W3P82-1928, Informs That Revision 4 to Emergency Plan,Revising Emergency Action Levels in Table 4-1 & Draft Emergency Plan Implementing Procedures Were Submitted in June 1982. Emergency Plan Exercise Postponed Until Later in 1982

Informs That Revision 4 to Emergency Plan,Revising Emergency Action Levels in Table 4-1 & Draft Emergency Plan Implementing Procedures Were Submitted in June 1982. Emergency Plan Exercise Postponed Until Later in 1982

ML20055B874
Person / Time
Site:	Waterford
Issue date:	07/19/1982
From:	Maurin L LOUISIANA POWER & LIGHT CO.
To:	Tedesco R Office of Nuclear Reactor Regulation
References
3-A45, W3P82-1928, NUDOCS 8207230414
Download: ML20055B874 (1)

Text

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I l OUISIANA 142 DELARONDE STREET MiOOLE SOUTH P O W E R & L i G H T! P o box 6008

• NEW ORLEANS. LOUISIANA 70174

• (504) 366 2345 UTIUTIES SYSTEM L. V. MAURIN July 19, 1982 Vice President Nudear Operations W3P82-1928 3-A45 b~Q - S E l Mr. R. L. Tedesco Assistant Director of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

Waterford 3 Emergency Planning

Reference:

Letter from NRC to LP&L dated June 22, 1982

Dear Mr. Tedesco:

We have reviewed the referenced letter and understand that your comments on the Emergency Classification Scheme are based on Revision 3 to the subject plan.

It should be noted that we submitted Revision 4 to the Waterford 3 Emergency Plan in June, 1982 which revised the Emergency Action Levels {

EALs) in Table 4-1. We have also submitted draft Emergency Plan Implementing Procedures in June, 1982. In order to completely review the revised EALs, one should review Table 4-1 (Revision 4) and EP-1-001 (Revision 0).

We would also like to inform you that the emergency plan exercise for NRC and FEMA evaluation that was scheduled for August, 1982 has been postponed until later on this year. A revised emergency planning schedule should be complete within the next several weeks and we will provide you with the information as soon as it is available.

If there are any questions please contact Mr. R. G. Azzarello of my statf.

Yours very truly, L. V. Maurin g)

LVM/RGA/pco l

{

Attachment cc: E. Blake, M. Stevenson, F. J. Miraglia, S. Black, D. Perrotti, L. Constable 8207230414 820719

, PDR ADOCK 05000382 F PDR

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'/ 'o. UNITED STATES

! .' NUCLEAR REGULATORY COMMISSION

{ , k.,,. P ij we.smNcTon. o. c. 2csss gu/5

%, ~'f Docket No. 50-382 JUN 2 21932 .

NL'CL5AM Motes;,9 Mr. L. V. Maurin Vice President - Nuclear Operations

• JUN 28 1992 Louisiana Power & Light Company 142 Delarende Street Se.. Orleans, Louisiana 70174 p g" "e ,, q' 784

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Dear Mr. Maurin:

, A

Subject:

Review of the Edergency Classification Scheme The staff has completed its review of the Energency Classification scheme contained in Section 4 of the Waterford 3 Radiological Emergency Plan, Revision 3. As a result of our review we find that additional information/ clarification is required on the Emergency Action Levels i

(EALs) listed in Table 4-1 of Section 4 of the Plan before we can conclude that the EALs conform to the guidelines expressed in Appendix 1 to NUREG-0654.

Please provide your response to the enclosed staff coments within sixty days. If you desire any discussion or clarification on the information requested, please contact the Project Manager Suzanne Black on (301) 492-7702 or Mr. D. J. Perrotti, EPLB on (301) 492-4871.

Sincerely, D 1 Frank J. . rag ia hief Licensing Branch No. 3 Division of Licensing

Enclosure:

Coments on EAL's cc w/ enclosure:

See next page a

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WATERFORD b .

Mr. L. V. Maurin Vice President - Nuclear Operations Louisiana Power & Light Company 142 Delaronde Street New Orleans, Louisiana 70174 cc: W. Malcolm Stevenson, Esq. -

Monroe & Lemann l *25 Whitney Suilding Neo r' ear.s, Louisiana 70130 Mr. E. Elake ,

Shaw, !itiman, Potts and; Trowbridge '

180;

• Street, N'.'

Washin;t:n, DC 20035 Gary L. Groesch 2257 Sayron Road New Orleans, Louisiana 70119 ,

Mr. F. J. Drummond Project Manager - Nuclear Louisiana Power & Light Company 142 Delaronde Street New Orleans, Louisiana 70174 Mr. D. B. Lester Production Engineer l; Louisiana Power & Light Company -

l 142 Delaronde Street New Orleans, Louisiana 70174 Luke Fontana, Esq.

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824 Esplanade Avenue l New Orleans, Louisiana 70116 Stephen M. Irving, Esq.

535 North 6th Street l Baton Rouge, Louisiana 70802 Resident Inspector /Waterford HPS P. O. Box 322 Killona,. Louisiana 70066 Dr. D. C. Gib:s /

Middle South Service, Inc.

I F. O. Box 61000 lj New Orleans, Louisiana 70161 11

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REVIEW 0F WATERFORD HUCLEAR STAT 80N EALS

GENERAL COMMENT

S The licensee has taken the position that except for those that have been so noted the initiating conditions do not apply unlnss the plant is in Mod 1, (operating at high power). This is unacceptable. Many of the norannotated ir.itiating conditions are serious events even at low power, hot standby or even cold shutdown. The licensee should drop this approach. If there are a few instance; where the emergency criteria can be looser.ed because of plant status, they should be individually j

addressed and justified.

The Initiating Conditicos relating to security (Unusual Event-12, Alert-16, Site Area-14,. General-3) do not follow the recommendations in g l NUREG-CB18. The licensee's EAL for an Unusual Event requires reaching security condition level " Yellow". The EAL for an Alert in addition to condition Yellcw requires assistance from the local Law Enforcement Agency. A Site Area Emergency is declared if condition " Red" is reached and a General Emergency is declared if a physical attack on the plant has resulted in occupation of the control room, or local shutdown stations by unauthorized persons. The EAls cannot be evaluated because the licensee has failed to provide information on the precise activities that would create a Yellow or Red condition. The possibility that the licensee's approach is nonconservative is indicated by the requirement that the control and shutdown panels must be occupied before declaring a General Emergency. NUREG-0818 calls for a General Emergency if any vital area is occupied.

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. UNUSUAL EVENT l The licensee has presented a number of the initiating conditions without EAls, probably because the event itself is an EAL. These include 9,11 and 15. It is suggested that the phrase " observation of. event" or

" shift supervisor's opinion" be used as EAls for these initiating conditions.

l The licensee has not addressed Initiating Conditions No.1, (ECCS

! initiated),14e (turbine rotating component failure) and 15 *

(catch-all). As regards to No.15, the text in section 4.1.1 does state j that the shift supervisor can declare an Unusual Event if in his judgement the plant status warrants such a declaration. This should

- also be stated as an EAL in Table 4-1. ,

i Initiating Condition No. 2 (radiological effluents). The relevant

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alarms and monitors should be listed. Back up sampling shculd not take more than 15 minutes.

Initiating Condition No. 3 (fuel damage indication). An EAL for rate of fuel failure is needed.

.. . . . . . - . . . - - - . z . . . . . . .. .. . ..

fnitiating Condition No. 4 (abnormal coolant temperature or pressure or abnormal fuel temperatures). An EAL far high fuel temperature should be added.

Initiating Condition No.10 (fire within the plant lasting more than 10 minutes). The licensee's EAL is nonconservative as it requires the fire be in a vital are- and require offsite support.

Initiating Condition No. 135 (high and low water). Tne low water level .

should be specified.

ALEP.T A r.rter of the initiating c:nditions were listed without accompanying EAls; this might have been done be:ause, in many cases, observation of the event suffices. In -these cases acceptable EA'.s are " observation of u event" or " shift supervisor's opinion". The initiating conditions that "

this applies to are 10, 11, 15, ISb, and 20.

Initiating Condition No.1 (savere loss of fuel cladding). .En EAL for rate of fuel failures should be added.

i Initiating Condition No. 4 (steam line break with significant primary to secondary leakage). The licensee failed to give detailed EALs for a steam line break. The suggestions of NUREG-0818 should be considered in develop;ng an acceptable set of EALs.

Initiating Condition No. 6 (1000 times normal radiation). The requirement for a confirming survey should be dropped unless it can be .

done in 15 minutes. The relevant alarms and monitors should be listed.

Initiating Condition No.12 (fuel handling accident). The requirement for visual confirmation should be dropped as this may not be possible during accident conditions.

- Initiating Condition No.13 (fire potentially affecting safety systems). The licensee's version of this initiating condition is L

nonconservative as it requires offsite support before declaration of an Alert.

Initiating Condition No.14 (most or all alarms lost). The licensee's version of this initiating condition may be nonconservative as it also requires the loss of the station computer in addition to the alarms.

l Whether or not a plant can be brought to a safe shutdown with 'only l

information from the plant computer is not known to the reviewer.

Initiating Condition No.17b (high and low water). An EAL for low water is required. >

SITE EMERGENCY Initiating conditions No. 3, 9, I5b,17, and 18 were not addressed.

Initiating Condition No.1 (LOCA). The licensee's EAL' set is acceptable i

except that it is missing a subset (low subcooling margin concurrent i

with decrease in reactor coof ant pr assure) useful in diagnosing TMI-2 type small LOCAs. The suggestions in h"JREG-0318 should be considered in develcping an acceptable EAL set.

Initiating Condition No. 5 (steam line break with prinary to secondary leakage). The licensee did not give EAls for the steam line break.

Secc7dly confirmation of radiation alarn by sample analysis is

re

;uired. The suggestions of NUREG-081E shculd be considered in developing an acceptable set of EALs for the steam line break. The declaration of the emergency should not be delayed more than a few minutes for sample analysis.

Ir.idating Conditica No. 8 (loss of hot shu-dcon capability). . The license did not prepare EALs for this Initiating Condition. The suggestions of NL' REG-0818 should be considered in developing an .,

acce-table EAL set. - -

Initiating Condition No.11 (fire). No EALs were provided probably becaase osservation of the event suffices. In thi: case, either

" observation of the event" or " shift supervisors opinion" would be suitable EALs. -

Initiating Condition No.12 (all alarms lost for over 15 minutes). The licensee's EAL set may be nonconservative because loss of the station computer is also required.

Initiating Condition No.15b (low water) and 15c (high wint's). An EAL is needed for low water. The requirement for observed darage to a vital structure from high winds should be eliminated as it conflicts with the intent of the NUREG-0654 version of the Initiating Condition.

Initiating Condition-Nor16a-(aircrash affecting vital plant structures by impact or fire). The licensee's EAL requires that instrument readings indicate equipment problems. This is nonconservative as instrumentatica may not indicate damage. For example a fire may not have reached vital equipment or some of the damaged equipment may not be ,

called upon to operate (e.g. ECCS). -

Initiating Condition No.16c (toxic or flammable gas). Gas concentrations do not have to be at the toxic or flammable level.

Concentrations need only be enough to make it difficult or dangerous to enter vital areas where lack of entry constitutes a safety problem.

GENERAL EMERGENCY h The licensee did not address Initiatine Conditiens 5 and 7. The i recommendations of NUREG-0818 should be considered in' arriving at I acceptable EAL sets.

!' Initiating Condition No. 2 (loss of 2 out of 3 fission product barriers with potential loss of the third). The licensee's EAL set is

. . ince plete. The suggestions of NUREG-0318 should be considered in ,

q arriving at a more comple:e EAL set. .

Initiating Condition No. 4 (poss-ble release of large amounts of radicactivity). The licensee's EALs are acceptable; however a " shift superviso.s opinion" EAL should be added.

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