NRC-90-0017, Forwards Rev 3 to Radiological Emergency Response Plan, Incorporating Changes to Initiating Conditions for Notification of Unusual Event Emergency Classification

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Forwards Rev 3 to Radiological Emergency Response Plan, Incorporating Changes to Initiating Conditions for Notification of Unusual Event Emergency Classification
ML20006E206
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 02/09/1990
From: Sylvia B
DETROIT EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20006E207 List:
References
CON-NRC-90-0017, CON-NRC-90-17 NUDOCS 9002220295
Download: ML20006E206 (20)


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O. Ralph syiv'a tens v vice Pecodent

, 64:0 Nonh Dmie Higtmay g n Nemport Michigan 4106 f i

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, February 9, 1990 i NRO-90-0017 L

'L U. S. Nuclear Regulatory Commission Attnt Document Control Desk Washington, D. C. 20555 ]

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! Roference: Fermi 2

  • NRC Docket No. 50-341 li NR0 License No. NPF-43 i Subject Fermi 2 RadioloDical Emergency Response Plan Revision  !

t Attached for your review and approval is a proposed revision to the Emergency Action Level (EAL) scheme in the Formi 2 Radiological  ;

Emergency Responso Preparedness (RERP) Plan. It incorporates changes to the initiating conditions for the Notification of Onusual Event  !

emergency classification.

1 NUREQ 0654, Appendix 1, provides a definition f or each emergency classification and example initiating conditions. Under 10 CFR 50.72 .

j the NRC requires immediate notification of an emergency declaration and .

one-hour or four-hour reports for non-emergency events. Many of the non-emergency events requiring a one-hour or four-hour report duplicate

. examples of Unusual Event initiating conditions contained in the NUREO Appendix.

1 Several current initiating conditions for Notification of Unusual Event do not accurately reflect the definition because they do not indicats a potential degradation of plant safety or are not precursors to more

  • serious events. We applied these criteria in our revision.

We reviewed nach initiating condition that currently leads to an Unusual

. Event doctaration. Of the twenty-four initiators which now exist in the Fermi RERP plan, we propose to make no changes to seventeen and to eliminate seven. The seven initiating conditions that we are proposing  !

to eliminate from the Plan would continue to be reported under 10CFR50.72. The basis for these changes is provided in Enclosure A. l The proposed revision to Section D of our RERP Plan is Enclosure B.

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j_ USNRC February 9, 1990 NRC-90-0017 page 2 This proposed change as submitted f or your approvat per 10 CFR 60 Appendix E section IV.B. The revision was discussed with State of Michtgen. Monroe County, and Woyne County emergency management representatives and they support the proposed changes. We will not implement this revision until we receive your concurrence.

Sincerely, h' 1ll'k Enclosures cet A. B. Davis R. Lt. DeFayette W. Q. Rogers W. G. Snen J. F. Stang t

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ENCLOSURE A ,

Summary of Unusual Event initiating Conditions ,

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, i Enclosure A Page 1 Current Fermi 2 Unusual Event Emergency Action Levels (EALs)

Gaseous effluent release greater than instantaneous limits allowed by Technical Specification 3 11.2.1.

Liquid effluent release greater than instantaneous limits allowed by Technical Specification 3 11.1.1.

NUREG 0654, Appendix 1 Radiological effluent Technical Specification limits exceeded.

t 10 CFR 50.72 (b)(2)(iv)(A) or (B) Four-hour report Any airborne radiosctive release that exceeds 2 times the applicablo l concentrations of the limits specified in Appendix B, Table II of Part 20

'- of this chapter in unrestricted areas, when averaged over a time period of one hour or any liquid effluent release that excceds 2 times the limiting combined Maximum Pormissible Concentration (MPC) at the point of entry into i the receiving water (i.e., unrestricted area) for all radionuclides except tritium and dissolved noble gases, when averaged over a time period of one L hour.

Discussion Exceeding radiological effluent Technical Specifications limits could be a precursor to higher classifications and has the potential to impact the public.

Conclusion Maintain the current Fermi 2 Unusual Event EALs.

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, l Enclosure A Page 2 j Current Fermi 2 Unusual Event EAL Any unplanned event that results in ECCS discharge into the reactor coolant system as a result of a valid signal.

NUREG 0654. Appendix 1 Energency Core Cooling Systen (ECCS) initiated and discharge to vessel.

10 CFR 50.72 (b)(1)(iv) one-hour report ,

J Any condition that results or should have resulted in Emergency Core Cooling System (ECCS) discharge into the reactor coolant system as a result of a valid signal.

l Discussion ECCS initiation and discharge into the reactor coolant system as a result I

of a valid signal could indicate a degradation in plant safety. However, this condition would be classified as an Unusual Event, Alert, or Site Area Emergency in accordance with loss of reactor coolant fission product barrier EALs. >

Conclusion Delete the current Fermi 2 Unusual Event EAL.

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Enclosure A Page 3 Current Fermi 2 Unusual Event EAL Failure of Safety Relief Valve (SRV) to reset.

NUREG 0654 Appendir 1 Failure of a safety or relief valve in a safety related system to close fullowing reduction of applicable pressure.

10 CFR 50.72 (b)(1)(1)( A) One-hour report The initiation of any plant shutdown required by the plant's Technical Specifications.

Discussion This condition is addressed by Technical Specifications Section 3 4.2.1 which requires the operator to complete specific actions to restore the SRV to operable status or to shutdown the reactor. If, as a result of this condition the operators were unable to maintain reactor water level above the safety limit, an Unusual Event would be declared based on loss of reactor coolant fission product barrier. Inability to comply with Technical Specification shutdown requirements would result in an Alert or Site Area Energency classification based on degraded safety system or reactivity control initiating conditions.

Conclusion Delete the current Fermi 2 Unusual Event EAL.

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--s Enclosure A Page 4 Currant Fermi 2 Unusual Event EALs -

Loss of- any Engineered Safety Features System (s) functions requiring --

shutdown in accordance with Technical Specifications, c Reactivity Control Limiting Conditions for Operation exceeded requiring '

snutdown in accordance with Technical Specifications.

Loss of primary containment penetration conductor overcurrent protectivs devices requiring shutdown in accordance with Technical Specifications.

NUREG 0654, Appendix 1 Loss of engineered safety feature or fire protection system function requiring shutdown by Technical Specifications (e.g., because of -

malfunction, persom.el error or procedure inadequacy).

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10 CFR 50 72 (b)(1)(1)(A) One-hour report The initiation of any plant shutdown required by the plant's Technical -

Specifications.

Discussion These conditions are addressed by various sections of Technical Specifications, each of which require the operator to restore the system to .

operation or shutdown within a specified time frame. These events do not i impose plant transients that could lead to a more serious event. The exception is reactivity control LCO 3 1 3 6, control rod coupling. If a control rod became decoupled, a contrcl rod drop accident could occur and potentially result in fuel clad failure. This event would be classified as an Unusual Event or Alert based on loss of fuel clad fission product barrier. Inah*' tty -to comply with the Technical Specification shutdown requirements a ".1 be classified as an Alert or Site Area Emergency in accordance wicn Jegraded safety system or reactivity control EALs.

Conclusion

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Delete the current Fermi 2 Unusual Event EALs. =

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Enclosure A Page 5

' Current Fermi 2 Unusual Event EAL Safety Limits exceeded requiring shutdown according to Technical Specifications. l NUREG 0654, Appendix 1 Abnormal coolant temperature and/or pressure or abnormal fuel temperatures outside of Technical Specification limits.

10 CFR 50.72 (b)(1)(1)(A) One-hour report The initiation of any nuclear plant shutdown required by the plant's Technical Specifications. .

Discussion Exceeding a safety. limit could degrade the reactor pressure vessel or fuel.

This event could be a precursor to a more serious condition.

-t Conclusion Maintain current Fermi 2 Unusual Event EAL.

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Enclosure A ,

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' Current Fermi 2 Unusual Event EAL Abnormal Reactor done pressure above Technical Specification Operational limits.

NUREO 0654. Appendix 1 Abnormal coolant temperature and/or pressure or abnormal fuel temperatures outside of Technical Specification limits.

10 CFR 50 72 (b)(1)(1)(A) One-hour repor' The initiation of any nuclear plant shutdown required by the plant's Technical Specifications.

Discussion This condition is addressed by Technical Specification 3 4.6.2, which requires the operator to restore reactor domo pressure within limits in 15 minutes or be in Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Inability to reduce reactor pressure to operational limits within 15 minutes indicates a problem that could be a precursor to a more serious condition.

Conclusion Maintain current Fermi 2 Unusual Event EAL.

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Enclosure A '

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-Current Fermi 2 Unusual Event EAL Reactor Cooldown Rate exceeding Technical Specifications.

NUREG 0654. Appendix 1 Other plant conditions exist that warrant increased awareness on the part of a plant operating staff or state and/or local offsite authorities or require plant shutdown under Technical Specification requirements or  !

involve other than normal controlled shutdown (e.g., cooldown rate exceeding technical specification limits, pipe cracking found during operation) .

10 CFR 50.73 (a)(2)(1)(B) Licensee event report Any operation or condition prohibited by the plant's Technical Specifications.-

Discussion Exceeding the cooldown rato could degrade the reactor pressure vessel.

This condition could be a precursor to a more serious condition. ,

Conclusion Maintain current Fermi 2 Unusual Event EAL.

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Enclosure A Page 8 Current Fermi 2 Unusual Event EALs ,

Loss of offsite power or loss of onsite AC power capability.

Loss of power distribution systems requiring shutdotin according to Techr.ical Specifications.

Loss of vital DC electrical power sources requiring shutdown in accordance with Technical Specifications.

NUREG 0654, Appendix 1 Loss of offsite power or loss of onsite AC power capability. ,

10 CFR 50.72 (b)(1)(1)(A) One-hour report The initiation of any nuclear plant shutdown required by the plant's Technical Specifications.

10 CFR 50.72 (b)(2)(ii) Pour-hour report Any event or condition that results in manual or automatic actuation of any Engineered Safety Feature (ESP), including the Reactor Protection System -

(RPS).

Discussion These events impose transients on plant systems that could lead to a more serious event.

Conclusion Maintain current Fermi 2 Unusual Event EALs.

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Enclosure A Page 9 4

Current Fermi 2 Unusual Event EAL Significant loss of communications capability.

NUREG 0654, Appendix 1 Indications or alarms in process or effluent parameters not functional in Control Room to an extent requiring plant shutdown or other significant loss of assessment or communication capability (e.g., plant computer, Safety Parameter Display System, all meteorological instrurentation).

10 CFR 50.72 (b)(1)(v) One-hour report Any event that results in a major loss of emergency assessment capability, offsite response capability, or communications capability.

Discussion This event does not indicate a degradation in plant safety and does not have the potential to degrade to a more severe situation.

Conclusion Delete the current Fermi 2 Unusual Event EAL.

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Enclosure A ,

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Current Fermi 2 Unusual Event EAL Other hazards being experienced or projected (aircraft crash onsite, explosion near or onsite, toxic or flammable gas release, turbine rotating component failure causing rapid plant shutdown, train derailment onsite).

NUREG 0654, Appendix 1 Other hazards being experienced or projected.

a. Aircraft crash onsite or unusual aircraft activity over facility
b. Near or onsite explosion ,
c. Near or onsite toxio or flammable gas release
d. Turbine rotating component failure causing rapid plant shutdown 10 CFR 50.72 (b)(1)(vi) One-hour report Any event that poses an actual threat to the safety of the nuclear power plant or significantly hampers site personnel in the performance of duties necessary_for the safe operation of the nuclear power plant including fires, toxic gas releases, or radioactive releases.

Discussion These events could be a precursor to a more serious event. Assistance from offsite authorities may be required and this declaration would provide them with useful information.

Conclusion Maintain current Fermi 2 Unusual Event EAL.

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Current Fermi 2 Unusual Event EAL Natural phenomenon being experienced or projected beyond normal values.  ;

NUREG 06511, Appendix 1 Natural phenomenon being experienced or projected beyond usual levels

a. Any earthquake felt in-plant or detected on station seismio instrumentation k

b.- 50 year flood or low water, tsunami, hurricane surge, seiche

c. Any tornado onsite
d. Any hurricane 10 CFR 50.72 (b)(1)(iii) One-hour report

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Any natural phenomenon or other external condition that poses an actual

. threat to the safety of the nuclear power plant or significantly hampers site personnel in the performance of duties necessary for the safe operation of the plant.

Discussion-These events could be a precursor to a more serious condition. Assistance from.offsite authorities may be required and this declaration would provide them with useful information.

Conclusion Maintain current Fermi 2 Unusual Event EAL.

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Enclosure A Page 12 Current Fermi 2 Unusual Event EAL

-Uncontrolled plant fire NUREG 0653,' Appendix 1 Fire within the plant lasting more than 10 minutes.

10 CFR 50.72 (b)(1)(vi) One-hour report '

Any event that poses an act'ual threat to the safety of the nuclear power plant or significantly hampers site personnel in the performance of duties  !

- necessary for the safe operation of the nuclear power plant including fires, toxic gas releases, or radioactive releases. ,

4 Discussion This event could be a precursor to a more serious event depending on plant equipment involved. Offsite assistance may be required and this declaration would provide offsite authorities with useful information.

Conclusion Maintain current' Fermi 2 Unusual Event EAL.

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Enclosure A

- Page 13 Current Fermi 2 Unusual Event' EAL Loss of One Fission Product Barrier - Fuel' clad failure.

.NUREG 0654, Appendir 1 Fuel' damage indication 10 CFR 50.72 (b)(1)(ii) One-hour report

Any event or condition during operation that results in the condition of the nuclear power plant, including its principal safety barriers, being seriously degraded. -

~ Discussion This. event indicates a degradation in plant safety and has the potential to degrade to a more severe situation.

Conclusion Maintain current Fermi 2 Unusual Event EAL.

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Enclosure A Page 14 Current Fermi 2 Unusual Event EALs Loss of One Fission Product Barrier

- Reactor water level safety limit exceeded according to Technical Specification 2.1.4.

- Reactor Coolant System leak rates greater than those specified in Tschnical Specification 3 4 3 2.

NUREG 0654, Appendix 1 Exceeding primary system leak rate technical specification 10 CFR 50.72 (b)(1)(ii) One-hour report Any event or condition during operation that results in the condition of the nuclear power plant, including its principal safety barriers, being seriously degraded.

Discussion This event indicates a potential degradation in plant safety and has a potential to degrade to a more severe situation.

Conclusion Maintain current Fermi 2 Unusual Event EALs.

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.: 6 Enclosure A Page 15 Current Fermi 2 Unusual Event EALs Loss of One Fission Product Barrier - Loss of Primary Containment Integrity requiring plant shutdown in accordance with Technical Specifications.

Loss of One Fission Product Barrier - Loss of Secondary Containment Integrity-requiring plant shutdown in accordance with Technical Specifications.

-NUREG 0654, Appendix 1

(' Loss of Containment Integrity requiring shutdown by Technical l l Specifications.  ;

I l- 10 CFR 50.72 (b)(1)(A) One-hour report '

1 i The initiation of any nuclear plant shutdown required by the plant's Technical Specifications, or j 10 CFR 50.72 (b)(1)(ii) One-hour report Any event or condition during operation that results in the condition of l

the nuclear power-plant, including its principal safety barrier, being j seriously degraded. l l

Discussion l Primary Containment is one of the principal fission product barriers and l its backup is Secondary Containment. If coupled with the loss of another fission product barrier these events could result in a radiological release i to the public.  ;

1 Conclusion Maintain the current Fermi 2 Unusual Event EALs.

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s-Enclosure A

'Page 16 Current Fermi 2 Unusual' Event EAL Security _ threat, attempted entry, attempted sabotage.

NUREG 0654. Appendix 1 Security threat _of attempted entry or attempted sabotage.

10 CFR 73 71 One-hour report Explicit threats, which are information received by a security organization that an act of theft or radiological sabotage will be attempted, are to be i reported to the NRC.

-Discussion These events could be a precursor to a more serious security event._ -

Assistance from offsite authorities may be required and this declaration would provide them with useful information.

Conclusion Maintain current Fermi 2 Unusual Event EAL. +

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1 Enclosure A Page 17 Current Fermi 2 Unusual Event EAL Transportation or= contaminated injured individuals from the facility to an offsite medical facility.

NUREG 0654, Appendix 1 4 Transportation of contaminated injured individual' from site to' offsite ,

hospital.

10 CFR 50.72 (b)(2)(v) Pour-hour report Any event requiring the transport of a radioactively contaminated person to an offsite medical facility for treatment.

Discussion This event does not impact plant safety and could not lead to a-degradation ,'

of plant safety.

Conclusion ,

Delete current Fermi 2 Unusual Event EAL.

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