ML20134B442
| ML20134B442 | |
| Person / Time | |
|---|---|
| Issue date: | 02/04/1993 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | Sniezek J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20133F923 | List:
|
| References | |
| FOIA-96-351 NUDOCS 9304070144 | |
| Download: ML20134B442 (5) | |
Text
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1 February 4, 1993 MEMORANC' M FOR:
James H. Sniezek J
Deputy Executive Director for Nuclear Reactor Regulation i
Regional Operations and Research Office of the Executive Director for Operations j
FROM:
Thomas E. Murley, Director Office of Nuclear Reactor Regulation Edward L. Jordan, Director Office for Analysis and Evaluation of Operational Data
SUBJECT:
DECLARATION OF ALERT FOR LOSS OF ANNUNCIATORS In your memorandum of December 28, 1992, you requested NRR and AE00 to evaluate the currt.nt classification for loss of annunciators and to revise the emergency classification and emergency action levels as needed.
As you know, emergency classifi:;ction and emergency action level (EAL) schemes are requirod by 10 CFR 50.47(b)(4) and Appendix E of 10 CFR Part 50,..which refers to NUREG-0654, " Criteria for Preparation and Evaluation of Radiological Emergency Response Procedures," for definition and discussion of " emergency classes." That information is contained in Appendix 1, " Emergency Action Level Guidelines," of NUREG-0654, which lists the following four classes of EALs:
(1) Notification of Unusual Event, (2) Alert, (3) Site Area Emergency, and (4) General Emergency.
The following statement appears immediately after this list in NUREG-0654:
The rationale for the notification ar.d alert classes is to provide early and prompt notification of minor events which could lead to more serious consequences given operator error or equipment failure or which might be indicative of more serious conditions which are not yet fully realized. A gradation is provided to assure fuller response preparations for more serious indicators.
Appendix 1 of NUREG-0654 aise contains examples of initiating conditions for each class "to form the basis for establishment by each licensee of the specific plant instrumentation readings (as applicable) which, if exceeded, will initiate the emergency class." (Pages 1-3). Those pertaining directly to loss of annunciators are as follows:
Notification of Unusual Event Indications or alarms on process or effluent parameters not a
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functional in control room to an extent requiring plant shutdown M I *' U SN EEEE E6t' TOE SE:0T c661-60-EO
James H. Sniezek February 4, 1993 or other significant loss of assessment or communication capability (e.g., plant computer, Safety Parameter Display System, all meteorological instrumentation).
Most or all alarms (annunciators) lost.
Although NUREG-0654 does not amplify this last example of an initiating i
condition, in keeping with the concept of " gradation," Alty_1 connotes a more serious condition than does Notification of Unusual Event. This " gradation" should also be reflected in the details of plant-specific EAL schemes prepared by licensees based upon NUREG-0554. This " gradation" may not always hold true, however, where a licensee simply and unconditionally incorporates into its plant-specific scheme an example of an initiating condition exactly as written in NUREG-0654.
The concept of " gradation" is evident in the following descriptions of the unusual event and alert classes found in NUREG-0654.
NOTIFICATION OF UNUSUAL EVENT ALERT Class Descriotion Class Descriotion unusual events are in process or Events are in process or have have occurred which indicate a occurred which involve an actual or potential degradation of the level potential substantial degradation of of safety of the plant. No releases the leyel of safety of the plant.
of radioactive material requiring Any rekases expected to be limited offsite response or monitoring are to small fractions of the EPA expected unless further degradation Protective Action Guideline exposure of safety systems occurs.
levels.
Purcose Purcose Purpose of offsite notification is Purpose of offsite alert is to (1) to (1) assure that the first step in assure that emergency personnel are any response later found to be readily available to respond if necessary has been carried out, (2) situation becomes more serious or to bring the operating staff to a stats perform confirmatory radiation of readiness, and (3) provide monitoring if required, and (2) systematic handling of unusual provide offsite authorities current events information and decision-status information.
l making.
- q James H. Sniezek February 4, 1993 Guidance Recentiv Issued by the NRC in August 1992, the NRC issued Revision 3 to Regulatory Guide 1.101,
" Emergency Planning and Preparedness for Nuclear Power Reactors," in which it endorsed guidance in NUMARC/NESP-007 (Revision 2, January 1992?, " Methodology for Development of Emergency Action Levels" as an acceptable alternative method to that described in Appendix 1 to NUREG-0654. As stated in that document:
" Licensees may use either NUREG-0654/ FEMA-REP-1 or NUMARC/NESP-007 l
in developing their site-specific EAL scheme but may not use portions of both methodologies." Nevertheless, regardless of which method a licensee uses to prepare a site-specific EAL scheme, much of the general discussion andNESP-007 guidance in NESP-007 applies to that in NUREG-0654 and augments it.
includes the following discussion of the difference between a Notification of Unusual Event and an algrl:
Rather than discussing the distinguishing features of " potential degradation" and " potential substantial degradation," a comparative approach would be to determine whether increased monitoring of plant functions is warranted at the Alert level as a result of safety system degradation. This addresses the operations staff's need for help, independent of whether an actual decrease in plant safety is determined. This increased monitoring can then be used to better determine the actual plant safety state, whether escalation to a higher emergency class is warranted, or whether de-escalation or termination of the emergency class declaration is warranted. Dose consequences from these events are small fractions of the EPA PAG plume exposure levels, i.e., about 10 millirem to 100 millirem.
j NESP-007 lists the following emergency action level as an example to amplify that given in NUREG-0654 for loss of annunciators as an initiating condition for an Alert:
EXAMPLE EMERGENCY ACTION LEVEL:
1.
The following conditions exist:
a.
Loss of most or all (site-specific) annunciators associated with safety systems for greater than 15 minutes.
AND b.
In the opinion of the Shift Supervisor, the loss of annunciators or indicators requires increased surveillance to safely operate the unit (s).
AND
February 4, 1993
-4 James H. Sniezek c
Annunciator or Indicator loss does not c.
l result from planned action AND d.
Either of the following:
1.
A significant plant transient is in progress.
OR 2.
Compensatory non-alarming indica-
)
tions are unavailable.
Consistent with the " gradation" concept, NESP-007 also lists the following example of an emergency action level corresponding to site Area Emeraency:
EXAMPLE EMERGENCY ACTION LEVEL:
1.
The following conditions exist-Loss of (site-specific) annunciators associated
)
a.
with safety systems.
AND b.
Compensatory non-alarming indications are unavailable AND Indications needed to monitor (site-c.
specific) safety functions are unavailable AND d.
Transient in progress.
Conclusion The current guidance for treating loss-of-annunciator events in EAL schemes is In publishing Revision 3 to Regulatory Guide 1.101 endorsing NESP-007, the NRC issued the licensed power reactor community more information of adequate.
value to all licensees regardless of the method they use to devise thei emergency action level schemes. licensees may use either NUREG-0654 or N schemes (but not portions of both) does not negate information and guidance that pertains to both.
.=
l 4
February 4, 1993 i
James H. Sniezek,
Licensees may revise their emergency plans and associated EAL schemes to i
i conform with that guidance if desired.
Original 3isteilWF.
ThomasE. krley Thomas E. Murley, Director Office of Nuclear Reactor Regulation Original Signed By Edward L. Jordan, Director Office for Analysis and Evaluation of Operational Data i
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