ML20212H908
| ML20212H908 | |
| Person / Time | |
|---|---|
| Site: | Zion, LaSalle, 05000000 |
| Issue date: | 01/12/1987 |
| From: | Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8701280052 | |
| Download: ML20212H908 (5) | |
Text
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J AN 121987 Docket Nos. 50-373, 50-374 Docket Nos. 50-295, 50-304 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 October 23, 1986, from Ms. I. Johnson of your nuclear licensing staff to Mr. J. G. Keppler, Regional Administrator, which transmitted a proposed revision to the Zion Station's Emergency Action Levels (EALs) and a supporting "PWR EAL Philosophy" document. The staff's comments on these submittals are provided as an attachment to this letter. As indicated by these comments, some revisions must be made before the proposed EALs can be considered acceptable. The attachment to this letter also contains two comments, applicable to the La Salle Station's proposed EALs, that are in addition to the comments on those EALs that were provided to you by our letter dated December 19, 1986.
If there are any questions, please have your staff contact Mr. T. Ploski of my staff at (312) 790-5529.
Thank you for your cooperation.
Sincerely, U.D. Shafer" woriginal sign d b7 W. D. Shafer, Chief Emergency Preparedness and Radiological Protection Branch
Attachment:
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D. L; Farrar, Director of Nuclear Licensing G. J. Diederich, Plant Manager DCS/RSB(RIDS)
Licensing Fee Management Branch
' Resident Inspector, RIII Phyllis Dunton, Attorney General's Office, Environmental-Control Division David Rosenblatt, Governor's Office of Consumer Services G. J. Plim1, Station Manager Jan Norris, Project Manager, NRR Mayor, City of Zion D. Matthews, EPB, 01E P
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SPECIFIC EAL COMMENTS Unusual Event a.
EALs 2F, 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 pron.pt 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.
EAL 2a: As an improvement, the coolant activity should be stated in terms of dose equivalent Iodine 131.
c.
EAL 6b: This EAL indicates that an Unusual Event would only be declared if offsite assistance had been requested. The criterion that offsite i
assistance must first be requested is inconsistent with regulatory guidance and must be deleted from this EAL. (See Comment "a" above regarding the NUREG-0654 rationale for Unusual Event EALs.)
d.
The proposed EALs do not address the following situations that are included in the regulatory guidance:
loss of capability to communicate with offsite support organizations; any tornado onsite (regardless of the associated damage caused onsite); unusual aircraft activity over the site; unit shutdown other than a normal, controlled shutdown; onsite train derailment; near or onsite explosion; and failure of a turbine rotating component causing rapid plant shutdown. The proposed EALs must be revised to address the aforementioned circumstances that are included in the regulatory cuidance.
Alert a.
EALs 3E and 6H: 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, b.
EAL 3H: As an improvement, the licensee should evaluate the possibility that a loss of all or most of the annunciators on one or two of the specified panels may constitute the same level of plant safety degradation as the loss of most annunciators on all three specified panels.
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j c.
EAL 40: As an improvement, this EAL should be reworded to read "10 gpm or greater" primary to secondary leakage.
d.
EAL 5A:
It is not apparent that the proposed EAL addresses the possibility of a ventilation equipment failure (to divert) which could result in a release to the environment. Also, it is not clear that the EAL satisfies the concern of example Alert condition number 12, as contained in NUREG-0654, with respect to a release originating either in containment or in the fuel handling building.
If monitor AR03 is located in containment, the AND condition in EAL SA may not be satisfied.
If monitor AR03 is in the fuel handling building, there is no EAL which
. adequately addresses a fuel handling accident inside containment.
Therefore, the licensee must revise the Alert EALs for Condition 5 to ensure that the possibilities of releases originating either in containment or in the fuel handling building are both adequately addressed.
j e.
EAL 6N: The licensee must re-evaluate this EAL versus the regulatory guidance to ensure that a crash causing damage to the switch yard or to other structures within the owner controlled area (e.g. training buildings) would be classified as an Alert.
f.
EAL 8H: The PWR EAL Philosophy document refers to a non-existant EAL 7J when providing the rationale behind EAL 8H. The misleading reference in the phil'osophy document should be corrected.
g.
The proposed Alert EALs do not address the following situations that are included in the regulatory guidance: indication of 5 percent total fuel failure; and any tornado striking the facility (regardless of associated
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damage to onsite facilities). The proposed EALs must be revised to l
address the aforementioned situations.
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j Site Area Emergency a.
EALs IM and IN (IM for La Salle EALs): The EALs are inconsistent with regulatory guidance in that only a dose rate associated with a whole body exposure limit has been specified. The Site Area Emergency EALs for radioactive releases must be revised to also address a dose rate associated with a thyroid exposure limit at the site boundary.
b.
EAL 2R:
It is not clear whether this or any other Site Emergency EAL addresses the possibility that a steam generator tube rupture with a leak rate less than makeup capability, in conjunction with a loss of offsite power, could result in a substantial unmonitored release. The licensee must re-evaluate the proposed EALs to ensure that the aforementioned situation has been adequately addressed as warranting a Site Emergency declaration.
)
c.
EALs 31 and 6R: The licensee contends that even if no backup method of achieving and maintaining hot shutdown is available, a Site Area Emergency declaration is not warranted. This position lacks the conservation of i
1
a f) the regulatory guidance. These EALs must be revised so that a Site Area Emergency would be declared if only one means for achieving and maintaining hot shutdown is available.
d.
EAL SC: The same comment as given for EAL'5A applies to EAL SC. The licensee must revise the Site Area Emergency EALs for Condition 5 to ensure that the possibilities of releases originating either in containment or in the fuel handling building are both adequately addressed.
e.
The proposed Site Area Emergency EALs do not address the following situations that are included in the regulatory guidance:
transient requiring operation of shutdown systems with failure to scram; fire actually compromising the functions of safety systems; most or all annunciators lost 'and a transient initiated or in progress; and actual severe damage to. safe shutdown equipment from missiles or explosion.
The proposed EALs must be revised to address the aforementioned situations.
General Emergency a.
EALs 15 and IT (15 for La Salle EALs): The EALs are inconsistent with regulatory guidance in that only a dose rate associated with a whole body
, exposure limit has been specified. The General Emergency EALs for radioactive releases must be revised to also address a dose rate associated with a thyroid exposure limit at the site boundary.
b.
EAL IS and IT: These EALs must be revised to conform with regulatory guidance to also address the possibility that the whole body and thyroid exposure limits could be determined from measurements made by field survey teams.
c.
EALs 20, 3N, 6Z, and 9L: The use of the word " total" should be re-evaluated versus a more conservative word such as "significant", since significant core degradation warranting a General Emergency declaration could occur without total core uncovery.
.