ML20207D095
| ML20207D095 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 12/19/1986 |
| From: | Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8612300326 | |
| Download: ML20207D095 (3) | |
Text
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'o D.EC 191986 Docket No. 50-373 Docket No. 50-374 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:
This is in response to a letter dated June 27, 1986, from Mr. C. M. Allen of your nuclear licensing staff to Mr. J. G. Keppler, Regional Administrator, which transmitted a proposed revision to the LaSalle County Station's Emergency Action Levels (EALs) and a supporting "BWR EAL Philosophy" document.
The staff's comments on both documents are provided as an attachment to this letter. As indicated by these comments, additional information must be submitted, and some revisions must be made before the proposed EALs can be considered acceptable.
If there any questions, please have your staff contact Mr. Tem Ploski of my staff at (3I2) 790-5529.
Thank you for your cooperation.
Sincerely, FQriginal signed by 7.D. Shnfm w W. D. Shafer, Chief Emergency Preparedness and Radiological Protection Branch
Attachment:
As stated cc w/ attachment:
D. L. Farrar, Director of Nuclear t.icensing G. J. Diederich, Plant Manager DCS/RSB (RIDS)
Licensing Fee Management Branch Resident Inspector, RIII e6123o0326 861219 Phyllis Dunton, Attorney PDR ADOCK 05000373 General's Office, Environmental F
PDR Control Division l
David Rosenblatt, Governor's y
Office of Consumer Services
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D. Matthews, EPB, OIE RII RIII RIII RT AS WOh
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P1 ski /Ims Snell FrT p
SPECIFIC EAL COMMENTS Unusual Event a.
Conditions 2B, 3A, and 6A: These EALs are not consistent with regulatory guidance. By not declaring an Unusual Event until power level has been reduced to 50 percent, the licensee is in disagreement with the NUREG-0654, Revision 1 rationale for Unusual Event EALs which 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 may be indicative of more serious conditions which are not yet fully realized."
An Unusual Event should be declared when the decision is made to begin shutdown per Technical Specifications, and not only after a specified power level has been reached. Therefore, the power level criterion must be removed from these EALs.
b.
Condition 2E: As worded, the EAL does not take into consideration the possibilities of: a buildup of radioactivity in the suppression pool; a valve continuing to relieve after the reactor is out of mode 1 or 2; or a breach in the reactor coolant system. Therefore, the criteria of reactor mode and suppression pool temperature must be removed from this EAL.
c.
Condition 68: This EAL is inconsistent with regulatory guidance in that the licensee would not declare an Unusual Event unless off-site assistance had been requested. The criterion that off-site assistance has been requested must be removed from this EAL.
d.
The proposed EALs do not address the following situations that are included in the regulatory guidance:
fuel damage indication as evident by high off gas as detected by an air ejector monitor; loss of capability to communicate with offsite emergency support organizations; any tornado onsite; unusual aircraft activity over the site; and unit shutdown other than a normal, controlled shutdown. The proposed EALs must address the aforementioned circumstances.
e.
Conditions 7A and 7B: The wording of these EALs implies that the gaseous releases must originate onsite in order to warrant an Unusual Event declaration. However, regulatory guidance states that the release can occur onsite or near-site. These EALs should be reworded to indicate that near-site releases could also warrant an Unusual Event declaration.
Alert Conditions 3E and CH: The licensee's position is that even if no backup method of achieving and maintaining cold shutdown is available, an Alert declaration is not warranted. This position lacks the conservatism of the regulatory guidance. These EALs must be revised so that an Alert would be declared if only one system for achieving and maintaining cold shutdown is available.
r I
Site Emergency a.
Conditions 3I and 6R: The licensee's position is that even if no backup method of achieving and maintaining hot shutdown is available, a Site Emergency declaration is not warranted. This position lacks the conservatism af the regulatory guidance. This EAL must be revised so that a Site Emergency would be declared if only one system for achieving and maintaining hot shutdown is available.
b.
The proposed EALs do not specifically address the following situations that are included in the regulatory guidance: transient requiring operation of shutdown systems with failure to SCRAM; fire compromising functions of safety systems; and most or all annunciators lost with a transient initiated or in progress. The proposed EALs must be revised to address these situations.
c.
Condition 6S: The licensee has eliminated from this EAL any of the NUREG's concern for the timeliness of re-establishing control from local stations.
It is understood that the timeliness of re establishing control is a function of the numbers and relative locations of remote control stations in each of the BWR stations. Nevertheless, the wording of this EAL should be revised so that a Site Emergency will be declared if control has not been re-established within a reasonable amount of time after Control Room evacuation, given the design and layout of the particular BWR station.
General Emergency a.
Condition IS: This EAl. must be revised to conform with regulatory guidance to also address the possibility that dose rates of at least 1R/hr at the site boundary could be determined from measurements by field survey teams, b.
Along with the proposed EALs, the licensee submitted a "BWR EAL Philosophy" document dated November 1985. The document described the rationales behind the wording of the various EALs.
However, with regards to the following General Emergency EALs, the document referred to guidance for PWR EAls rather than to BWR EAls: 2P, 2Q, 3L, 3M, 6Y, 6Z, 9G, and 9H.
Other The licensee's submittal was incomplete as a number of EALs for Condition 1 (Radioactive Effluent Releases) were still being developed by the licensee's architect / engineer. The following EALs must, therefore, be submitted for staff review:
IB, IC, 1H, IN, 10, 1P, and IT.
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