJ.jjCallan, Director
Division of Radiation Safety
and Safeguards
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NUCLEAR REGULATORY COMMISSIOM
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Docket No. 50-285
License No. DPR-40
Omaha Public Power District
ATTN:
W. G. Gates, Division Manager
Nuclear Operations
444 South 16th Street Mall
Mail Stop BE/EP4
Omaha, Nebraska 68102-2247
Gentlemen:
SUBJECT: NRC INSPECTION REPORT 50-285/92-20
Thank you for your letter dated December 7,1992, in response to the emergency
exercise weakness identified in NRC Inspection Report 50-285/92-20 dated
November 2, 1992. Your response detailed your analysis of the weakness and
identified as a contributing cause the conflicting assessment criteria
contained in your procedures. You also committed to evaluate the conflicting
criteria and initiate procedure changes as necessary.
We have reviewed your response and agree with your analysis that Emergency
Plan Implementing Procedure (EPIP)-OSC-1, Sections 4.0 and Attachment 6.1-
appear to permit different interpretations of conditions challenging the
containment fission product barrier. We also agree with your conclusion that
under such conditions, the most conservative assessment and clas::ification
should have been invoked.
This item will remain open until we have reviewed the results of the procedure
evaluations and changes committed to in your response letter.
Should you have any questions concerning this letter, please contact
Dr. D. Blair Spitzberg of my staff at (817) 860-8191.
Sincerely,
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L. J. Callan, Director
')ivis on of Radiation Safety
and Safeguards
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Omaha Public Power District
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cc:-
LeBoeuf, Lamb, Leiby & MacRae
ATTN: Harry H. Voigt, Esq.
1875 Connecticut Avenue, NW
Washington, D.C.
20009-5728
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Washington County Board
of Supervisors
ATTN: Jack Jensen, Chairman
Blair, Nebraska 68008
Combustion Engineering, Inc.
ATTN: Charles B. Brinkman, Manager
Washington Nuclear Operations
12300 Twinbrook Parkway, Suite 330
Rockville, Maryland 20852
Nebraska Department of Health
ATTN:
Harold Borchert, Director
Division of Radiological Health
301 Centennial Mall, South
P.O. Box 95007
Lincoln, Nebraska 68509-5007
Fort Calhoun Station
ATTN:
T. L. Patterson, Manager
P.O. Box 399
Fort Calhoun, Nebraska 68023
Program Manager
FEMA Region 7
911 Walnut Street, Room 200
64106
Director
Nebraska Civil Defense Agency
1300 Military Road
Lincoln, Nebraska 68508
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J. L. Milhoan
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Spitzberg, DRSS/FIPS
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Section Chief, DRP/TSS
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Resident inspector - Fort Calhoun Station
MIS System
DRSS/flPS File
RIV File
Lisa Shea, RM/ALF, (MS MNBB 4503)
S. Bloom, NRR Project Manager (MS 13113)
C. A. Hackney, RSLO
G. F. Sanborn, E0
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J. Lieberman, OE (MS 7115)
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December 7, 1992
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LIC-92-337
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U. S. Nuclear Regulatory Comission
ATTN: Document Control Desk
Mail Station PI-137
Washington, DC 20555
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References: 1.
Docket No. 50-285
'
2.
Letter from NRC
November 2,1992 (A. B. B,each) to OPPD (W. G. Gates) dated
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 inspection 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,
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W. 5 &
W. G. Gates
Vice President
WGG/grc
Attachment
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LeBoeuf, Lamb, Leiby & MacRae
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J. L. Milhoan, NRC Regional Administrator, Region IV
R. P. Mullikin, NRC Senior Resident inspector
S. D. Bloom, NRC Project Manager
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Attachment'
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LIC 92 337
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Page 2
Under the specific safety function for Containment Integrity (6.), the
following acceptance criteria are presented:
Condition 2: Break Inside Containmni
a.
Each Containment penetration not required to be open-has at
least one isolation valve closed. (ERF pages 560-566).
'
b.
Hydrogen concentration < 3.07,or Hydrogen Purge in progress.
c.
Containment Spray flow rate a 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
' :
VERIFICATION CRITERI A:
1.
This event is not covered by any other EAL.
2.
The event is a failure or challenge to ANY two (2) fission
product barriers listed below (Attachment 6.1).
A.
.
B.
C.
Containment
4.
-Attachment 6.liof EPIP-05C 1, states- the following for Containment:
1
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C. Containment f ailure or Challenge'
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-Containment Hydrogen Concentration greater than-37..
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2.
Contcinment Pressure greater than 50 psig QB rising at
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a rate that will exceed 60 psig before corrective action
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can halt or reverse the pressure increase.
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Containment ~
Integrity: as- defined-
by--Technical-
Specifications is not ? resent during an unplanned-
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potent 1al exists for loss 'of one 'of
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the other two fiss on product barriers._
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Omaha PubBc Power District
444 South 16th Street Mall
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Cmaha, Nebraska 68102 2247
402/63&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
November 2,1992 (A. B. 8,each) to OPPD (W. G. Gates) dated
Gentlemen:
SUBJECT:
NRC Ir.spection Report No. 50-285/92-20, Response to an Identified
Weakness
-
The subject report transmitted an emergency exercise weakness resulting from an
i
NRC inspection 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,
1
N. 5 &
W. G. Gates
Vice President
WGG/gre
Attachment
c:
LeBoeuf, Lamb, Leiby & MacRae
J. L. Milhoan. NRC Regional Administrator, Region IV
R. P. Mullikin. NRC Senior Resident Inspector
S. D. Bloom, NRC Project Manager
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Attachment
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LIC 92 337
Page 1
RESPONSE TO AN EMERGENCY EXERCISE WEAKNESS
WEAKNESS
The inspectors noted a problem with emergency detection and classification when
the staf f did not promptly recognize that conditions existed for a Site Area
Emergency classification.
At 9 a.m., the Technical Support Center staff was
aware that containment spray and ventilation coolers were lost and that a primary
coolant leak existed.
These conditions indicated a challenge or loss of the
containment and reactor coolant system fission product barriers as defined in
EPIP-05C-1,
' Emergency Classification'
and,
therefore,
should have been
classified as a Site Area Emergency. At about 9:20 a.m., the Technical Support
Center controller issued a contingency message to the Site Director to declare
a Site Area Emergency.
Failure to promptly classify this event prom)tly in
accordance with the emergency classificaticn procedure was identificc
as an
exercise weakness (285/9220-01).
Response
Omaha Public Power District (OPPD) has completed a review to determine the cause
of the weakness identified during the 1992 NRC Evaluated Exercise on October 16,
1992.
The following information was identified:
1.
EPIP-05C-1, " Emergency Classification," Revision 21, Section 4.0 defines
a Challar.ged Barrier as:
4.1
CHALLENGED BARRIER - A challenge to a barrier is defined as one of
the following conditions:
4.1.1 Inability to maintain a critical safety function which
protects that barrier.
s
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 time has not yet
permitted verification of the failure.
2.
E0P-20 " Functional Recovery Procedure," states the following instructions
under Section 7.0, " Safety function Status Check":
The purpose of this section is to provide a form which enables the
operators to continually verify that the actions they are taking are
adequate to satisfy th; Safety Function Acceptance Criteria.
Satisfying the acceptance criteria assures that the actions beirg
taken are maintaining the plant in a safe condition and also
verifies by independent assessment (performed by the STA) that the
operator has implemented the correct procedure.
___
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Attachment
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LIC-92-337
Page 2
Under the specific safety function for Containment Integrity (6.), the
following acceptance criteria are presented:
.
Condition 2: Break inside Containment
a.
Each Containment penetration not required to be open has at
[
least one isolation valve closed. (ERF pages S60 566).
b.
Hydrogen concentration < 3.0Y, or Hydrogen Purge in progress.
,
c.
Containment Spray flow rate a 2400 gpm total or Containment
pressure s 5 psig.
3.
The
Emergency
Action
Level
(EAL)
in
EPIP OSC-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 -
-VERIFICATION CRITERIA:
1.
This event is not covered by any'other EAL.
2.
The event is a failure or challenge to ANY two (2) fission
prcduct barriers listed below (Attachment 6.1).
A.
Fuel' Cladding
B.
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 37..
2.
Containment Pressure greater than 50 psig QB rising at
a rate that will exceed 60 psig before corrective action
can halt or reverse the_ pressure increase.
3.
Containment
Integrity-
as
defined
by
Technical
Specifications is not ? resent during an unplanned
transient AtQ the >otential exists for loss of-one of
- the other two fiss'on product barriers.
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Aftachment
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-
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closed and sealed.
(4)
All automatic containment isolation valves are operable
er 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.
,
4
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
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 t.Al 1.16
(item 3,page2).
OPPD has determined that these conflicting criteria contributed to the weakness,
l
and proposes to perform a multi-discipline review of the appropriate procedures..
-
.
Corrective Actions and Schedule
.0 PPD will convene a review group to evaluate the conflicting criteria discussed
above,-as well as- other EAL criteria currently in use, 'and initiate procedure
t-
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
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completed by April -16,1993.-
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