ML20138P296
| ML20138P296 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 12/19/1985 |
| From: | Adensam E Office of Nuclear Reactor Regulation |
| To: | Corbin McNeil Public Service Enterprise Group |
| References | |
| NUDOCS 8512260039 | |
| Download: ML20138P296 (8) | |
Text
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UNITED STATES 4
NUCLEAR REGULATORY COMMISSION o
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December 19, 1985
- Docket No. 50-354 Mr. Corbin A. McNeill, Jr., Vice President-Nuclear Public Service Electric & Gas Company Nuclear Administration Building P.O. Box 236 Hancocks Bridge, New Jersey 08038 Dea'r Mr. McNeill
Subject:
Request for Additional Information -
Emergency Action Levels We have completed our review of the emergency classification scheme contained in Section 5.0 (Rev. 4) of the Hope Creek Generating Station Radiological Er.ergency Plan. As a result of our review, we find that additional information/
clarification (see enclosure) is required on the Emergency Action Levels (EALs) listed in Table 5-1 of the Plan (which referenced the Hope Creek Technical Specifications) before we can conclude that the EAls conform to the guidelines expressed in Appendix 1 to NUREG-0654.
In addition, there are several instances in Table 5-1 where the notation
"(later)" is used. The missing information must be incorporated in a plan revision before our review of the EAL scheme can be completed.
If you desire any discussion or clarification on the infonnation requested, please contact NRC Project Manager, David Wagner, on (301) 492-8525.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.
Sincerely, m4;q
...e
/
h Elinor G. Adensam, Director Project Directorate No. 3 Division of BWR Licensing
Enclosure:
As stated cc:
See next page ff L
8512260039 851219 PDR ADOCK 0500 4
F
Mr. C. A. McNeill Public Service Electric & Gas Co.
Hope Creek Generating Station cc:
Gregory Minor Susan C. Remis Richard Hubbard Division of Public Interest Advocacy Dale Bridenbaugh New Jersey State Department of MHB Technical Associates the Public Advocate 1723 Hamilton Avenue, Suite K Richard J. Hughes Justice Comples San Jose, California 95125 CN-850 Trenton, New Jersey 08625 Troy B. Conner, Jr. Esquire Office of Legal Counsel Conner & Wetterhahn Department of Natural Resources 1747 Pennsylvania Avenue N.W.
and Environmental Control Washington, D.C.
20006 89 Kings Highway P.O. Box 1401 Dover, Delaware 19903 Richard Fryling, Jr., Esquire Mr. K. W. Burrowes, Project Engineer Associate General Solicitor Bechtel Power Corporation Public Service Electric & Gas Company 50 Beale Street P. O. Box 570 TSE P. O. Box 3965 Newark, New Jersey 07101 San Francisco, California 94119 Manager - Licensing Regulation Resident Inspector c/o Public Service Electric & Gas U.S.N.R.C.
Bethesda Office Center, Suite 550 P. O. Box 241 4520 East-West Highway Hancocks Bridge, New Jersey 08038 Bethesda, Maryland 20814 Ms. Rebecca Green Richard F. Engel New Jersey Bureau of Radiction Deputy Attorney General Protection Division of Law 380 Scotch Road Environmental Protection Section Trenton, New Jersey 08628 Richard J. Hughes Justice Complex CN-112P Trenton, New Jersey 08625 Mr. Robert J. Touhey, Mr. Anthony J. Pietrofitta Acting Director General Manager DNREC - Division of Power Production Engineering Environmental Control Atlantic Electric 89 Kings Highway 1199 Black Horse Pike P. O. Box 1401 Pleasantville, New Jersey 08232 Dover, Delaware 19903 i
Regional Administrator, Region I Mr. R. S. Salvesen U. S. Nuclear Regulatory Commission General Manager-Hope Creek Operation 631 Park Avenue Public Service Electric & Gas Co.
King of Prussia, Pennsylvania 19406 P.O. Box A Hancocks Bridge, New Jersey 08038
ENCLOSURE HOPE CREEK EAL REVIEW Item 1:
Page 5.8, Section 2 - Abnormal Reactor Coolant Leak Rate.
The EAL for Notification of Unusual Event (NUE) reads " Plant shut-down is initiated per any action statement of 3.4.3.2."
Analysis: This EAL for a NUE requires that the classifier refer to the cited technical specification and know how to inter-pret it. The technical specification action statement 3.4.3.2.d encompasses conditions that are not directly indicative of RCS leakage (e.g., valve leakage pressure monitors inoperable).
Interpreting the cited technical specifications requires reference to yet another section for the definition of " Pressure Boundary Leakage."
Recommendation - It is recommended that this EAL be revised as follows:
- 1. Any Pressure Boundary Leakage, e.g., a non-isolable fault in an RCS component, pipe wall or pressure vessel, OR l
-> 2. 5 gpm or more unidentified leakage, OR
- 3. 25 gpm or more identified leakage, averaged over any 24-hour period.
Item 2r Page 5.8, Section 2 - Abnormal Reactor Coolant Leak Rate The EAL for an Alert requires that conditions for 2A be satisfied, and that RCS leakage surveillance indicates a leak rate greater than 50 gpm.
Analysis: The reason for this and linking is not clear.
Recommendation: - It is recommended that this EAL be revised as follows:
- 1. Reactor coolant leakaoc surveillance indicates a leak rate of greater than 50 gpm.
4 Item 3:
Page 5.12, Section 4 - Loss of Decay Heat Removal The EAL for an Alert includes " Complete loss of Safety Auxiiiaries Cooling System (SACS) operability, as in-dicated by:
Plant shutdown is initiated per any action statement 3.7.1.1."
Analysis: Action Statements of 3.7.1.1 cover a range of plant conditions and a range of partial operability conditions for the SACS.
Therefore, the EAL, as stated, is self-contradictory and could confuse the control room staff trying to apply it.
The action statements associated with partial operability of the SACS are obviously not consistent with an Alert condition. The only action statements consistent with an Alert condition are those for_ complete loss of SACS.
Recommendations: - It is recommended that this EAL be revised as follows:
C. SNSS/EDO determines that both subsystems of the Safety Auxiliaries Cooling System (SACS) are inoperable.
_.._____.m a Item 4:
Page 5.20, Section 9 - Electrical Power Failures The EAL for a NUE includes " Degraded onsite AC-power Capability (i.e., emergency diesel generators), as indicated by plant shutdown initiated as required per any action statement of i
Technical Specifications 3.8.1.1," OR 1
" Degraded DC Control Power Capability (inoperability of any of channels A, B, C or D) or per any action statement of T.S.3.8.2.1."
Analysis: The statement of this NUE initiating condition is more consera-tive than the NUREG-0654 example initiating condition NUE-7, because it includes as conditions, " loss of some onsite power or DC power capability" (e.g., partial loss of onsite AC or DC power).
The decision to go with a more conservative " partial loss" criterion for the NUE classification requires a complex and lengthy set of definitions of all the possible " partial loss" l
conditions. Because the cited technical specification action statements already define various levels of electric power system degradation, a choice was made to use entry into those action statement as Eats rather than redefining the " partial loss" conditions for this EAL set.
By doing this, a number of l
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conditions have been conservatively included for which activation of the emergency response organization is probably not appropriate. This may be a redundant attempt to cover NUREG 0654 example initiating condition NUE-15, which is adequately covered in Section 10 of Table 5-1.
Recommendations:
It is recommended that this EAL be revised as follows:
A. Loss of all offsite power (i.e., loss of power to 4.16 KV vital buses), as indicated by both of the following annunciators:
- 1. Station Service Transformer 1AX501 TRBL (E3-B1)
- 2. Station Service Transformer IBX501 TRBL (E3-84)
AND At least (3) emergency diesel generators start and energize the 4.16 KV sital buses.
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. OR B. The SNSS/ED0 determines that onsite AC power capability (emergency diesel generators) or DC control power capability is significantly degraded.
Also, on page 5.21, it appears that the word " Alert" should appear at the top of the ELASSIFICATION column opposite EAL Statement B.
The words " Site Area Emergency" should be opposite EAL statement 9.C.A, farther down the CLASSIFICATION column.
Item 5:
Page 5.22, Section 10 - Technical Specifications Items - EAL Related.
The EALs for a NUE include " Shutdown initiated to comply with Technical Specifications Action Statements (with the exception of Safety Limit Technical Specifications)" OR
" Shutdown initiated to comply with Technical Specifications exceeding Safety Limits as defined in T.S.2.0."
Analysis:
These references to Technical Specifications appear to be an appropriate means of satisfying NUREG-0654 example initiating condition NUE-15.
Recommendation: No change from current wording.
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