Information Notice 2013-01, Emergency Action Level Thresholds Outside the Range of Radiation Monitors

Emergency Action Level Thresholds Outside the Range of Radiation Monitors

ML12325A326
Person / Time
Issue date:	02/13/2013
From:	Camper L, Laura Dudes, Mary Muessle NRC/FSME, Office of Nuclear Reactor Regulation, Office of New Reactors, Office of Nuclear Security and Incident Response
To:
Banic M, NRR/DPR, 415-2771
References
TAC ME9258 IN-13-001
Download: ML12325A326 (5)

ML12325A326 UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR SECURITY AND INCIDENT RESPONSE

OFFICE OF NUCLEAR REACTOR REGULATION

OFFICE OF NEW REACTORS

OFFICE OF FEDERAL AND STATE MATERIALS AND

ENVIRONMENTAL MANAGEMENT PROGRAMS

WASHINGTON, DC 20555-0001

February 13, 2013

NRC INFORMATION NOTICE 2013-01:

EMERGENCY ACTION LEVEL THRESHOLDS

OUTSIDE THE RANGE OF RADIATION

MONITORS

ADDRESSEES

All holders of an operating license or construction permit for a nuclear power reactor or a

non-power (research or test) reactor under Title 10 of the Code of Federal Regulations

(10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, including those

that have permanently ceased operations and have certified that fuel has been permanently

removed from the reactor vessel.

All holders of and applicants for a power reactor early site permit, combined license, standard

design certification, standard design approval, or manufacturing license under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.

PURPOSE

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to

inform addressees of inspection findings related to licensees failures to properly evaluate the

effect of site equipment changes on the emergency plan. The agency intends this IN to inform

licensees of the importance of having adequate procedures to properly evaluate changes to

site procedures, equipment, and facilities for potential impact on the licensees ability to

maintain an effective emergency plan. Specifically, this IN informs licensees of issues that

arose when radiation monitors were not properly evaluated in conjunction with changes made

to emergency action level (EAL) thresholds for emergency classifications. The NRC

previously alerted licensees to similar issues in IN 2005-19, Effect of Plant Configuration

Changes on the Emergency Plan, dated July 18, 2005.

The NRC expects that recipients will review the information for applicability to their facilities

and consider actions, as appropriate, to avoid similar problems. However, suggestions

contained in this information notice do not constitute NRC requirements; therefore, no specific

action or written response is required.

DESCRIPTION OF CIRCUMSTANCES

At the plants cited below, effluent radiation monitor indications are used as EAL thresholds for

emergency classifications. Any site configuration or procedural changes that have the potential to affect the emergency plan, may benefit from being systematically evaluated by the licensee

for their impact on the effectiveness of the emergency plan.

EAL Thresholds Outside the Range of Radiation Monitors at Kewaunee

Kewaunee Power Station submitted a revision to its EAL scheme to the NRC for approval in

2005. The revision specified ALERT EAL thresholds for multiple instruments that were beyond

the display capabilities of those instruments by a decade or more. Both the waste effluent liquid

monitor and gaseous effluent radiation monitor were incapable of displaying values high enough

to trigger an ALERT declaration. According to the licensee such deficiencies would have

prevented timely and accurate emergency classification and response. The licensee staff that

developed revisions to the EAL scheme did not identify that the monitors could not display the

calculated values. The plant operated for approximately 2 years with inaccurate emergency

classifications or EAL thresholds, a condition that could have led to the failure of the licensee to

declare an ALERT emergency in a timely manner.

The NRC determined that a violation of 10 CFR 50.54(q) occurred because of the licensees

failure to follow and maintain in-effect emergency plans that meet the standards in

10 CFR 50.47(b)in particular, 10 CFR 50.47( b)(4). Additional information appears in

Kewaunee Power Station, NRC Emergency Preparedness Inspection Report 05000305/2008503, dated September 23, 2008, available on the NRCs public Web site in the

Agencywide Documents Access and Management System (ADAMS) under Accession

No. ML082670904.

EAL Thresholds Outside the Range of Radiation Monitors at Prairie Island

Prairie Island Nuclear Generating Plant submitted a revision to its EAL scheme to the NRC for

approval in 2005. The revision specified ALERT EAL thresholds for multiple instruments that

were beyond the display capabilities of those instruments by a decade or more. Both the waste

effluent liquid monitor and spent fuel pool vent radiation monitor were incapable of displaying

values high enough to trigger an ALERT declaration based on the licensees revised EAL

scheme. These deficiencies would have prevented timely and accurate emergency

classification and response. The licensee staff that developed revisions to the EAL scheme did

not identify that the monitors could not display the calculated values.

The NRC determined that a violation of 10 CFR Part 50.54(q) occurred because of the

licensees failure to follow and maintain in-effect emergency plans that meet the standards in

10 CFR 50.47(b), in particular, 10 CFR 50.47( b)(4). Additional information appears in Prairie

Island Nuclear Generating Plant, NRC Inspection Report 05000282/2010503, dated

April 09, 2010, on the NRCs public Web site in ADAMS under Accession No. ML100990307.

EAL Thresholds Outside the Range of Radiation Monitors at Crystal River

A revision to the licensees EAL scheme, in 2010, incorporated threshold values for declaring a

GENERAL EMERGENCY (GE) based on an effluent release that was well outside the range of

the licensees EAL-specified effluent monitors to report. The threshold for declaration of a GE

was above the maximum usable range of the reactor building and auxiliary building effluent

radiation monitors on the range specified. Therefore, the licensee had no way of accurately

measuring these threshold values or declaring a GE in a timely manner. In evaluating the root

cause for this condition, the licensee further identified that the radiation monitor indications were nonlinear above 2/3 full scale on the mid-range instrument, and that this monitor would enter an

automatic purge mode before reaching the EAL threshold. Both of these design features

lowered the usable display range even further.

The NRC determined that a violation of 10 CFR Part 50.54(q) occurred because of the

licensees failure to follow and maintain in-effect emergency plans that meet the standards in

10 CFR 50.47(b), in particular, 10 CFR 50.47(b)(4). Additional information appears in Crystal

River Unit 3NRC Emergency Preparedness Inspection Report 05000302/2011501, dated

September 23, 2011, on the NRCs public Web site in ADAMS under Accession

No. ML112660544.

DISCUSSION

The NRC requires licensees to comply with 10 CFR 50.54(q)(2), which states, in part, that a

licensee authorized to possess and operate a nuclear power reactor shall follow and maintain

the effectiveness of emergency plans that meet the standards in 10 CFR 50.47(b) and the

requirements in Appendix E, Emergency Planning and Preparedness for Production and

Utilization Facilities, to 10 CFR Part 50. Non-power reactor licensees, while not required to

comply with 10 CFR 50.47(b), must also meet the requirements of Appendix E.

Site configuration changes have the potential to adversely impact the licensees ability to

maintain and implement an effective emergency plan as required by 10 CFR 50.47(b) and

Appendix E to 10 CFR Part 50, as appropriate. The licensee may consider evaluating all site

configuration changes for their impact on the ability of the licensee to implement the sites

emergency plan and, if necessary, the need to implement compensatory measures. Changes, such as training, facility modifications, site egress and ingress, etc., can all affect the

emergency plan.

In some of the instances discussed above, the licensees root cause evaluations generally

identified inadequate control of the calculations that established the EAL thresholds, and

deficiencies in the training of personnel responsible for these activities. Personnel were not

knowledgeable about the design and operation of the radiation monitors credited in their EAL

scheme.

CONTACT

S

This information notice requires no specific action or written response. Please direct any

questions about this matter to the technical contact listed below or the appropriate NRC

project manager.

/RA/

/RA/

Mary C. Muessle, Acting Director

Larry W. Camper

Division of Policy and Rulemaking

Division of Waste Management and

Office of Nuclear Reactor Regulation

Environmental Protection

Office of Federal and State Materials and

Environmental Management Programs

/RA/ JLuehman for

Laura A. Dudes

Division of Construction Inspection

and Operational Programs

Office of New Reactors

Technical Contact:

Jonathan Fiske, NSIR/DPR/DDEP/IRIB

301-415-6277 E-mail: JAF4@nrc.gov

Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.

ML12325A326 TAC ME9258

• via e-mail

OFFICE PM:NSIR

Tech Editor*

BC:IRIB:NSIR

DD:EP:NSIR

D:DPR:NSIR BC:RDB:FSME

NAME

JFiske

CHsu

RKahler

MThaggard

RLewis

BWatson

DATE

11/28/12

10/23/12

11/28/12

1/15/2013

1/24/13

1/29/13 OFFICE LA:PGCB:NRR PM:PGCB:NRR BC:PGCB:NRR

DD:DCIP:NRO DD:DWMEP:

FSME

(A)D:DPR:NRR

NAME

CHawes

MBanic

DPelton

LDudes

(JLuehman for)

LCamper

MMuessle

DATE

2/6/13

2/4/13

2/8/13

2/11/13

2/13/13

2/13/13