ML20214R506

Forwards Comments & Questions on Plant Emergency Classification & Action Level Scheme Review.Schedule for Response Requested

ML20214R506
Person / Time
Site:	South Texas
Issue date:	11/26/1986
From:	Kadambi N Office of Nuclear Reactor Regulation
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8612080001
Download: ML20214R506 (11)

Text

g Docket Nos.: 50-498 and .50-499 Mr. J.H. Goldberg, Group Vice President - Nuclear Houston lighting and Power Company P. O. Box 1700 Houston, TX 77001

SUBJECT:

NRC STAFF REVIEW 0F THE SOUTH TEXAS PROJECT EMERGENCY Cl.ASSIFICATION AND ACTION LEVEL SCHEME.

The staff has conducted the sub. ject review as part of the review at the STP Emergency Plan. The review has resulted in the enclosed comments and questions. Please inform us as to your schedule for responding to the enclosure.

Please contact me at (301) 492-7272 if you have any questions.

Sincerely, e

N. Prasad Kadambi, Pro. ject Manager PWR Pro. ject Directorate No. 5 Division of PWR licensing-A

Enclosure:

As stated

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Docket Nos.: 50-498 and 50-499 Mr. J.H. Goldberg, Group Vice President - Nuclear Houston I.ighting and Power Company P. O. Box 1700 Houston, TX 77001

SUBJECT:

NRC STAFF REVIEW 0F THE SOUTH TEXAS PROJECT EMERGENCY Cl.ASSIFICATION AND ACTION LEVEL. SCHEME.

The staff has conducted the sub. ject review as part of the review at the STP Emergencv Plan. The review has resulted in the enclosed comments and questions. Please inform us as to your schedule for responding to the enclosure.

Please contact me at (301) 492-1272 if you have any questions.

Sincerely,

&b wh N. Prasad Kadambi, Project Manager PWR Project Directorate No. 5 Division of PWR I.icensing-A

Enclosure:

As stated cc: See next page

o Mr. J. P. Goldberg Houston lighting and Power Company South Texas Project 4

CC*

Brian Berwick, Esq. Resident Inspector / South Texas Assistant Attorney General Project Environmental Protection Division c/o U.S. Nuclear Regulatory Commission P. O. Box 12548 P. O. Box 910 Capitol Station Bay City, Texas 77414 Austin, Texas 78711 Mr. Jonathan Davis Mr. J. T. Westermeir Assistant City Attorney Manager, South Texas Project City of Austin Pouston 1.ighting and Power Company P. O. Box 1088 P. O. Box 1700 Austin, Texas 78767 Pouston, Texas 77001 Ms. Pat Coy Mr. P. l.. Peterson Citizens Concerned About Nuclear Mr. G. Pokorny Power City of Austin 5106 Casa Oro P. O. Box 1088 San Antonio, Texas 78233 Austin, Texas 78767 Mr. Mark R. Wisenberg Mr. J. B. Poston Manager, Nuclear I.icensing Mr. A. Von Rosenberg Houston I.ighting and Power Company City Public Service Boad P. O. Box 1700 P. O. Box 1771 Pouston, Texas 77001 San Antonio, Texas 78296 Mr. Charles Halligan Jack R. Newman, Esq. Mr. Burton I. Lex Newman & Poltzinger, P.C. Bechtel Corporation 1615 1. Street, NW P. O. Box 2166 Washington, D.C. 20036 Pouston, Texas 77001 Melbert Schwartz, Jr., Eso. Mr. E. R. Brooks Baker & Botts Mr. R. l. Range One Shell Plaza Central Power and I.ight Company Pouston, Texas 77002 P. O. Box 2122 Corpus Christi, Texas 78403 Mrs. Peggy Buchorn Executive Director Citizens for Equitable Utilities, Inc.

Route 1, Box 1684 Brazoria, Texas 77422

g Houston I.ighting & Power Company South Texas Project cc:

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Office of Executive Director for Operations 611 Ryan Plaza Drive. Suite 1000 Arlington, Texas 76011 Mr. 1.anny Sinkin, Counsel for Intervenor Citizens Concerned about Nuclear Power, Inc.

Christic Institute 1324 North Capitol Street Washington, D.C. 20002 1.icensing Representative Houston 1.ighting and Power Company Suite 1309 7910 Woodmont Avenue Bethesda, Maryland 20814 -

, SOUTH TEXAS PROJECT El.ECTRIC GENERATING STATION EMERGENCY ACTION 1.EVEl. REVIEW l.0

SUMMARY

This review of the South Texas Pro.iect (STP) Emergency Action f.evels (EAI.s) focused on Emergency Classification Procedure (0EPP01-ZA-0001),

Draft, Revision 2. This procedure is su'ostantially changed from the original. The procedural steps and the document layout (format) are entirely different. From a review / evaluation standpoint this is a new document.

The procedure consists of the following:

The basic procedure.

Addendum 1; EAl. Table, which is a flow chart used to direct the user from 4 basic modules listed as:

A. RADI01.0GICAI.

B. OPERATIONAL.

C. FIRE-NATURAL.-SECURITY D. MISCEl.l. ANE0VS to one or more of 13 submodules in Addendum 2.

Addendum 2; Classification Guide, which are abnormal conditions, initiating conditions, leading to event classification.

Addendun 3; Correlation of Design Basis Accidents, which lists the DBA and the Emeroency Classification with reference to the FSAR and NUREG 0654.

Attachment 2; NUREG 0654 Appendix 1 Cross Reference. Addendum 3 is also referred to as Attachment 1. This inconsistency should be corrected.

2.0 COMMENTS 2.1 GENERAL. COMMENTS a) Addendum I and portions of Addendum 2 are very difficult to read. The copy quality is poor, b) The format of Addendum 2 is inconsistent. For example:

The Radiolooical Module in the EAl. column is in outline form using lower case letters for each parameter. However, this format is not followed in the entire module.

I All the remaining modules use upper case letters in the outline format.

in the operational module, EAl. column 3.11.1, the C.

condition is not in outline format.

- - _ . _ - _ = _ _ _ . _ _ _ _ . _ -

Portions of the Operational Module are entirely in upper case letters. Other sections use a combination of upper and lower case letters.

The print type and size varies throughout the procedure.

It is recommended that procedure ZA-0001 be formatted using accepted human factors techniques.

c) The Radiological Module, Submodule 2 uses and "and/or" condi-tional statement in several EAI.s. The use of "and" statements to require two or more conditions to satisfy an event and the use of an "or" statement to require only one of two or more conditions to satisfy an event is acceptable. However, the use of "and/or" is confusing. Generally, "and" or "or", should be highlighted in some manner, not buried in the text where they can be easily missed, di It is recommended that us of "and/or" statements be eliminated and all tie statements be highlichted, by capitalizino, under-linino, or use of bold-face print, el Addendum 1. Eneroency Action f.evel Table. This flow diagram should be helpful to the user, facilitating quick access to the appropriate submodule(s) in addendum 2. The print quality of the provided copy is poor and should be improved for use in the procedure.

2.7 ADDENDUM 2, Cl.ASSIFICATION GUIDE al Radiolooical Submodule 1 Initiating Condition (IC) 1.3 -- Radiation levels or airborne contamination levels... increase by a factor of 1000. The EAI.

for this IC states: " Corresponding alarms on:

a. Radiation monitoring system

b. Ruilding ventilation monitors

c. Continuous air monitors

d. Effluent monitors."

Are all the alarms set at 1000X the normal readings? It appears that any alarm or alarms on the above monitors will cause an Alert Classification. Is this the intent of this IC?

IC 1.4 -- Gaseous and/or liquid effluent...No liquid effluent monitor is listed in the EA'. column, IC 1.5, 1.6 and 1.7 do not include the meteorlogical conditions required by NUREG 0654.

b) Radiological Submodule 2 IC 2.1 -- Fuel damaoe indication. The EAI. states, in part "less than or equal to 1.0 uCi/om, and, less than or equal to 100/E-Bar uCi/gm gross..."

-p-

' Should the statement read, "creater than"? Do these conditions accurately state the Technical Specifications (TS)? Will this '

EAl. trigger a classification that may not be required?

IC 2.1 (continued). The EAI. states in part " Alert on failed fuel monitor". NUREG 0654 allows for an increase of 0.1%

equivalent fuel failures within 30 minutes.

The EAI. uses a fixed setpoint, which does not allow a trend observation. Is the setpoint equivalent to 0.1% fuel failure?

Will the selected setpoint trigger a classification that may not be reouired?

IC 2.3 -- Severe loss of fuel cladding. The EAl. states in part

" reactor greater than 20% power, and/or failed fuel monitor alarm."

What covers the conditions when the power is less than 20%. Is the setpoint selected on the monitor eouivalent to the NUREG 0654 requirement of increase greater than 1% fuel failures within 30 minutes or 5% total fuel failures?

IC 2.5 -- Degraded core with possible loss of coolable geometry.

The EAI. states in part " Evidenced by low flow and high core differential pressure ... and containment dose radiation monitor".

What values for the selected parameters are expected for this IC?

IC 2.6 - 1.oss of 2 of 3 fission product barriers (FPB). The EAI. states "As indicated by combination of above".

The above does not adequately address the Reactor Coolant System (RCS) or the containment barriers. The IC does not address a challenge to or potential loss of the third barrier as required by NUREG 0654. If one FPB is intact with no potential for loss, then based on FPB analysis the classification will be lower than General Emergency.

Specific plant parameter readings to indicate a breached condi-tion for each FPA should be included in this procedure.

c) Operational Submodule 3 IC 3.1 -- Failure of a safety or relief valve etc... The EAl. Is missino a panel number.

IC 3.2 -- Exceedino either primary / secondary leak rate TS or primary leak rate TS.

Which EAI. addresses the primary leak rate portion of this IC?

IC 3.4 -- Primary coolant leak rate greater than 50 GPM.

,, No value is provided for the RCB atmosphere monitor. How does the procedure user determine the leak rate greater or less than 50 GPM? Is there a makeup rate or floor drain fill rate that would indicate the RCS leak rate?

IC 3.5 -- Rapid failure of steam generator tubes. No steam generator parameters are included in the EAL.

Are there any observable steam generator parameters that could be used to indicate this type of tube failure? Could this event cause a safety to lift?

IC 3.6 -- Steam line break with greater than 50 GPM primary to secondary leakage and indication of /uel damage. The EAI.

requires that RCS activity exceed 300 uCi/gm dose equivalent I-131 to trigger this classification.

If the steam line break is inside containment, will the main steam line monitors detect the break? Could the containment high rance monitors be used for indication? Typical RSC sample time for dose equivalent I would be approximatelv 45 minutes, which delays the classification. What installed process moni-tors could be used for indication of fuel damage?

IC 3.7 -- Rapid failure of steam generator tubes with loss of offsite power. The EAI. contains an "and" statement that is not understood. No value is provided for condenser vacuum pump discharge.

What is the purpose of the "and" statement? What value should be used for the condenser vacuum pump discharge?

IC 3.8 -- Small and large LOCA's with failure of ECCS to perform leading to severe core melt in minutes to hours. Breach of containment likely. The EAI. lists high containment pressure with ro value provided.

The classification for IC 3.8 is incorrectly given as Site Area Emeroency. It should be General Emergency. What value is considered high containment pressure?

IC 3.9 -- Known loss of coolant activity (the word " activity" should be " accident"). 1.0CA greater than makeup capacity. The EAL lists: Observation of ECCS initiation and pressurizer level low level alarm.

The classification for IC 3.9 is incorrectly given as General Emergency. It should be Site Area Emergency. The makeup capacitv addressed here means, or should mean, normal makeup capacity. It does not mean the makeup capacity of the high volume ECCS pumps. IC 3.9 should be rewritten using normal makeup capacity volumes.

-4

E

, IC 3.11 -- ATWAS resulting in core damage or additional failure of core cooling or makeup systems. The EAL l.ists elevated reactor coolant activity. No value is provided for the reactor coolant activity.

What value will be used for reactor coolant activity? Again, the delay while waiting for a sample will result in a delay in the classification.

di Operational Submodule 4 IC 4.5 and 4.6 -- loss of AC and DC power for more than 15 minutes. The EAI.s list inability to recover within 15 minutes.

Why does the EAI. repeat the Initiating Conditions?

e) Operational Submodule 5 IC 5.1 -- Any TS 1.00 resulting in shutdown. The EAI. lists loss of meteorlogical assessment capabilities.

A. Meterological towers AND instrumentation; B. Inability to establish communications with the National Weather Service via commercial telephone.

Should the AND statement be an OR statement? The EAI. does not address a loss of normal emergency communications.

IC 5.4 -- Emergency core cooling system initiated and discharge to vessel. This EAI. reauires indication of safety injection with an Emeroency Core Cooling parameter not being maintained.

The NUREG states, "ECCS initiated and discharge to vessel."

IC 5.5 -- Complete loss of all capabilities needed for plant shutdown. The attachment 2 cross reference states this IC relates to NUREG 0654 Alert number 10, which states; complete loss of any function needed for plant cold shutdown.

Should IC 5.5 read, ..." plant cold shutdown"?

f) Operational Submodule 6 IC 6.1 -- Failure of the rector protection system to automati-cally initiate and complete a scram, which brings the reactor suberitical. The EAf. relies on indication of the computer printout for rod positions.

Is the computer system a safety system suitable for classifica-tion durino emergency conditions? IC 6.2 and IC 6.3 do not use the computer system for rod position, c) Operational Submodule 7 No Comments.

s. 'h) Operational Submodule 8 No enmments.

1) Fire / Natural / Security Submodule 9 No comments, j) Fire / Natural / Security Submodule 10 No comments, ki Fire / Natural / Security Submodule 11 IC 11.2 and 11.3 -- Several natural phenomena being experienced or projected... The EAL lists the seismic monitor values as 0.1 g for both IC 11.2, Alert and 11.3, Site Area Emergency. IC 11.3, in addition to the seismic activity, requires safety system damage.

Do the selected values of seismic activity meet the requirement of NUREG 0654 Alert #17a and Site Area Emeroency #15a? Why is safety system damage required in IC 11.37 The NUREG states for Site Area Emergency, "Earthouake greater than SSE levels." ,

1)  !!iscellaneous Submodule 12 IC 12.1 to IC 12.6 -- The NUREG lists multiple examples of hazards that relate to these EAl.S. The procedure does not include the NUREG examples. The procedure relies on the user to differentiate between hazard and severe hazards without the benefit of any helpful examples.

It is recommended that the examples provided in the NUREG be included in these EAl.s.

m) Miscellaneous Submodule 13 TC 13.1 -- Transportation of contaminated individual.... The EAl. states "As determined necessary by the Radiological Direc-tor, Emergency Director or Shift Supervisor."

Does this allow the Radiological Director to classify for this event?

General comment for addendum 2. Addendum 2 is very difficult to use. The EAI. blocks do not tie tcoether multiple plant limits necessary to satisfy a classification. For those conditions when a single plant limit satis-fies a classfication, it is not always immediately clear. A human factors approach is strongly sugoested to make this potion of the procedure easier to uso during off normal events.

I I

i j  !

, 2.3 ADDENDUM 3. COREl.ATION OF DESIGN BASIS ACCIDENTS This section of the procedure lists each design basis accident (D8A) in column format. A second column lists the emergency classification. ho plant parameters are provided. Many of the DBAs are repeats of those listed in Addendum 2. Powever, the detailed descriptions used in Addendum 2 are not provided in this section.

It is recommended, to avoid potential confusion, that those events repeat-ed in Addendum 3 provide a reference directing the user to the appropriate submodule(s) of Addendum 2. And, for those DBAs that do not have detailed descriptions in Addendum 2, plant parameters should be provided in the DBA Addendum.