ML20138H183

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Forwards Comments & Changes on Draft Salem AIT Rept
ML20138H183
Person / Time
Site: Salem  PSEG icon.png
Issue date: 01/28/1993
From: Mccabe E
NRC
To: Ruland W
NRC
Shared Package
ML20138G636 List:
References
FOIA-96-351 NUDOCS 9701030147
Download: ML20138H183 (4)
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From Ebe C. McCabe (ECM1)

To KP2(WHR)

Date:

Thursday, January 28, 1993 11:54 am 4

Subjects DRAFT SALEM AIT REPORT

Bill, Craig Gordon tells me that the comments / changes he gave you on the draft AIT report should address most or all of my concerns.

Since he didn't have a later report draft and couldn't fina you to get one, I'm sending the attached comments on the version I got from E-mail.

Will be glad to comment on the revised version when received.

Ebe PS:

Although the Wordperfect version essentially reproduced the ECG specification of declaration of an Alert if "15 minutes have elapsed since the loss of annunciators," E-Mail doesn't reproduce the block diagrams and their content.

It is, however, on the "S"

drive as "SALEMAIT.EP."

CC:

CZG, JHJ, SFS, KP2(JPD)

Files:

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0 9701030147 961226 PDR FOIA O'NEILL96-351 PDR

o SALEM DRAFT AIT REPORT CONCFRNS The primary EP concern about the draft Salem AIT report is the discounting of the importance of classifying and reporting emergency conditions. The RI EP Section Chief's view is that a violation of the emergency plan requirement for classifying the annunciator loss as an Alert occurred in this case, and that it is improper to discount that failure by finding that the licensee failed to make a one-hour non-emergency report of the matter.

In this case, after the fact review / testing indicates (the adequacy of that review / testing was not assessed incident to developing this document) that there was no significant loss of ability to respond to plant conditions. That means that the specific safety significance of this classification and reporting failure was minor. But, that does not alter the fact that, generically, it is-important (and required) to report emergencies. That's essential to the timely initiation of licensee management, NRC, and State and local official oversight / review functions.

The bases of the direction provided by NRC management on timely classification of nuclear power plant emergencies (11/25/86 James M. Taylor Memorandum to James G. Kepler) is relevant to this matter. That memorandum included the following rationale.

"The purpose of the emergency classification and action level scheme is to ensure that licensees accurately and promptly assess, classify and nodfy authorities of an emergency.

In its rationale for the final emergency planning regulations, the Commission stated, 'In order to discharge effectively its statutory responsibilities, the Commission firmly believes that it must be in a position to know that proper means and procedures will be in place to to assess the course of an accident and its poteritial severity, that NRC and other appropriate authorities and the public will be notified promptly, and that appropriate protective actions in response to actual or anticipated conditions can and will be taken.' The intent of the regulations is clear -- to provide for prompt assessment and notification. The wording in Appendix 1 to NUREG-0654 provides further emphasis on the aspect of promptness in notification of offsite authorities."

"A pbnt specific EAL scheme is the mechanism that results in declaration of an emergency class. If plant parameters indicate that conditions have reached an emergency threshold according to the EAL scheme, a declaration is called for. If a declaration is not made at this time, the licensee has not implemented or followed its emergency plan.... "

...While the regulations do not cite a specific allowable time limit between event occurrence and when an emergency must be declared, I believe that the regulations, the guidance provided in Appendix 1 to NUREG-0654, and the regulatory / enforcement history to date provide an adequate basis for issuing violations to those licensees who delay in classifying, declaring and notifying proper authorities of an emergency condition."

It is clear from the above, from 10CFR50.72, and from the EP examples in the NRC Enforcement Policy, that both classification and reporting of emergencies are essential.

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The AIT report does not clearly make the point that failure to classify and report denies senior licensee management, the NRC, and cognizant State and local officials timely opportunity to assess the emergency condition and the correctness of on-shift actions.

At Salem, it also appears that the emergency plan does not call for notification about terminated emergencies without implementing the same response as for ongoing events. A separate decision point is indicated for such cases. The draft AIT report seems to adequately address this aspect.

At Salem, a IAss of Annunciator Alert is specified by the licensee's Emergency Classification i

l Guide, Section 10, Page 1, under the following circumstances.

i B. LOSS OF MOST OR ALL ANNUNCIATION IF 1

i Loss of mosi or all Overhead Annunciators.

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AND 15 minutes have elapsed since the loss of annunciators.

THEN l

REFER TO A'ITACIIMENT 2 ALERT For the Salem loss of annunciators, if the operators had concluded that an Alert declaration was not proper because they had sufficient information, alarms, and staffing to respond to nuclear safety problems, including emergencies, while the annunciators were not working, then it may -

i well have been supportable that they did not declare and report the prescribed Alert. But, the I

indications are that their rationale was that an Aleit need not be declared because it was over.

l (Also, confirmation of sufficiency of the other annunciators was attempted after the event, indicating that there was insufficient basis for such a conclusion when the annunciator loss was l

discovered.)

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A related consideration is that we also need to view any deviation from emergency reponing requirements from the viewpoint of NRC credibility. (New Jersey responded to the Salem event, after the tardy notification.) In this regard, the recently expressed view of Chairman Selin seems relevant. He msponded to a Region III question as follows.

Question: What is the value of emergency exercises?

l Chairman: I personally think one of my biggest advantages here is that I'm not imbued

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with a lot of the history of the Commission and can take a fresh view of a lot of issues.

But the historical viewpoint is essential here. Emergency exercises have grown up as part of an implicit bargain between the Commission, industry, and the general public.

It's a very delicate bargain, and in my view it should not be disturbed. The question about their value is almost secondary to the sanctity of that bargain.

The above perspective is also applicable to other aspects of emergency preparedness, including the reporting of emergency conditicas to off-site officials. If we are to change the a'ssociated mquirements through non-implementation, then we am also transgressing the implicit bargain j

the Chairman remarked upon.

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T, From:

Ebe C. McCabe (ECM1)

To:

Jim Joyner

^- ' '-

/

Date:

Tuesday, February 9, 1993

Subject:

ENFORCEMENT OF NON-DECLARATION OF ALERT AT SALEM The following relates to the above subject.

1.

An emergency must be declared in accordance with the emergency plan and/or procedures, even if the emergency has ended.

Failure to do that is a violation.

(At Salem, the loss of annunciators lasted for more than the 15 minutes required for an Alert classification, and not declaring an Alert was a violation.)

2.

Failure to declare an ongoing emergency, when identified, unduly prevents or delays licensee,

NRC, and State and local responses and analyses.

Failure to declare a terminated emergency, when identified, unduly prevents or delays the typically lesser response of licensee, State, and local review of on-shift actions for appropriateness, and can prevent including the emergency in industry and NRC records / data bases.

Failure to declare a terminated emergency will typically be a less severe violation than failure to declare an ongoing one.

(Each case must be evaluated individually.)

The widespread practice of reporting and closing an emergency at the same time appears to meet the off-site organizations' needs, but some licensees do not have provisions for doing that without also mobilizing their staff as for an ongoing emergency (indicating that plan revisions may be appropriate).

3.

At Salem (this may or may not apply elsewhere), even not declaring an Alert for an ongoing loss of the overhead annunciators might be justifiable because other indicators and/or alarms might allow operation, and initial emergency plan implementation, without additional staffing.

If so, the licensee should modify their emergency plan and proceoures accordingly.

4.

Some emergency plans / procedures allow a licensee to determine that a condition does not warrant an emergency declaration because of lack of safety significance, despite the plan's identification of such an event as an emergency.

Inacmuch as the Salem licensee did not make the Alert declaration because the event was over, no such provision was implemented there (i.e.,

indications are that they would have declared an Alert if the annunciators had remained inoperable).

Also, it would be wise (and probably should be made a requirement) for on-shift and on-call licensee managers to make sure that their management and the NRC and State and local responders know, early on, why a specified emergency classification is not being nade.

Ebe 1l

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