ML20054K069
| ML20054K069 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/22/1982 |
| From: | Miraglia F Office of Nuclear Reactor Regulation |
| To: | Maurin L LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8207010017 | |
| Download: ML20054K069 (5) | |
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4 11r. L. V. Maurin Filt raglia 4g Vice President - fluclear Operations s
Loutstana Power & Light Compalny t r ey, O
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' r@ ' A 142 Delaronde Street I&E E
flew Orleans, Louisiana 70174 g'
ACRS(10)
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Dear Mr. Maurin:
'tg i y
Subject:
Review of the Energency Classification Scheme Ql 9
The staff has completed its review of the Emergency 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 (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 I4UREG-0654.
Please provide your response to the enclosed staff consnents within sixty days.
If you desire any discussion or clarification on the infonnation requested, please contact the' Project Manager Suzanne Black on (301) 492-7702 or Mr. D. J. Perrotti, EPLB on (301) 492-4871.
Sincerely,
' Original signed by / rara J. :; ;.giaa l
Frank J. litraglia, Chief
~
Licensing Branch No. 3 Division of Licensing I
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Enclosure:
Consnents on EAL's cc w/ enclosure:
See next page 9
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l NRC FORM 3tB110 UCINRCM O240 OFFICIAL RECORD COPY
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WA.TERFORD 4
Mr. L. V. Maurin 4
Vice President - Nuc1 car Operations
_. Louisiana Fower & Light Company 142 Delaronde Street i
New Orleans, touisiana 70174 l
cc:
W. Malcolm 5:evenson, Esq.
l Monroe & Lem:nr.
1423 Whiina,. Luiiting how Cricens, Leai:iana 70130 Mr. E. 01ake i
Shaw, Pittmar,, Fotts and Trowbridge v1 I E OG' P St r e et, '",'
i Washington, DC 2003E Gary L. Groescn 2257 Bayron Road l
New Orleans, Louisiana 70119 Mr. F. J. Drum. mend Pr oject Manacer - Nuclear Louisiana Power & Light Company 142 Delaronde Street New Orleans, Louisiana 70174 i
l Mr. D. E. Lester Production Engineer Louisiana Power & Light Company 142 Delaronde Street New Orleans, Louisiana 70174 l
Luke Fontana, Esq.
824 Esplanade Avenue j
New Orleans, Louisiana 70116 t
4 Stephen M. Irving, Esq.
4 535 North 6th Street Baton Rouge, Louisiana 70802 l
l Resident Inspector /Waterford NPS i
P. O. Box 822 Killena, Louisiana 70066 Dr. I C. Gibts Midcie South Service, Inc.
P. C. Eor 61000 hew Orleans, Louisiana 70161 1
w
REVIEW OF WATERFORD hUCLEAR STATION EATS
GENERAL COMMENT
S The licensee has taken the position that except for those that have been so noted the initiating conditions do not apply uninss the plant is in Med 1, (operating at high power).
This is u, acceptable. Many of the nor1 annotated 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 instanct. where the emergency criteria can be loosened because of plant status, they should be individually addressed and justified.
The Initiating Conditions relating to security (Unusual Event-12, Alert-16, Site Arca-14, General-3) do not f ollow the recorcendations in
- .-j NJREG-0518.
The licensee's EAL for an Unusual Event recuires reaching security condition level "Yellcw".
The EAL for an Alert in addition to cc.cition Yellow 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 ir -cupation of the control room, or local shutdown stations by unauthorized persons.
The EALs cannot be evaluated because the licensee has failed to prcvide 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.
UNUSUAL EVENT 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.
The licensee has not addressed Initiating Conditions No. 1, (ECCS l
initiated), 14e (turbine rotating component failure) and 15 (catch-all).
As regards to No.15, the text in section 4.1.1 does state 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.
Initiating Condition No. 2 (radiological effluents).
The relevant I
alarms and monitors should be listed.
Eack up sampling should no; take more than 15 minutes.
Initiating Condition No 3 (fuel damage indication).
An EAL for rate of l
fuel failure is needed.
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Initiating Condition fio. 4 (abnormal coolant temperature or pressure or abnormal fuel temperatures).
An EAL for high fuel temperature should be added.
Initiating Condition No.10 (fire within the plant lasting nore than 10 minutes).
The licensee's EAL is nonconservative as i+ requires the fire be in a vital ara 2 and require offsite support.
Ir.itiating Ccndition No. 13b (high and low water).
The low water level should be specified.
ALEF.T A number of the initiating c nditicns were listed without accerparying EALs; this mipt have been done because, in many cases, observation of the event suf fices.
In these cases acceptable EAls are " observation of e.ent" or "shif. supervisor's opinion".
The initiating concitions that this applies :: are 10, 11, 15, 18b, and 20.
Initiating Candition No.1 (severe loss of fuel cladding).
An EAL for rate of fuel failures should be added.
Initiating Ccndition 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 acceptabis 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 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.
k'hether or not a plant can be brought to a safe shutdown with only informaticn from the plant computer is not known to the reviewer.
Initiating Ccndition No.17b (high and low water).
An EAL for low water is required.
SITE EP.ERGENCY Initiating conditions No. 3, 9, 16b, 17, and 18 were not addressed.
Initiating Conditica No.1 (LOCA).
The licensee's EAL set is acceptable except that it is nissing a subset (low subcooling margin concurrent
with decrease in reactor coolant pr assure) useful in diagnosing TMI-2 type small LOCAs.
The suggestions in tiJREG-0818 should be considered in developing an acceptable EAL set.
Initiating Condition fio. 5 (steam line break with primary to secondary leakage).
The licensee did not give EALs for the steam line break.
Sectndly confirmation of radiation alarrs by sample analysis is required.
The suggestions of fi'JREG-0812 should 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.
Initiating Cordition No. 5 (loss of hot shutdcwn capability).
The licensee did not prepare EALE for this Initiating Ccadition.
Tne suggestions of NUREG-CE18 shtald be considered in developing an acceptable EAL set.
- .-4 Ir.itiating Condition No.11 (fire). rh EAls were provided probably t e:ause coservation of the s.ent suffices.
In th!: case, either
'cDservation of the e.ent" 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 winds).
An EAL is needed for low water.
The requirement for observed damage to a vital structure from high winds should be eliminated as it conflicts with the intent of the NUREG-065a version of the Initiating Condition.
Initiating Condition No.16a (aircrash affecting vital plant structures by impact or fire).
The licensee's EAL requires that instrument readings indicate equipmerit problems.
This is nonconservative as instrumentation 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 cperate (e.g. ECCS).
Initiating Condition No.16c (toxic or flam.mable 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 rne licensee did not address Initiating Conditions 5 and 7.
The re::mendations of NJkEG-C516 should be considered irc arriving at acceptable EAL sets.
Initiating Condition No. 2 (loss of 2 out of 3 fission product barriers with potential loss of the tnird).-
The licensee's EAL set is in:c plete.
The suggestiers of NUREG-0818 should be considered in arriving at a more complete EAL set.
Initiating Condition No. 4 (poss-ble release of large amounts of ra dio a cti vity).
The licensee's EAls are acceptable; however a " shift supervisors opinion" EAL should te added.