ML20133G234

Requests That Response to Encl RAI Re Classification Scheme of EALs Be Submitted within 45 Days of Ltr Date

ML20133G234
Person / Time
Site:	Catawba
Issue date:	01/14/1997
From:	Tam P NRC (Affiliation Not Assigned)
To:	Mccollum W DUKE POWER CO.
References
TAC-M96519, TAC-M96520, NUDOCS 9701150246
Download: ML20133G234 (16)

Text

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January 14, 1997 i Mr. William R. McCollum Site Vice President Catawba Nuclear Station Duke Power Company 4800 Concord Road l York, South Carolina 29745-9635

SUBJECT:

CATAWBA NUCLEAR STATION - CLASSIFICATION SCHEME OF EMERGENCY .

ACTION LEVELS (TAC M96519 AND M96520)

Dear Mr. McCollum:

y.

By letter dated August 29, 1996, Duke Power Company submitted for Catawba '

Nuclear Station the classification scheme following the guidelines of NUMARC/NESP-007, Revision 2.. The staff _.has completed its initial review and determined that' additional information, as identified in the enclosure, is needed, y - ,

Werequesttha'tiyoI1providethejddit'ional'informationwithin45 days'fromthe '

date of this . letter ~~ If iou ~or your_ staff. need additional time to respond, or clarificationi of the questions, please contact me at 301-415-1451.

Sincerely, 4

' Original signed by:

Peter S. Tam, Senior Project Manager Project. Directorate II-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket No. 50-413 and 50-414-

Enclosure:

Request for Additional Information cc w/ encl: See next page Distribution R.Crlenjak,RII Docket File ACRS T-2 E26 PUBLIC OGC, 0-15 B18 PDII-2 RF J.Zwolinski S.Varga W.Maier, 0-9 HIS k }

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putou 3 lt UNITED STATES g g NUCLEAR REGULATORY COMMISSION

,# WASHINGTON, D.C. 2066Hm01 o,

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'%q * , . . . ,o January 14, 1997 Mr. William R. McCollum Site Vice President Catawba Nuclear Station Duke Power Company 4800 Concord Road York, South Carolina 29745-9635

SUBJECT:

CATAWBA NUCLEAR STATION - CLASSIFICATION SCHEME OF EMERGENCY ACTION LEVELS (TAC M96519 AND M96520)

Dear Mr. McCollum:

By letter dated August 29, 1996, Duke Power Company submitted for Catawba Nuclear Station the classification scheme following the guidelines of NUMARC/NESP-007, Revision 2. The staff has completed its initial review and determined that additional information, as identified in the enclosure, is needed.

We request that you provide the additional information within 45 days from the date of this letter. If you or your staff need additional time to respond, or clarification of the questions, please contact me at 301-415-1451.

Sincerely, W

Pete . am, Senior Project Manager Project Directorate 11-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket No. 50-413 and 50-414

Enclosure:

Request for Additional Information cc w/ encl: See next page

[

Mr. W. R. McCollum Duke Power Company Catawba Nuclear Station cc:

Mr. M. S. Kitlan North Carolina Electric Membership Regulatory Compliance Manager Corporation Duke Power Company P. O. Box 27306 4800 Concord Road Raleigh, North Carolina 27611 York, South Carolina 29745 Senior Resident Inspector Mr. Paul R. Newton 4830 Concord Road Legal Department (PB05E) York, South Carolina 29745 Duke Power Company 422 South Church Street Regional Administrator, Region II Charlotte, North Carolina 28242-0001 U. S. Nuclear Regulatory Commission i 101 Marietta Street, NW. Suite 2900 J. Michael McGarry, III, Esquire Atlanta, Georgia 30323 Winston and Strawn I 1400 L Street, NW i Max Batavia, Chief Washington, DC 20005 Bureau of Radiological Health South Carolina Department of North Carolina Municipal Power Health and Environmental Control Agency Number 1 2600 Bull Street 1427 Meadowwood Boulevard Columbia, South Carolina 29201 P. O. Box 29513 Raleigh, North Carolina 27626-0513 Mr. G. A. Copp Licensing - EC050 Mr. Peter R. Harden, IV Duke Power Company Account Sales Manager 526 South Church Street Westinghouse Electric Corporation Charlotte, North Carolina 28242-0001 Power Systems Field Sales P. O. Box 7288 Saluda River Electric Charlotte, North Carolina 28241 P. O. Box 929 Laurens, South Carolina 29360 County Manager of York County York County Courthouse Ms. Karen E. Long York, South Carolina 29745 Assistant Attorney General North Carolina Department of Justice Richard P. Wilson, Esquire P. O. Box 629 Assistant Attorney General Raleigh, North Carolina 27602 South Carolina Attorney General's Office Elaine Wathen, Lead REP Planner P. O. Box 11549 Division of Emergency Management Columbia, South Carolina 29211 116 West Jones Street Raleigh, North Carolina 27603-1335 Piedmont Municipal Power Agency 121 Village Drive Dayne H. Brown, Director Greer, South Carolina 29651 Division of Radiation Protection N.C. Department of Environment, Mr. T. Richard Puryear Health and Natural Resources Owners Group (NCEMC) P. O. Box 27687 Duke Power Company Raleigh, North Carolina 27611-7687 4800 Concord Road York, South Carolina 29745

REQUEST FOR ADDITIONAL INFORMATION l

REGARDING CATAWBA NUCLEAR STATION UNITS 1 AND 2 EAL REVISION TO NUMARC/NESP-007 METHODOLOGY

Reference:

Catawba Nuclear Station's proposed emergency action levels (EALs),

submitted on August 29, 1996.

i The August 29, 1996 submittal consisted of the revised Section D from the Catawba Emergency Plan which discussed the emergency classification system, a i table containing a cross-reference between NUMARC EALs and corresponding i Catawba EALs, concurrence letters from the offsite emergency management '

agencies within the Catawba emergency planning zone that approved the revised EALs, and procedure RP/0/A/5000/01, which contained the EALs, their technical bases, a list of definitions and acronyms, and guidelines for declaration of l

emergency events.

The proposed EALs were reviewed against the guidance in NUMARC/NESP-007, i Revision 2. This document has been endorsed by the NRC in Regulatory Guide l l 1.101, " Emergency Planning and Preparedness for Nuclear Power Reactors", l

Revision 3, as an alternative means by which licensees can meet the requirements in 10 CFR 50.47 (b) (4) and Appendix E to 10 CFR Part 50.

Since the staff has previously endorsed the guidance in NUMARC/NESP-007, the j review focused on those EALs that deviated from the guidance and those EAls '

that required the development of site-specific thresholds. As a result of ,

reviews of the material submitted, a number of EALS were identified which required additional information in order to determine whether the EALs conform to NUMARC/NESP-007. Please provide this additional information as discussed ,

below.

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NUMARC Recoanition Cateaory A Abnormal Rad Levels /Radioloaical Effluent Issue No. 1 NUMARC EAL AUI.1 states:

AU1.1. A valid reading on one or more of the following monitors i that exceeds the "value shown" (site-specific nonitors) indicates that the release may have exceeded the above criterion and indicates the need to assess the release with (site-specific procedure):

(site-specific list)

Note: If the monitor reading (s) is sustained for longer than 60 minutes and the required assessments cannot be completed within this period, then the declaration must be made based on the valid reading.

Catawba EAL 4.3.U.1-1 is an equivalent EAL to the NUMARC guidance for releases involving liquid effluents. This EAL states:

a. A valid TRIP 2 alarn on radiation monitor ENF-49L or ENF-57 AND l

b. Failure of the release path to automatically isointe AND

c. The liquid radioactive release to the environment exceeds two tines the SLC Ifnit for 60 minutes or longer.

The intent of the NUMARC guidance for this EAL was to make it possible for a classifying official to classify this event based on the instrument reading alone, in the absence of any readily available dose assessment confirmation.

Other EALs under this Initiating Condition (IC) provide for classification using sample results or other means. Including part c. in the Catawba EAL prevents such classification based on instrument reading alone, since part c.

is a restatement of the IC and depends on means other than instrument readings to evaluate whether the EAL is satisfied.

Catawba EALs 4.3.U.1-1 and 4.3.U.1-2 do not contain any provisions for l performing an assessment of the dose impact of the monitor reading.

! Performance of this assessment is important to verify that the actual offsite consequences of the release of radioactive material can be accurately determined.

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These same issues exist for NUMARC EAL AA1.1 (Catawba EALs 4.3.A.1-1 and 4.3.A.1-2.)

Please revise this EAL to be consistent with the NUMARC guidance, or provide  :

additional information that justifies the departure from the guidance. '

Issue No. 2 NUMARC EAL AA2.4 states:

l Water level less than (site-specific) feet for the Spent Fuel Pool and Fuel Transfer Canal that will result in irradiated fuel uncovering. i i

Catawba EAL 4.3.A.2-2 is listed as being equivalent to the above NUMARC EAL l and states:

Plant personnel report that water level drop in reactor refueling cavity, spent fuel pool, or fuel transfer canal has or will exceed makeup capacity such that irradiated fuel will become uncovered.

The Catawba EAL does not list a site-specific level for the spent fuel pool by which operators either locally at the pool or in the control room can conclude that the EAL is being exceeded. Without being able to coropare the observed level to an explicit threshold, the personnel classifying the event must base their conclusions on subjective observations only.

Please provide additional information that justifies the departure from the NUMARC guidance.

Issue No. 3 NUMARC EAL AA3.1 states:

Valid (site-specific) radiation monitor readings GREATER THAN 15 mR/hr in areas requiring continuous occupancy to maintain plant safety functions:

Catawba EAL 4.3.A.3-1, listed as equivalent to this EAL, is similarly worded but does not contain the site-specific monitor designations to be used in the determination.

l Please provide additional information that justifies the departure from the NUMARC guidance.

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Issue No. 4 Catawba EAL 4.3.A.3-2 provides for declaration of an Alert condition based on abnormal radiation levels in the plant. It reads as follows:

i Valid radiation nonitor reading of > 5 R/hr in a plant vital area.

The basis for this EAL does not describe how this value of 5 R/hr was determined.

Provide a description of the methodology by which the above radiation level was selected.

1 Issue No. 5 Catawba EALs 4.3.S.1-1 and 4.3.G.1-1 list gaseous effluent monitor thresholds for releases of radioactive materials that yield site boundary doses that approach EPA protective action guidelines for protection of the general public. Notes contained in these EALs describe the methodology for the selection of the monitor thresholds, but do not list the source term assumptions used in their derivation.

Please provide detailed derivation calculations for the monitor thresholds for both of these EALs, including source term assumptions used for both.

NUMARC Recoanition Cateaory F Fission Product Barrier Reference Table Issue No. 6 EAL FC5 in the NUMARC Fission Barrier Reference Table describes a condition that represents a loss of the fuel clad barrier based on containment radiation monitor readings. This EAL states:

Containment rad monitor reading GREATER THAN (site-specific) R/hr The equivalent Catawba EAL is 4.1.F.3, which states:

Containment radiation monitor 53 A or 53 8 reading >117 R/hr The Fission Product Barrier Matrix located in Enclosure 4.1 of Section D of the Catawba Nuclear Site Emergency Plan lists this EAL, but lists it as a POTENTIAL loss of the fuel clad barrier. The corresponding EAL in Enclosure 4.1 of RP/0/A/5000/01, " Classification of Emergency," properly lists this EAL as a LOSS of the fuel clad barrier. The EAL basis document also properly lists this EAL as a LOSS of the fuel clad barrier.

Provide additional information to clarify which is the proper characterization of this EAL.

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NUMARC Recoanition Cateaory H Hazards and Other Conditions Affectina Plant Safety

Issue No. 7

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Catawba IC 4.6.U.1 reads as follows:

Fire or Explosion Within Protected Area Boundary Not Extinguished Within 15 Minutes of Detection.

s i

The wording of this IC is such that a classifying official, referring to the IC only, would be led to believe that an explosion that did not last 15 minutes would not be a classifiable event. Catawba EAL 4.6.U.1-2 actually

does prescribe the declaration of an Unusual Event for Any unanticipated

, explosion within the protected area, regardless of duration.

Provide additional information that justifies the wording of this IC and that assurer how all unanticipated explosions will be considered for j classif. cation, rega dless of duration.

4

Issue No. 8 Catawba IC 4.7.A.1 states: i Natural and Destructive Phenomena Affecting the Plant Vital Area.

Catawba EAL 4.7.A.1-2 addresses this IC and states:

Tornado striking plant structures within the vital area OR sustained winds 160 mph for >15 minutes.  ;

, This IC and EAL combination do not define the term "the (plant) vital area",

a and they are not consistent with other ICs and EALs, such as 4.6.S.1-1, which j uses the term "A Vital Area" and lists the specific plant areas to which the EAL refers.

Provide additional information that describes how the term " Plant Vital Area" will be interpreted by classifying officials and why this term is inconsistent i with other EALs that are more descriptive.

Issue No. 9 NUMARC EAL HA1.1 reads as follows:

(Site-specific) nethod indicates selsnic event greater than Operating Basis Earthquake (0BE).

~

Catawba EAL 4.7.A.1-1, listed as equivalent to NUMARC EAL HA1.1, lists the acceleration values that constitute an operating basis earthquake, but the

a. ,

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l Catawba EAL does not specify the instrumentation from which the readings are

. to be taken. These instruments Ar_t specified in Catawba EALs 4.7.U.1-1 and 4.7.U.1-2, which are used to classify less severe earthquakes.

Please provide additional information that justifies the departure from the j NUMARC guidance.

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Issue No. 10 NUMARC IC HA2 describes the condition of a fire or explosion affecting the i operability of plant safety systems required to establish or maintain safe

shutdown as an Alert condition. The NUMARC guidance lists this IC as applicable in all modes of operation. Catawba has divided this IC into two

separate ICs, 4.6.A.1 for modes 1-4 and 4.6.A.2 for modes 5 and 6. Neither of these ICs specify the defueled condition as an applicable operating condition.

The need to maintain a safe shutdown condition is applicable in the defueled

, condition also.  !

l l Provide additional information that justifies the departure from the NUMARC  !

j guidance.

l Issue No. 11 l

! NUMARC EAL HA5.1 recognizes the initiation of control room evacuation as an  ;

Alert condition, and states:  !

Entry into (site-specific) procedure for control roon evacution. >

j Catawba EAL 4.7.A.3-1 is listed as equivalent to this EAL and states:

)

l Evacuation of the control roon and control is, or is in the process of l i being, established from the Auxiliary Shutdown Panel (ASP) or the SSF.

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While the NUMARC EAL calls for declaration of the Alert condition upon entry l into the procedure for control room evacuation, the Catawba EAL further

! restricts the declaration of the event until after control at a remote i location has been established or is being established. The wording of the Catawba EAL may cause a classifying official to delay unnecessarily in

. classifying the event until he/she is sure that control of the reactor from j the remote location (s) is assured. The Alert condition may conceivably not be

! declared until after 15 minutes has progressed, thus necessitating the

! declaration of a Site Area Emergency under Catawba EAL 4.7.S.I. In such a

] case the Alert condition of Catawba EAL 4.7.A.3-1 would never be classified or i reported.

i The site-specific procedure to be used in establishing remote control of the

reactor is not specified in the EAL. This comment applies to Catawba EAL 4.7.S.1, which also lacks the site-specific procedure number in the EAL.

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~ _. _ _ _ _. _ ___. -_ _ _ . _ _ -_ . . _ _ _ _ _ _ _ _ . _ _ _ . .

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Please provide additional information that justifies the departure from the NUMARC guidance.

l Issue No. 12 NUMARC EAL SA1.2 states:

l (Site-specific) indication (s) exist that indicate that reactor 1 protection systen setpoint was exceeded and automatic scran did not y occur, and a successful manual scran occurred.-

Catawba EAL 4.4. A.1-1, listed as equivalent to the NUMARC guidance, states

The following conditions exist:

a. Valid reactor trip signal received or required.

l AND

b. Manual reactor trip from the control room is successful and reactor power is less than 5% and decreasing. i j The Catawba EAL does not include the requirement that the automatic reactor

trip function is not successful. This omission could lead to classification of an Alert in cases where a manual reactor trip pre-empted an automatic trip because it occurred prior to the action of the reactor protection system. An

, Alert condition would not exist in this case, because the reactor protection

system is fully capable of effecting a reactor trip. In cases where an i operator manually trips the reactor as a reactor protection system setpoint is

being approached, the reactor may trip and the protection system setpoint may

, be exceeded after the trip has occurred. In such cases the Catawba EAL would j be met, although no degradation of the reactor protection system exists. In such cases as are described above, a careful review of the sequence of events

at the time of the trip is necessary before this type of event can be

accurately classified. The wording of the Catawba EAL may preclude this i review if the EAL appears to be met.

I This same issue applies to Catawba EAls 4.4.S.1-1 and 4.4.G.1-1, which correspond to NUMARC EALs SS2.1 and SG2.1, respectively.

Provide additional information that justifies the departure from the NUMARC guidance.

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Issue No. 13 NUMARC EAL SA3.1 describes conditions that indicate an inability to maintain the plant in a cold shutdown condition and states:

The following conditions exist:

a. Loss of (site-specific) technical specification required functions  ;

to maintain cold shutdown. i AND

b. Temperature increase that either:

Exceeds technical specification cold shutdown temperature limit OR Results in uncontrolled temperature rise approaching cold shutdown technical specification limit.

Catawba EAL 4.4.A.2-1 corresponds to this EAL and states:

Total loss of Residual Heat Renoval (ND) and/or Nuclear Service Water (RN) and/or Component Cooling (KC)

AND l

Inability to maintain reactor coolant temperature below 200*F. i The Catawba EAL lacks the anticipatory provision of the NUMARC guidance by failing to provide for declaration of the event for an uncontrolled temperature rise apprc4ching the cold shutdown technical specification limit.

Provide additional information that justifies the departure from the NUMARC guidance. ,

Issue No. 14 NUMARC EAL SS3.1 describes an EAL that results in a Site Area Emergency declaration for loss of all vital DC power. It states:

Loss of all vital DC power based on (site-specific) bus voltage indications for greater than 15 minutes.

7 Catawba EAL 4.5.S.2-1 is equivalent to the above guidance and states:

The following conditions exist: ,

s. Unplanned loss of both unit related EVDA and EVD0 busses as indicated by bus voltage less than 110 VDC.

NID

b. Failure to restore power to at least one required DC bus within 15 ninutes from the time of loss.

The basis for the above Catawba EAL states:

Prolonged loss of all DC power will cause core uncovering and loss of containment integrity when there is significant decay heat and sensible heat in the reactor systen.

Considering the statement in the basis above, it is unclear how the Catawba EAL can justify the use of the word " unplanned". As currently worded, this EAL will preclude the declaration of a Site Area Emergency for any planned loss of all vital DC power even without compensatory measures being taken to preclude the challenge to the fission product barriers.

Please provide additional information that justifies the departure from the NUMARC guidance.

Issue No. 15 NUMARC EAL SS4.1 describes symptoms of a complete loss of any site-specific function needed to achieve or maintain Hot Shutdown. The basis for this EAL states:

This EAL addresses complete loss of functions, including ultimate heat sink ... required for hot shutdown with the reactor at pressure and temperature. ... Escalation to General Energency would be via ...

Fission Product Barrier Degradation ICs.

Catawba EALs 4.4.S.2-1, 4.4.S.2-2 and 4.4.S.2-3 are listed as equivalent to this EAL and read as follows:

4.4.S.2-1 Core Cooling CSF-RED 4.4.S.2-2 Heat Sink CSF-RED 4.4.S.2-3 Subcriticality CSF-RED The use of the above Critical Safety Function Status Tree (CSFST) red paths in the Catawba EALs fails to meet the intent of the NUMARC guidance; i.e., to describe complete losses of hot shutdown functions which are orecursors to Fission Product Barrier challenges. By listing the affected Fission Product

i-Barrier red paths, the Catawba EAls are listing conditions that are the consecuences of the loss of such function (s) and, therefore, more appropriately a General Emergency condition as is discussed in the NUMARC basis.

It is unclear how the above CSFSTs address the loss of the ultimate heat sink, I as is explicitly included in the NUMARC basis. l l

Provide additional information that justifies the departure from the NUMARC guidance.

Issue No. 16 NUMARC IC SS6 describes conditions that indicate a failure to monitor a significant transient in progress. The EAL associated with this IC states:

The following conditions exist: l

a. Loss of (site-specific) annunciators associated with safety systens.

MD l

b. Compensatory non-alarming indications are unavailable.

MD

c. Indications needed to monitor (site-specific) safety functions are unavailable.

MD

d. Transient in progress.

4 The basis for this EAL contained in the NUMARC guidance states:

" Planned" actions are excluded from this EAL since the loss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not an anulforating factor.

Catawba EAL 4.2.S.1-1 is listed as equivalent to this EAL and states:

The following conditions exist: '

l a. Unplanned loss of most (>50%) annunciators associated with safety  ;

I systens for greater than 15 minutes.

l MD

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l b. A significant plant transient is in progress.

i MD

c. loss of the OAC.

l MD l

, d. Inability to provide manual nonitoring, independent of the OAC

{ Critical Safety Function Status Tree program, of any one of the

, following Critical Safety Functions:

• subcriticality l

l

• core cooling

• heat sink containment Theinclusionofthe! word" unplanned"inparta.oftheCatawbaEALis contrary to the guidance contained in the NUMARC basis.

I J The inclusion of a 15 minute grace period for recovery of the annunciators is j also inconsistent with events of the severity level described above.

, Please provide additional information that justifies the departure from the j NUMARC guidance.

s Issue No. 17

, NUMARC EAL SGl.1 describes conditions that warrant a General Emergency declaration for a prolonged loss of all onsite and offsite AC power. This EAL states:

1. Prolonged loss of all offsite and onsite AC power as indicat,qi by:

a. Loss of power to (site-specific) transformers.

MD

b. Failure of (site-specific) energency diesel generators to supply power to energency busses.

MD

c. At least one of the following conditions exists:

• Restoration of at least one energency bus within (site-specific) hours is NOT likely OR

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(Site-specific) indication of continuing degradation of core cooling based on Fission Product Barrier nonitoring. j Catawba EAL 4.5.G.1-1 is listed as equivalent to the above NUMARC EAL and states:

Prolonged loss of all offsite and onsite AC power as indicated by:

a. Loss of power on essential buses ETA and ETB for greater than 15 minutes.

AND

b. Standby Shutdown Facility (SSF) fails to maintain hot standby AND

c. At least one of the following conditions exists:

• Restoration of at least one essential bus within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is NOT likely. '

• Indication of continuing degradation of core cooling based on Fission Product' Barrier monitoring.

The basis for the Catawba EAL states:

The SSF is capable of providing the necessary functions to maintain a hot shutdown condition for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. No fission product barrier degradation would be expected if the SSF is functioning as intended.

It is unclear how the classifying official would determine if and when part b.

of the above Catawba EAL is met; i.e., how long the station blackout event would have to progress until the classifying official determined that the standby shutdown facility was not able to maintain hot standby. There are no specific criteria for making this determination in the EAL and there is no time limit by which this determination must be made. Failure to determine this condition quickly could delay both the classification of this event and the implementation of protective actions for the public.

Please provide additional information that justifies the departure from the NUMARC guidance.