ML20235S461
| ML20235S461 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/28/1986 |
| From: | Jamison J Battelle Memorial Institute, PACIFIC NORTHWEST NATION |
| To: | Perrotti D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20235S055 | List: |
| References | |
| FOIA-87-346, RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8707210666 | |
| Download: ML20235S461 (13) | |
Text
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KaR OBallelle l
Pacific Northwest Laboratories P.O. Bon 999 Ricbland, Washingion U.S.A. 99352 Telephone 1509: 375-3782 l
May 28, 1986 1
Donald J. Perrotti Emergency Preparedness Branch U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Don:
SEABROOKSTATIONEMERGENCYACTIONLEVELS(EALs)
Attached is Gordon Bryan's ~ report of the third technical evaluation of the j
Seabrook Station EALs. This review was made in response to your i
April 17, 1986 request.
1 The first technical review was completed on February 20, 1986 and was based on amendment 55 to the Seabrook Radiological Emergency Plan (SREP) and rev. 3 to Emergency Plan Implementing Procedure ER-1.1, " Classification of Emergencies."
j On February 27, 1986, Gordon and members of the NRC staff met with utility
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personnel to review the initial report.
section 5.0 of the Plan (g, the utility submitted a formal revision ofSREP) to the NRC Prl Subsequent to that meetin No. 5 (PSNH letter SBN-962 T.F. B7.1.8 of 3/6/86). That revision and a draft j
revision 4 to ER-1.1 formed the basis for the second technical review report dated March 24, 1986.
I On March 24, 1986, Gordon and members of the NRC staff met again with the utility and reviewed the second report. On April 2, 1986, PSNH forwarded
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letter SBN-985 to the NRC PWR Project Directorate No. 5, subject " Emergency l
Classification System." On April 11, 1986, PSNH forwarded FSAR Amendment 58 by letter SBN-999. On April 24, 1986, Seabrook promulgated revision 4 to procedure ER-1.1.
The attached report is based on those documents and the
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minutes of the March 24, 1986 meeting that identified all outstanding deficiencies.
Evaluation was made to standards from 10 CFR 50 Appendix E.IV.B and D, and NUREG-0654.
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8707210666 870717
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NO
-346 PDR I
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D. J. Perrotti May 28, 1986 Page 2 OBattelle If I may be of further assistance, please contact me on FTS (509) 375-3782.
Sincerely.
v c=- N J. D. Jamison Technical Leader Emergency Preparedness Group Health Physics Technology Section HEALTH PHYSICS DEPARTMENT JDJ/GRB:sjs Enclosure DB Matthews, w/ enclosure M cc:
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1 TECHNICAL REVIEW OF THE SEABROOK STATION EMERGENCY ACTION LEVELS May 13, 1986 1.0
SUMMARY
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Seabrook has adopted the best of the various EAL schemes available to the industry, a mixture of symptomatic and event-related initiating conditions.
The symptomatic portion of the Seabrook EALs is based on site-specific revisions to the Westinghouse Owner's Group (WOG) Emergency Response Guidelines. (ERGS) and the WOG Critical Safety Function Status Trees (CSFSTs).
The event-oriented portion of the Seabrook EAls stems from Appendix I to NUREG-0654.
The EAL scheme is documented in the Seabrook Radiological Emergency Plan (SREP), the Seabrook Technical Specifications, and Seabrook's Emergency Plan Implementing Procedure (EPIP) ER-1.1 (rev. 4).
With one exception, (Encl. 4, paragraph B, item Alert 10), the reviewer found that the utility has satisfactorily addressed all deficiencies that remained open as of completion of the March 24, 1986 meeting.
Upon correction of the remaining deficiency, the Seabrook EALs will meet the requirements of 10 CFR 50 and the guidance of NUREG-0654 and will be adequate to support licensing of the plant.
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2.0 BACKGROUND
1 This report is the result of the third technical review of the Seabrook
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Station EALs. The first two reviews were based on earlier versions of the 1
Seabrook Radiological Emergency Plan (SREP) and procedure ER-1.1,
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" Classification of Emergencies."
Following the first two reports, the reviewer met with members of the NRC staff and personnel from the utility.
Thereafter, the utility issued formal revisions to the SREP and to procedure ER-1.1.
Seabrook has adopted the best of the various EAL schemes available to the industry, a mixture of symptomatic and event-related initiating conditions.
The symptomatic portion of the program is based on site-specific revisions to the Westinghouse Owner's Group (WOG) Emergency Response Guidelines (ERGS) and the WOG Critical Safety Function Status Trees (CSFSTs) that direct the user to the emergency response procedures and, concurrently, to the accident classification scheme. The event-oriented portion of the EAL scheme stems from Appendix I to NUREG-0654.
Any review of a symptomatic EAL scheme must first consider some of the design criteria implicit in the symptomatic process. The WOG ERGS and CSFSTs assume an initial condition of reactor critical (modes 1 or 2), that the protection system has (or should have) actuated to shut down the reactor, and that no Technical Specification Limiting Conditions for Operations (LCOs) have been exceeded (so as to have a defined minimum equipment capability).
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Although the symptomatic process may appear to be complex, it is an excellent process with only two significant weaknesses; its treatment of radiation, and a tendency toward tardy classification. Both of these weaknesses have been avoided in the composite Seabrook EAL scheme.
3.0 COMPARISON OF THE PLAN AND PROCEDURE " EMERGENCY CLASSIFICATION SYSTEM FLOW CHARTS" EPIPs are intended to implement the Emergency Plan. To evaluate Plan implementation, a side-by-side comparison was made between the Emergency Classification Flow Chart shown in figure 5.6 of the FSAR (part of the Emergency Plan) and the equivalent (unnumbered) page in the classification EPIP, ER-1.1.
The deficiencies that were noted 3/24/86 are stated below, followed by the status of the item at the time of this review.
Item: Miscellaneous emergency condition 7a of the Plan is a Notice of Unusual Event (NOVE)(correct).
In the EPIP, there is no steam generator tube leak condition that leads to a NOVE.
(NUREG-0654, Appendix 1 NOUE Initiating Condition [IC) 5).
l Status: Closed. No NOUE is listed in either the Plan or EPIP for EAL 7.
However, the NUREG-0654 guidance is met under Seabrook EAL lla, technical specification shutdown to cold as required by Technical Specifications (TS)3.4.6.2.
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A Item: The plan lists Ba, 8b, and 8d, omitting 8c.
The EPIP correctly lists Ba-8c; and nomenclature differs between the Plan and the EPIP throughout 1
condition 8 (e.g., inclusion of the words " Fuel Cladding Failure / Melt" in item 8 of the Plan; omission of same words in item 8 of the EPIPs).
j5tatus:
Closed.
Plan and procedure inconsistencies have been corrected.
1 Item: The nomenclature and classifications differ between the Plan and the EPIP for item 15 (e.g., primary or secondary coolant versus emergency coolant recirculation; only one declaration results from the Plan, a General Emergency
[GE], whereas the EPIP lists conditions that can result in an Alert or a GE).
Status:
Closed.
Inconsistencies have been corrected.
Item: The second of three General Emergency conditions listed for the "2 containment integrity" line lists "Z red and 20...."
It should read "Z red and 20a.... "
Status: Closed. Appropriate corrections have been made.
Item:
Item 8b differs, Plan to procedure. See above.
Status: Closed.
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Item:- The Plan entry under the NOUE column of line 11 should be labeled lla.
Status:
Closed Item:
Line 12 entries differ, Plan to procedure (e.g., HP-41, METPAC is excluded, " unexplained" in Plan 12b, etc.).
Status:
Closed. The entries are identical.
Item:
Line 14 entries differ (e.g., no procedure 14b; nomenclature:
Plan 14a and 14b versus procedure 14a; reference to specific procedures; use of
" termination").
Status:
Closed. The entries are identical.
i Item:
Line 15 is inconsistent, Plan to procedure.
Status: Closed. The entries are identical.
Item:
Line 18 is inconsistent Plan to procedure, i
l Status: Closed. The entries are identical.
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CONCLUSIONS 1.
The Plan and procedure Emergency Classification Flow Diagrams are
-identical in content.
2.
All classification flow chart open items from the March 24, 1986 meeting have been resolved.
4.0 _E_MERGENCY PLAN EAL EVALUATION 4.1 GENERAL FINDINGS Item:
Figure 5.3, Critical Safety Function (CSF) for the Heat Sink, is improperly labeled Number 4.
It should be Number H.
Status:
Closed.
4.2 PLAN EALs VERSUS NUREG-0654, APPENDIX 1, GUIDANCE The following open items were closed at the 3/24/86 meeting:
NOVE:
8, 12, 13, 14, 15, and 17.
ALERT:
4, 5, 6, 9, 11, 12, 16, 17, 18, and 19.
SAE:
1, 5, 8,10,11,13b,14,15a-c,16a-c, and 17.
GE:
1, Sa-e, and 7.
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In the remainder of this section, paragraph numbers correspond to those of'the example _ initiating conditions of NUREG-0654, Appendix 1.
Where numbers are omitted, the reviewer found the Plan to confonn to the NUREG.
4.2.1. NOUE 1.
Not (completely) covered by the Seabrook Eats.
l Status: ' Closed.. Seabrook EAL 14a covers all aspects of this requirement except for the case of inadvertent' safety injection initiation without degraded plant conditions. Attachment I to PSNH letter SBN-985 of 4/2/86 provides justification for omission of this portion of the NUREG guidance from the EAL scheme.- This reviewer concurs with Seabrook's reasoning.
3b. Classified as an Alert (not NOUE) at Seabrook but only if based on letdown monitor readings. The case of equivalent values from an RCS Sample (as distinct from the letdown monitor) is not covered.
Status: Closed. Revised EAL Ba is sufficient.
3c. Not covered by the feabrook EALs.
Status: Closed. Seabrook EAL 8a conservatively addresses this requirement.
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4.
Not covered.
L Status:
Closed. Covered by EAL lla, shutdown due to technical specifications (TS) requirement (per TS 3.4.9.1).
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5.
Not covered by the Seabrook EALs.
Status: Closed. Covered by EAL lla, shutdown due to technical specification requirement (per TS 3.4.6.2).
6.
Not covered by the Seabrook EALs.
Status: Closed. Covered by EAL lla, shutdown due to technical specificationrequirement(perTS3.4.6.2).
9.
Not covered by the Seabrook EALs.
Status: Closed. With one exception, all aspects of the NUREG-0654 initiating condition 9 guidance are met in Seabrook's EAL lla, the EAL that directs a NOUE in the event of a technical specification requirement to shut down (in this case, TSs 3.5.3, 3.5.4, 3.6.2.1, 3.6.3,and3.6.2.2).
The exception is the " Loss of... fire protection system function requiring shutdown in accordance by technical specifications...".
NUREG-0654 guidance assumes that licensee technical specifications 8
require a shutdown upon loss of the fire protection system.
Although they are still in the iterative preparation process, the current draft version of Seabrook's technical specifications do not
. require a shutdown on the loss of the fire protection system.
Therefore, unless the technical specifications are revised to include such an LCO, that portion of the NUREG guidance is not applicable.
Recommend this item be passed to the NRC technical specification review body for consideration as a possible LCO.
- 11. Not covered.
Status: Closed by Seabrook EALs 9a-9d and 10a. It is noted that in the case of meteorological data, a NOUE results only if both local (control room) and remote indications are lost. This is considered reasonable.
4.2.2 ALERT' lb.
Incomplete. Provided that the Seabrook item 8a value of gross activity of 600 uCi/cc at the letdown monitor is the engineering equivalent of the NUREG requirement to detect 300 pci/cc of equivalent I-131, part of the requirement is met. However, the Seabrook EAL is based solely on letdown monitor reading and neglects the possibility of a 300 uCi/cc input from an RCS sample, as is provided for in the more general definition of the NUREG.
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l Status: Closed by revised EAL 8b.
Ic. -Not covered.
Status: Closed by revised EAL Bb.
10.
Incomplete. Although the Seabrook EALs address some facets of this item (e.g., 6c, 16c, etc.), it does not appear that " COMPLETE loss of any function needed for plant cold shutdown" has been covered..
Those functions must first be defined.
Status: Open. The current EAL is in error and may be incomplete.
PSNH letter SBN-985 of April 2, 1986 indicates that this initiating condition is covered by Seabrook EALs 17a (Control Room Evacuation) and 18b (Shift Superintendent's Discretion).
Under the latter EAL, the EPIP cites the example " loss of heat source." The citation should read " heat sink" not " heat source."
The functions required for plant cold shutdown are not defined.
Recommend adding this listing to 18b, discretionary events, by expanding the examples cited.
15.
Incomplete. Typically, there are many technical specification radiological limits with one set called " instantaneous." Assuming that is the case, since no particular technical specifications are 10
referenced in Seabrook EAL 12b, omission of " instantaneous" is critical.
Status: Closed.
Revised EAL 12b is applicable.
The site boundary dose rate quoted is ten times the instantaneous technical specification gaseous effluent limit.
4.2.3 SAE 13a Not covered.
Status: Closed by revised EAL 12c.
l Comment: This EAL may be too restrictive.
The Seabrook EAL declares SAE earlier than is required by the guidance since it uses actual meteorology and instantaneous rates. Although this is conservative with respect to protection of the public, it may result in unwarranted escalation to SAE.
(Consider the case of a single unverified erroneous site boundary monitor reading of 55 mr/hr W.B.
taken during some routine monitoring effort. The Seabrook EAL would require innediate declaration of an SAE; the NUREG-0654 guidance
(>50 mr/hr for i hr would provide tine for verification prior to declaration).
4.2.4 GENERALEMERGENCY(GE)
None.
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