ML17244A596

Forwards Category 2 & 3 Regulatory Positions to Be Addressed in Sep.Reg Guide 1.114 Encl

ML17244A596
Person / Time
Site:	Ginna
Issue date:	06/11/1979
From:	Ziemann D Office of Nuclear Reactor Regulation
To:	White L ROCHESTER GAS & ELECTRIC CORP.
References
TASK-***, TASK-RR NUDOCS 7907110651
Download: ML17244A596 (17)

Text

JUN yi 1979 Docket No.60-244 fir. Leon D. Ilhite, Jr.

Vice President Electric and Steam Production Rochester Gas 8 Electric Corporation 89 East Avenue Rochester, New York 14649

Dear fir. <lhite:

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RE:

IHPLENENTATION OF CATEGORY 2 AND 3 REGULATORY GUIDES IN THE SYSTEtlATIC EVALUATION PROGRN1 - R. E.

GINNA ATOil!IC POWER STATION In the Systematic Evaluation Program for your facility we plan to address Regulatory Guides and other staff positions that have been classified as Category 2 or 3 for implementation by our Regulatory Requirements Review Committee.

Category 2 and Category 3 are defined as follows:

1 Category 2:

Further staff consideration of the need for backfitting appears to be required for certain identified items of the regulatory position - these individual issues are such that existing plants need to be evaluated to determine their status with regard to these safety issues to determine the need for backfitting.

Category 3:

Clearly backfit.

Existing plants should be evaluated to determine whether identified items of the regulatory position are resolved in accordance with the guide or by some equivalent alternative.

For your Inforisatlon, a list of the Category 2 and 3 positions that we current'ly plan to address is provided in Enclosure l.

The SEP topics under which these issues will be considered is also shown.

A copy of one Category 3 position, Regulatory Guide 1.114, Revision 1, "Guidance on Being Operator at the Controls of a Nuclear Power Plant", is provided in Enclosure 2.

To complete our evaluation of this specific guide you are requested to rovide.a commitment to meet the:recommendations.of the ouide.

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please contact the assigned questions or comments about Pr'object ftanager for your facility if you have'any these matters.

Sincerely, Original Signe'd. b7:l

])enni,s L. Ziemann H

Dennis L. Ziemann, Chief Operating Reactors Branch d2 Division'of Operating Reactors

Enclosures:

1.

List of Category 2 and 3 Positions 2.

Regulatory Guide 1.114 cc 1I/enclosures:

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Mr. Leon D. White, Jr.

JlN 1-1 1979 cc w/enclosures:

Lex K. Larson, Esquire

LeBoeuf, Lamb, Leiby 5 MacRae 1757 N Street, N.

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Washington, D.

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20036 Mr. Michael Slade 1250 Crown Point Drive

Webster, New York 14580 Rochester Committee for Scientific Information Robert E.

Lee, Ph.D.

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Box 5236 River Campus Station Rochester, New York 14627 Jeffrey Cohen New York State Energy Office Swan Street Building Core 1, Second Floor Empire State Plaza

Albany, New York 12223 Director, Technical Development Programs State of New York Energy Office Agency Building 2 Empire State Plaza

Albany, New York 12223 Rochester Public Library 115 South Avenue Rochester, New York 14604 KM C, Inc.

ATTN:

Richard E. Schaffstall 1747 Pennsylvania

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Suite 1050 Washington, D.

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ENCLOSURE l CATEGORY 2 AND 3 MATTERS TO BE ADDRESSED IN THE SEP CATEGORY 2 MTTERS

, Dot.'ument Number Revision RG 1.27 2.

RG 1.52 RG 1 ~59 RG 1.63 RG 1.91 RG 1.102 Date 1/76 7/76 8/77 7/78 2/78 9/76 Title Ultimate Heat Sink for Nuclear Power Plants Design, Testing, and Maintenance Criteria for Engineered-Sa fety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light Mater Cooled Nuclear Power Plants (Revision 2 has been published but the changes from Revision.l to Revision 2 may, but need not, be considered.

Design Basis Floods for Nuclear Power Plants, Electric Penetration Assemblies in Containment Structures for Light Mater Cooled Nuclear Power Plants Evaluation of Explosions Postulated to Occur on Transportation Routes Near Nuclear Power Plant Sites Flood Protection for Nuclear Power Plants To ic II-3.C YI-8 II-3.B III-12'I-1.

C II-3.B RG 1.108 1

RG 1 ~115 1

RG1 117 1

RG lol24 1

RG 1 ol30 0

8/77 7/77 4/78 1/78 7/77 (Con<<nued)

Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants Protection Against Low-Trajectory Turbine Nissiles Tornado Design Classification Service Limits and Loading Combination: for Class 1

Linear Type. Component Suppor".s Design Limits and Loading Cocbinctions for Class 1 plate-and Shell-Type Component Supports II VIII<<2 III-4.B III-4,A III-9 III-'ll III-9 III-11

f CATEGORY 2 NATTZRS (CONT 'D)

~ Continued Dccusent Number Rcvfsfon Date Title To 1c RG 1 +137 0

ITP ASB Q.5-1 1

STP NTEB 5-7 1/78 4I77 VIII-2 IX-6 Icterical Select)on and Processing 6&delknes for BN Coolant Peessure Boundary Piping V-4 Fuel 0)l Systems for Standby D)esel Generators (Paragraph C.2)

Guidelines for Fire Protect)on for Nuclear Parer Plants

{See Ieplesientat)on Sect)on, Sect)on D)

RG 1.141 0

4/78 Contahnmcnt Isolation Proves)ons for Fluid Systems YI-4

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CATEGORY 3 MTTERc'ocument Xunher Revi s ion RG 1.99 1

Date 4j77 Title Effects of Residual Elements on Predicted Radiation Damage to Reactor Vessel t4terials (Paragraphs C.l and C.2.

Topic V-6 RG 1.101 RG 1 el 14 RG 1.121 O

RG 1.127 1

RSB 5-1 3/77 11/76 8/76 3/78 1/78 Emergency Planning for Nuclear Pmer Plants Guidance on Being Operator at the Controls of a Nuclear Paar Plant Bases for Plugging Degraded PMR Steam Generator Tubes XIII-1 ORB g2 Inspection of Mater-Control Structures III-3.C Associated xith Nuclear Pmer Plants Branch Technical Position:

Design Require.VII-3 aunts of the Residual Heat Removal System Y-II.B RSB 5-2 RG 1 97 RG 1.56 1

'3/78 8/77 7/78 Branch Technical Position:

Reactor Coolant System Overpressurfzation Protection Instrumentation for Light Mater Cooled Nuclear Pmer Plants to Assess Plant Conditions During and FollMng an Accident (Paragraph C.3 - fifth addftfonal guidance on paragraph C.3.d to he provided later)

Nafntenance of Mater Purfty fn Boilfng Mater Reactors V-6 VII-5 Y-12.A

V 1

MATTERS THAT ARE NOT TO BE ADDRESSED l.

Regulatory Guide 1.105 "Instrument Setpoints" - This matter was included in the SEP Topic VII-l.B and was resolved on the basis of the NUREG-0138 discussion of the topic.

However, DOR generic action on specific instrumentation such as LPRM drift in BWRs is continuing (such action was noted in the NUREG) and these generic l.eviews may be expanded if the need to do so is identi fied.

.2.

Regulatory Guide 8.8 "Information Relevant to Ensuring That Occupational Radiation Exposure at Nuclear Power Stations Will Be As Low As is Reasonably Achievable (Nuclear Power Reactors)"-

This matter is presently being proposed for resolution by DOR/EEB on a generic basis.

Since ALARA issues were not included in the initial SEP scope it would be inappropriate to include this one unique issue now.

3.

Regulatory Guide 1.68.2 "Initial Startup Test Program to Demonstrate Remote Shutdown Capability for Mater-Cooled Nuclear Power Plants" -- This matter was determin'ed, by Regulatory Requirements Review Committee, to be applicable to plants in the OL stage of licensing.

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ENCLOSURE 2

U.S. NUCLEAR REGULATORY COMMISSION Rt=GUMTDRVGUNIDE OFFICE OF STANDARDS DEVELOPMENT Revision 1

November 1976 REGULATORY GUIDE 1.114 GUIDANCE ON BEING OPERATOR AT THE CONTROLS OF A NUCLEAR POWER PI.ANT A. INTRODUCTION Paragraph (k) of$50.54, "Conditions of Licenses,"

of 10 CFR Part 50, "Licensing of Production and Utilization Facilities," requires that an operator or

'enior operator licensed pursuant to 10 CFR Part 55, "Operators'icenses,"

be present at the controls at all times during the operation of a facility.'eneral Design Criterion 19, "Control Room," of Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50 requires, in part, that a control room be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain the nuclear power plant "in a safe condition under accident conditions.

As delined in 10 CFR ba50.2(t), thc term "controls,"

when used with respect to nuclear reactors, means ap-paratus and mechanisms, the manipulation of which directly affects the reactivity or power level of the reactor. This guide describes a method acceptable to the NRC staff for complying with the Commission's regulations that require an operator to be present at thc controls, of a nuclear power plant. Thc Advisory Committee on Reactor Safeguards has been con-suited concerning this guide and has concurred in the regulatory'position.

B. DISCUSSION Operating experience has shown that there is a need for guidance with regard to acceptable methods ofcomplying with thc Commission's requirement for the presence of an operator at thc controls of a facility. The operator at the controls of a nuclear power plant has many responsibilities, which include but are not limited to (I) adhering to the plant's technical speciTications, plant operating procedures, o Line indicates substantive change from previous issue.

'urrent Standard Tcchnical SpeciCtcalions require a licensed operator lo be prcsenl in thc control room at all times while fuel ic in lhc reactor.

USNRC REGULATORYGUIDES Repvistor.

Guides ore issued lo describe ond make available lo tho pubhc mclncds oCCtpiabl ~ tO the NRC

~taft of implementing specific pons of thc Commission s repulsuons. to dehnesle techniques used by lhe staff in evslu stinp specific pioblems or poslulsted sccidtnu,or to provide gvidance to appli conte Rtguloloty Guides are nol substitutes for reyulations, ond compliance with them ia not required, Methods snd solutions difierent from those set out in the guides willbe acceptable iflhey provide ~ basis fottht findings requisite lo lhe issuance or continuance of a permit ot license by the Commission Cornrnenl ~ and suggtsuons lor improvement ~ in these guides

~i~ tncovroped

~ 1 sll Amos, snd guides will bo tevised. es appropriett to accomniodo1 ~ corn ments and lo ttliecl now inlormalion or taperitnce This guide was revised sa a

~sault'of subslontrve commtnls teceivod fiom the public snd additional at ~If rtvitw and NRC regulations; (2) reviewing operating data, ihcluding data logging and review, in order to ensure safe operation of the plant; and (3) being able to manually initiate engineered safety features during various transient and accident conditions.

l, Powei Aeactors 2

Aeseorch end Test Aeaclora 3

Fuels snd Msteiials Feei niea environmental and Sitrr 0 5 Met ~ ri~ls snd Plant Protection 6 Ptodvcla T Trsnsponation 6 Occupational Health g Antitrust Review 10 General Copi ~ s ol pvbhshod gwdta mar bt obtained by wtitten request indicating the divisions desired to tht U 5 N clear Regulatory Commission,vhshtnpton.

D C 20555. Attention Director, Ollntol Stan ards Development.

In order for thc operator at the controls of a nuclear power plant to be able to carry out thes~ and other responsibilities in a timely fashion, he must give his attention to the condition ofthe plant at all times.

Hc must be alert in order to ensure that the plant is operating safely and must be capable oftaking action to prevent any progress toward a condition that might be unsafe. This is facilitated by control room design and layout in which all controls, instrumenta-tion displays, and alarms required for.the safe opera-tion, shutdown, and cooldown of the unit arc readily available to the operator in the control room.

C. REGULATORY POSITION

1. The operator at thc controls of a nuclear power plant should have an unobstructed view ofand access to the operational control panels,'ncluding in-strumentation displays and alarms, in order to be able to initiate prompt corrective action, when neces-sary, on receipt of any indication (instrument move-ment or alarm) of a changing condition.

2. The operator at the controls. should not normal-ly leave the area where continuous attention (including visual surveillance ofsafety-related annun-ciators and instrumentation) can be given to reactor operating conditions and vthere he has access to the reactor controls. For example, the operator should not routinely enter areas behind control panels where

'perational conlrol panels are control panels that enable the opcralor at the controls lo perform required manual safely func-lions <<nd equipment surveillance and to monitor plant condi-lions under normal and a:cident condiiions. Operational control panels include inllrumcr,:alion for lhe reactor. reactor coolant system, containment.

and safely.related process syslems.

Comments should be sent to:he Secrttary ol the Commission. U.S Nuclear Regul ~lory Commission, Was"ingtot' C

20555 Attention. Docketing ond Seryice Sechon The guides sre issued in the fol owing ten brood dwiaions

I plant performance cannot be monitored.

The operato'r at the controls should not under any cir-cumstances leave the surveillance area defined by regulatory position 3 for any nonemergendy reason (e.g., to confer with others or for personal reasons) without obtaining a qualified relief operator at the controls. In the event of an emergency affecting the safety of operations, the operator at the controls may momentarily be absent from the defined surveillance area in order to verify the receipt of an annunciator alarm or initiate corrective action, provided he re-mains within the confines of the control room.

3. Adm'inistrative procedures should be es-tablished,to define and outline (preferably with

, sketches)'specific areas within the control room where the operator at the controls should remain.

The procedures should define the surveillance area and the areas that maj be entered, in the event of an emergency affecting the safety of operations.

by the operator at the controls to verify receipt of an annun-ciator alarm or initiate corrective action.

4. Prior to assuming responsibility for being operator at the controls, the relief operator should be properly briefed on the plant status. In order to en-sure that proper relief occurs, administrative procedures should be written to describe what is re-quired. The administrative procedure should include, as a minimum, a definition ofproper relief(e.g., what information is required to be passed on and acknowledged between the two operators).

5. A single operator should not assume the operator-at-the-controls responsibility for two or more nuclear power units at the same time.

D. IMPLEMENTATION The purpose of this section is to provide informa-tion to license applicants and licensees regarding the NRC staffs plans for using this regulatory guide.

This guide reflects current NRC staff practice.

Therefore, except in those cases in which the appli-cant or licensee proposes an acceptable alternative method for complying with specified portions of the Commission's regulations, the method described herein is being and will continue to be used in the evaluation ofsubmittals for operating license or con-struction permit applications and the performance of licensees until this guide is revised as a result of sug-gestions from the public or additional staff review.

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