ML20244D730

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Forwards Request for Addl Info/Clarification Developed as Result of Review of Emergency Action Levels Contained in Section 5.0, Emergency Classification Sys, (FSAR Amend 56) of Facility Radiological Emergency Plan
ML20244D730
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 03/10/1986
From: Matthews D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: Noonan V
Office of Nuclear Reactor Regulation
Shared Package
ML20234B686 List:
References
FOIA-87-346 NUDOCS 8603140413
Download: ML20244D730 (6)
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March 10.1986 I l MEMORANDUM FOR: Vincent S. Noonan, Director Project Directorate No. 5  !

Division cf PWR Licensing-A Office of Nuclear Reactor Regulation FROM: David B. Matthews, Chief i Emergency Preparedness Branch i Division of Emergency Preparedness (

and Engineering Response Office of Inspection and Enforcement

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION ON SEABROOK .

STATION EMERGENCY ACTION LEVELS .

Enclosed is a request for additional information/ clarification developed as -l a result of our review of the emergency action levels (EALs) contained in Section 5.0 (FSAR Amendment 56) " Emergency Classification System" of the Seabrook Station Radiological Emergency Plan.

s An emergency classification. and action level scheme compatible with NUREG-0654 has been established by the applicant. However, revision to specific EALs in Section 5.0 is required before we can conclude that the EAL scheme conforms to the guidance criteria of NUREG-0654. A preliminary discussion was held with the applicant in an impromptu meeting on February 27, 1986 in conjunction with the emergency plan exercise and appraisal effort. Our comments are included in the attached draft letter.

Please transmit the enclosed request to the applicant and provide this Branch I with a copy of the final transmittal.  !

I Original Signed By:  !

David B. Matthews i David B. Matthews, Chief Emergency Preparedness Branch ,

Division of Emergency Preparedness l and Engineering Response  :

Office of Inspection and Enforcement I i

Enclosure:

DISTRIBUTION w/o enclosure- 1 Request for Additional Information RHVollmer, IE DBMatthews IE j on Seabrook EALs JGPartlow, IE KEPerkins, IE j BKGrimes, IE JAAxelrad IE i CONTACT: Donald J. Perrotti, IE ELJordan, IE CRVan Niel, IE  !

492-4865 SASchwartz, IE DCS {

DEPER R/F EPB R/F i DISTRIBUTION w/ enclosure:  !

FKantor, IE DJPerrotti, IE j RRBellamy, RI VNerses, NRR ,

STurk, ELD I i APB/IE EP .k E DJPerrotti:sc F tor DBMatthews j 3/4/86 3/ /86 3/{0/86 g(,fh l @S b- dj y l

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DRAFT Gentlemen:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - EMERGENCY ACTION LEVELS'

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7"he staff has reviewed the emergency classification scheme contained in Section 5.0 (FSAR Amendment 56) of the Seabrook Station Radiological Emergency 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 Section 5.0 of the Plan before we can conclude that the EALs conform to the I guidelines expressed in Appendix 1 to NUREG-0654. ,

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Please provide your response to the enclosed staff comments within .seven days'. l q

If you desire any discussion or clarification on' the information requ..ted, -i please contact NRC Project Manager, Victor Nerses, 301/49.2-8535.

Sincerely,

Enclosure:

t Comments on EALs i a

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~A. GENERAL FINDINGS:

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1. Figure 5.3, Critical Safety Function '(CSF) for the Heat Sink, is <

1 improperly labeled Number 4. It should be Number H. '

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2. The plan skips' misc. emergency condition Sc, a typo. -

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3. The words "other than fire" should be deleted from chart EAL 17.

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B. PLAN EALS VS NUREG-0654 App.1 GUIDANCE.

Note - In the remainder of this enclosure, paragraph. numbers conform to - j the initiating conditions of Appendix 1 of NUREG-0654. ,

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NOTIFICATION OF UNUStWL EVENT (NOUE) 1, 3c, 4, 5, 6, 9, and 17 are not specifically identified In the-Seabrook i EALs. Confirm that these initiating conditions are covered and that.a NOUE

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would be declared under such conditions.

3b. Classified as an Alert (not NOUE) at Seabrook but only if based upon letdown monitor readings.. The case of equiva' lent values from 'an RCS sample (as distinct from the letdown monitor) -is not covered.

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j 11 & 12. Not covered by the Seabrook EALs.

8. Not covered. It appears that the intent was te, cover this requirement in Seabrook EAL item 20. However,'no classification can result from iteu 20.

13, 14 & 15. Covered generically as Seabrook item 18a. However,*the detailed definitfon stated in the NUREG initiating conditions is missing.

Seabrook simply discusses " hazards", undefined.

ALERT l I

lb. The Seabrook EAL is solely contingent on letdown monitor and neglects j the possibility of a 300 uCi/cc input from an PCS sample, as is provided for in the more general definition of the NUREG. i l

t Ic, 4, 6, 19. Not covered in Seabrook EALs j l

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5. Incomplete. Provided that the numbers work out, it possible that a leak of SG GPM outside containment would invoke Seabrook EAL 12b. However, l the case of the 50 GPM leak inside containment is not addressed. l l

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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.

12. Incomplete. The Seabrook EAL (13) states. " fuel accident with release of radioactivity". Recommend consider adding "to containment or fuel handling building".
15. Incomplete. Typically, there are many tech spec radiological limits oe with one set called " instantaneous". Assuming that is the case, since no particular tech specs are referenced in Seabrook EAL 12b, omission of

" instantaneous" is critical.

16, 17 8 18. Incomplete. Lacking a definition of the word hazard in Seabrook 18b, it does not appear that the specific circumstances of the NUREG (II. D. 1) are covered by this item. See comment under NOUE 13, 14, 15.

SITE AREA EMFRGENCY (SAE) ,

1. This initiating condition correlates to Seabrook EAL item 15. However, there is no SAE in Seabrook 15. The tenninology " emergency coolant recirculation" is ambiguous.

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, a 5, 13a, 13b. Not covered in Seabrook EALs.

8. Clarification is needed. Many of the applicable situations are covered.

To ensure that " Complete loss of any function..." was addressed, definition of functions needed for hot shutdown is required.

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10. Not covered by Seabrook Eats. Without input from radiation levels, the only classification made for a fuel handling accident by the Seabrook plan is an Alert.

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11. . Clarification of Seabrook plan-EAL (16c) is required regarding the SAE related to fire. The NUREG merely requires that the fire compromise i

the function of safety systems. Seabrook's alert level (16b) fire is con-trolled, contained, and potentially affecting; the SAE fire is uncontrolled, uncontained, actually affecting, fhere is no classification for a con-trolled, contained fire affecting safety related equipment consistent with NUREG-0654. The entire set of fire classifications in the plan should be reviewed.

14. Clarification of Seabrook EAL 18c is required with regard to " hazards" t

being defined to include " imminent loss of physical control of the plant".

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