ML20138H130
| ML20138H130 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 01/27/1993 |
| From: | Mccabe E NRC |
| To: | Shankman S NRC |
| Shared Package | |
| ML20138G636 | List:
|
| References | |
| FOIA-96-351 NUDOCS 9701030134 | |
| Download: ML20138H130 (3) | |
Text
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From:
Ebe C. McCabe/y)sp ECM1 g
'To:
SFS Date:
Wednesday, January 27, 1993 8:28 am
Subject:
SALEM ENFORCEMENT PANEL -Reply -Reply
- Susan, I think your rationale is right.
But there is some complexity to the alarm / annunciator loss issue.
The NRC made the NUREG-0654 example Alert "Most or all alarms (annunciators) lost."
The problem is with "most."
We don't redefine "most" so the NUREG-0654 guidance means more than half.
NUMARC guidance defines 75% of the alarms / annunciators as most
& that sort of misses the point.
Because we don't expect the operators to count the operable annunciators, "most" is really a qualitative criterion.
The core problem is the ability to respond effectively to plant conditions affecting safety while simultaneously, or nearly so, implementing the emergency plan.
Without the alarms and/or annunciators, that task is tougher.
The NRC hasn't definitively addressed this touchy issue, but staffing in an emergency with the alarms / annunciators working has been found weak enough by some licensees that they normally staff beyond TS requirements.
The Salem AIT identified alternative annunciators but, in the report version I saw, did not show that the operators determined that they had the annunciators they needed to assure effective response to plant conditions.
Had the operators done that and therefore not declared an Alert, they'd have been in the right.
As I understand it, what the AIT-found was that an Alert was not declared because it was over shortly after being identified.
That's not grounds for not classifying and reporting, and Emergency Plans should provide for doing that without unnecessary mobilizing of the licensee's response organization.
Somc don't.
I suggested to Reggie Rogers, the Northeast Utilities EO Director and a leader in the NUMARC initiative, that licensees should define and mark (e.g., a fire engine lime bezel?) the alarms and/or annunciators needed for effective emergency response and implement the emergency plan when those are lost.
(Some room for operator judgement is needed too.)
That evaluation would be a complex one but, I think, a better option than leaving the choice up to a snap decision only.
As far as the Salem annunciator loss is concerned, I don't believe the core issue was being effectively addressed.
The AIT leader appeared to have very strong opinions, weak EP background, an unwillingness to listen, and a short-sighted willingness to I
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%0 9701030134 961226 PDR FOIA O'NEILL96-351 PDR
.A deviate from the long-standing NRC insistence that literally adhering to plans / procedures is required.
(Otherwise, plan / procedure requirement following becomes amorphous and arbitrary.
There are ways to knowingly deviate when needed, and the licensee probably could have done so in this case.
But, just not classifying and reporting without making the determination that the basic conditions for an Alert hadn't existed isn't right.)
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ENFORCEMENT PANEL BRIEFING FORM Appendix B E9Im
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Date of Board:
2/19/93 Licensee Name:
PSE&G Salem 1 & 2 Docket /LicenseeNumber(s): 50-272/311 DPR 70/75 1
Types of Licensed Activities: _ Reactor last day ofInspection: _12/23/92_ Exit on 10/93 ATTENDEES: Board Chairman: _W. Lanning Enforcement Representative:
Cognizant Section Chief: _W. Ruland Responsible DRP Manager Wenzinger (Reactor Licensee) lead Inspector:
W. Ruland Others Potentially Escalated Violations (include specific requirements violated)_1) Failure to implement 50.47(b)(8) to supply adequate emerj;ency fecilities and equipment to support emergency response (OHA system inadequate). 2) Failure to report an ALERT as required by E-Plan and TS 6.8.1.e. 3) Failure of operators to meet a condition of their license (55.53(d)...shall observe
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all applicable rules...of the Commission.
Note: PSE&G alma may have failed to make a required report per 50.72(b)(1)(v) but that would not be an escalated action Safety Significance / Apparent Severity levels: _Providing the inadequate OHA system could delay operator response, other emergency actions, or could lead to operator errors.
Root causes see page 29 of report
. Method of Identification (NRC, License, Other State or Federal Inspector, Allegation, etc.):
Problem revealed by event.
i Corrective Actions Taken or Planned to Date: _1) annunciator system procedure revised 2) training and mod planning started
- 3) revised ECG 4) substantial effort during AIT 5) Issued AB for loss of annunciators 6) disciplined two operators 7) post-event SERT and compensatory measures Prior Licensee Performance (cps, Orders, No. of Viols, Similar Viols, SALPs): _SL III no CP for operators failure to follow procedure for U2 Turbine Failure in i1/91;_SALP: EP - 1, OPS -2, Erl'S - 2 Prior Notice of Previous Problems (i.e., Audits, Information Notices, Bulletins, NMSS Newsletters, etc.):
None Multiple Examples: _At least one operator was involved in entering an invalid password Duration:
N/A Board Recommendations:
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