ML20135H806

Forwards Response to 850508 Request for Addl Info Re Emergency Action Levels & NRC Comments on Station Dose Assessment Methodology.Info on Emergency Action Levels Incorporated Into Rev 8 to Emergency Plan

ML20135H806
Person / Time
Site:	Hope Creek
Issue date:	09/18/1985
From:	Mittl R Public Service Enterprise Group
To:	Butler W Office of Nuclear Reactor Regulation
References
NUDOCS 8509240247
Download: ML20135H806 (9)

Text

~f Pubhc Servee O PS G Company Ekrtnc and Gas 80 Park Plaza, Newark, NJ 07101/ 201430 8217 MAILING ADDRESS / P.O. Box 570, Newark, NJ 07101 Robert L. Mitti General Manager -

Nuclear Assurance and Regulation September 18, 1985 4

Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Attention: Mr. Walter Butler, Chief Licensing Branch 2 Division of Licensing Gentlemen:

REQUEST FOR ADDITIONAL INFORMATION - EMERGENCY ACTION LEVELS ~AND DOSE ASSESSMENT METHODOLOGY HOPE CREEK GENERATING STATION DOCKET NO. 50-354 Pursuant to Enclosure 1 of the NRC request for additional information regarding the Hope Creek Generating Station Emergency Action Levels (letter from W. Butler (NRC) to R.L. Mittl (PSE&G), dated May 8, 1985), Public Service Electric and Gas Company hereby submits the attached information (see Attachment 1) for review. This information was incor-porated into the HCGS Emergency Plan, Revision 8, dated June 30, 1985.

Pursuant to Enclosure 2 of the request for additional infor-mation referenced above regarding the llope Creek Generating Station Dose Assessment Methodology, Attachment 2 provides responses to the staff's comments for review.

Very truly yours, I

c 8509240247 8 18 PDR ADOCM 0 354 ,

j F PDR The Energy People

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Director of Nuclear 2 9/18/85 Reactor Regulation Attachments C D.H. Wagner USNRC Licensing Project Manager A.R. Blough USNRC Senior Resident Inspector c____--_--__-__----_____--_-___.__-_--_-_____

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ATTACHMENT 1 HOPE CREEK GENERATING STATION EMERGENCY PLAN RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION, DATED MAY 8, 1985 RESPONSE TO ENCLOSURE 1; REVIEW OF THE HOPE CREEK GENERATING STATION EMERGENCY ACTION LEVELS Notification of Unusual Event Initiating Condition 2A (No. 5)

PSE&G's proposed Technical Specification 3.4.3.2, Action Statement (b) applies to any reactor coolant system leakage, -

which will include system leaks both inside and outside j of primary containment.

Initiating Condition SA (No. 3) ,

This emergency action level (EAL) is being revised as suggested.

Initiating Conditions 10B (No. 1) and 10C and 10D (No. 4) ,

l Section 10 is being revised to include EAL clarification.

The revisions of these EALs will case implementation, provide consistency with current action levels being utilized by PSE&G, and have been accepted by the state and local governments.  :

i Essentially, the revised EALs will require the declaration i of an Unusual Event at any time a unit shutdown is initiated ,

or required in order to comply with technical specifications.  ;

Initiating Conditions llD (No. 2) and 12C ( N o. ' 2 )  !

t This EAL is being revised as suggested.

Initiating Condition 13A (No. 10) l Although the NUREG-0654/ Rep-1, Rev. 1 example EAL states

" Fire within the plant lasting more than 10 minutes", the EAL described in the Hope Creek Emergency Plan provides for any fire, either within the plant or external to the r plant, that affects plant operation. This EAL is considered to be more conservative than the example EALs while maintaining consistency with EALs already accepted by the associated state and local governments. Additionally, the EAL as currently ,

provided eliminates confusion of an event for a fire that '

is extremely minor and has no clear initiation time and/or .

duration. l

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Alert i

Initiating Condition 2B (No. 5)

This EAL is being revised as suggested. ,

1 l Initiating Condition 7B (No. 14) l This EAL is being revised as suggested.

l Initiating Conditions llE (No. 15) and 12E (No. 15) l This EAL is being revised as suggested.

l Site Area Emergency l

l Initiating Condition 4B (No. 8) l l In order to maintain consistency with the detailed category l listing for EALs, the combined failure of the reactor pro-l tection system (failure to scram) and an inoperable standby l liquid control system is provided as initiating condition /

l EAL set 3B. The additional changes are being incorporated into the EAL as suggested.

l Initiating Condition SE (No. 2) l This EAL is being revised as suggested.

l Initiating Condition 7C (No. 12) l

! This EAL is being revised ar suggested.

Initiating Condition llF (No. 13)

This EAL is being revised as suggested.

General Emergency Initiating Condition 2D (No. 6.b)

This EAL is being revised as suggested.

Initiating Condition 4C (No. 6.d)

This EAL is being revised as suggested.

Initiating Conditions 6A and 6B (No. 2)

This EAL is being revised with respect to the suggested EAL content.

Protective Action Decisionmaking CALs Predetermined protective action recommendations (PAR), as provided in NUREG-0654, Appendix 1, General Emergency Initiating

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..- Condition 4, are discussed in the Hope Creek Emergency Plan, Section 10, Accident Assessment. This discussion commits

'to providing_ predetermined PARS in the Hope Creek Emergency Plan Implementing Procedures that are consistent with the guidance provided in NUREG-0654 and Inspection and Enforcement Information Notice'83-28. These PARS utilize barrier failure information developed to correct EAL sets 6A and 6B. These PARS are provided in the implementing procedures to allow the emergency coordinator the chance to initiate a number of parallel activities while assessing the overall condition of the plant and, if necessary, providing the state and local governments with actions to be taken in fast-paced accident sequences while the situation can be reviewed properly.

Initiating Conditions Not Addressed Unusual Event 14B This initiating condition /EAL set was not included. There are no railroads within approximately seven miles of the station.

Alert 9 This initiating condition /EAL set was not included. The coolant pump seizure is analyzed in the Hope Creek Generating Station FSAR, paragraph 15.3.3, as having the same consequences as a recirculation pump trip (paragraph 15.3.1.5). This sequence does not yield fuel damage. Initiating condition /

EAL set 5B provides an alert declaration for fuel failure that meets the intent of this action icvel.

General Emergency 4 The action levels for this initiating condition are as dis-cussed for Protective Action Decisionmaking above.

General Emergency 6C The initiating condition /EAL set 2D is being revised to include sequences for the General Emergency 6B and 6C.

This EAL will contain both the LOCA - ECCS failure - core melt, and the LOCA - containment failure - ECCS failure sequences.

ar ATTACHMENT 2 HOPE CREEK GENERATING STATION EMERGENCY PLAN RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION, DATED MAY 8, 1985 RESPONSE TO ENCLOSURE 2; REVIEW OF THE HOPE CREEK GENERATING STATION DOSE ASSESSMENT METHODOLOGY ITEM 1 LOCATION (REV. 2): COMMENT:

Page 10.2 Provide a schedule for installing last paragraph the described software at HCGS.

RESPONSE

The Midas software will be installed at Hope Creek prior to the 100%

Reactor Power Warranty Run. The next revision of Section 10 will be revised to indicate this information.

ITEM 2 LOCATION: COMMENT:

Page 10.3 The following should be added first (complete) at the end of the paragraph:

paragraph " Output from the MIDAS calcula-tions will be available on these terminals."

RESPONSE

This change was provided in Revision 4.

ITEM 3 LOCATION: COMMENT:

Page 10.3 The second paragraph should be second paragraph changed to indicate when MIDAS will be installed at HCGS.

RESPONSE

As discussed in the response to Item 1 above, the fourth full paragraph undor subsection 10.3 will be revised to include the scheduled installation of the MIDAS model. This schedule will apply to all committed capa-bilities and equipment as discussed with regard to the MIDAS dose assessment methodology.

( .- ITEM 4 LOCATION: C000 TENT:

( Page 10.3 This paragraph clearly references l second paragraph a manual method for dose assessment using plastic overlays found in emergency kits in the emergency response facilities. The text in Section 10 should be supplemented with a short description of the manual method and words saying that it is available in HCGS facili-

. ties or committing to have it:hore, with emergency implementing pro-cedures, by a specific date.

RESPONSE

A description of the manual method is.provided in Revision 4 in the seventh full paragraph in subsection 10.3. The procedures (all Emergency Plan Procedures)'for implementing the manual method were provided to the Staff on June 3, 1935.

These procedures are available for implementation at the HCGS emergency response facilities.

ITEN 5 LOCATION: COMMENT:

Page 10.3 second A revision of this material should and third para- be made stating clearly that models graph conforming to the Class A and Class B models in Appendix 2 to NUREG-0654 (Revision 1) are in the part of the MIDAS software which will be installed in HCGS facilities by a specified date. It should be made clear that the "model based on PLG's CRACIT" is' installed by the date as noted above, that it is Class B model and that it calcu-lates deposition concentrations and doses.

RESPONSE

The seventh full paragraph of sub-

, section 10.3 in Revision 4 provides a discussion of the MIDAS package as requested in the above comments.

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ITEM 6 LOCATION: COMMENT:

Page 10.3 in the The first sentence should be changed fifth paragraph to read: " Procedures will be devel-oped and submitted for staff review for monitoring potential release pathways and for performing dose i assessment."

l RESPONSE:

I l This paragraph has been revised to indicate procedural development.

The developed procedures have been submitted for staff review.

ITEM 7 LOCATION: COMMENT:

Page 10.3 in the A submittal date should be indicated next-to-last line after: "will be prepared."

RESPONSE

These procedures have been submitted for Staff review.

ITEM 8 LOCATION: COMMENT:

l l Page 10.4 A specific date should be.added fifth line after: " incorporated." (the refer-ence to EPA's document in the last line of this paragraph is incomplete i and inadequate; many EPA report numbers begin with " EPA-520").

RESPONSE

As discussed above, the computer i

and manual methods for dose assess-ment have been incorporated into the Emergency Plan procedures and provided for Staff review. Revision 4 of Section 10 changes the reference l

l from " EPA-520" to " EPA-520/1-75-001".

l ITEM 9 LOCATION: COMMENT:

Page 10.4 The last sentence should be changed l

last paragraph to state that the class D model will be on line at HCGS by a specified date.

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Item 9 Continued RESPONSE:

( The full model description was i provided as indicated in the response

( to Item 5 above. The revisions i

with regard to scheduling will be as provided in response to items 1 and 3 above.

ITEM 10 LOCATION: COMMENT:

Page 10.4 A specified date should be inserted last paragraph in first line after: "will be developed". *

RESPONSE

These procedures have been provided for Staff review.

ITEM 11 LOCATION: COMMENT:

Page 10.5 Under " Dose Assessment from Field l Monitoring", a statement is needed I

that Emergency Implementing Procedures will be prepared and submitted for staff review for projecting doses at other locations ~f rom field monitoring results.

RESPONSE

This change was made in Revision i 4 of Section 10. The procedures  !

were provided for Staff review.

ITEM 12 LOCATION: COMMENT:

Page 10.6 The second line should be changed l

to read: " water samples will be i taken and counted with a".

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RESPONSE

This change was provided in Revision 4 to Section 10.

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