ML18047A328
| ML18047A328 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/27/1982 |
| From: | Bush S AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML18047A285 | List: |
| References | |
| NUDOCS 8205190066 | |
| Download: ML18047A328 (6) | |
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- 9 PAL I SADES PLANT A CRITIQUE OF THE INTEGRATED PLANT SAFETY ASSESSMENT SYSTEMATIC EVALUATION PROGRAM S. H. Bush Since Palisades is the first plant reviewed under the Systematic Evalua-tion Program, the approach taken and the criteria us.ed to establish the accept-ability of assessment are somewhat tentative, particularly because there has been no opportunity to interface with authors and othi=r reviewers.
Two sug-gested benchmQrks are:
~ Does the report meet the original AEC/NRC Corrrnission Charter. for SEPs.
Are the items identified as problems adequately described, including justification of their resolution.
An examination of documents SECY-76-545 and SECY-77-561 provided some insight into the approach used to handle SEP plants.
The five program objec-tives can be used as criteria for measuring compliance.
The suggested approach for handling deviations can permit an assessment of the resolution~ suggested in the Palisades report. These criteria follow.
The following five objectives of the program were established by the Task Force:
1.* The review program must assess the adequacy of the design and opera-tion of all currently licensed nuclear power plants.
- 2.
The program should establish documentation which shows how each oper-ating plant compares,with current criteria.on significant safety iss *.s, and provide a rationale for acceptable departures from the~e criteria.
1.
- 0205190066 820430 PDR ADOCK 05000255 p
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- 3.
The program should provide for the capability to make integrated and balanced decisions ~ith respect to any required backfitting.
- 4.
The program should be structured for early identification and resolu-tion of significant deficiencies.
_5.
The program should efficiently utilize available resources and mini-mize* requirements for additional resources by NRC or industry.
The planned syst~matjc_evaluation would establish. t~~ a~equacy of all operating power ~eactors wit,h respect to safety and provide clear written documentation bases for this conclusion.
When deviations from c~rrent licensing criteria are identified, the fol-lowing alternatives (or combinations of alternatives) will be considered as a basis for establishing acceptability:
- 1.
The deviation can be justified as not significantly decreasing the level of safety.
- 2.
Use of non-safety systems to perform safety functions.
- 3.
Administrative or procedural changes to enhance system reliability.
- 4.
Augmented surveillance programs.
- 5.
Selected backfitting to enhance system reliability.
Presumably one critical evaluation of Appendix A will be sufficient on the assumption that these items will remain unchanged in the future. While Appen-dix B covering generic issues may change somewhat, one review as to adequacy should be suffi~ient.
Obviously~ Appendix C will change because of plant and site specificity. Appendices E and F will need review on a case-by-case basfs.
t Examination of Appendices A, B, and C unearthed some problems.
The
~ording,-teferences and approach used with the items-in Appendix A reveal the 11rnind set" of the 1976-77 _period.* Personally, I feel that some -of the strong positions taken then have weakened in the past 4-5 years.
An example mjght be valve lockout *. As predicted some of the locked out valves have been found to be in the wrong position so the effects of an accident would be exaggerated *.
. 2
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.9-I_ $USpect a probabilistic approach could lead to dropping others; however, the option appears to exist in the so-called 11lesser safety significance 11 approac.h.
With regard to Appendix B as related to A, I am at a lo~s as to why some of the unresolved safety issues were ignored.
Specifically, issues A-11, A-31,
- A-45 and A-49 were not cited. If these were included, some other items would shift to the generic packet.
While I understand the words regarding folding in* the USI and TMI issues, it is not immediately obvious how this will be
- accomplished.
- -I suspect that the issues-in Appendix A~ if.wri'tten in 1982-82, would* dif-fer substantially from the words generated in 1977; however, those words can be accepted_.
SECTION 1 An item of major concern becomes apparent in the listings on page 1~7 and
- in Appendix F.
While the number of LERs arising from personnel or procedural errors is not large, the safety significance of some of the events is substan-tial, particularly with regard to lpss of containment integrity and improper positioning of safety-related valves.
These events extend over a sufficiently long period that is indicative of ~n indifference on the part of top management to take appropriate action.
In my opinion the document does n~t stress this area sufficiently.
Unless there is positive evidence of an improvem~nt in operator actions, I question approving a full-term operating license.
SECTION 2
- Explanatory only--no comments.
SECTION 3 The positive actions t~en to resolve issues III-6, VII-3, VIII-2, VIII-3B and VI-6 are considered appropriate.
My personal opinion is that some ~f the changes under III-6 may not have contributed much to plant.safety.
3.
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- 9 SECTION 4 In essence, this secti~n represents the action$ and bases. for the actions taken *including a factoring in of the PRA in Appendix B.
II-1-A no comment; no problem.
II-38, 81.C Pending; probable backfit.
I II-1 Positive actions that should provide missing information and enable decision as to acceptability of various items.
~III *A-good example of accepting alternate app~oaches when deviation-occurs.
Instead of backfitting, it is recognized that sources of water can be made ~vailable. Emphasis is on clearly defined proce-dures covering use of alternate water source~ than on upgrading or i
backfitting.
. j
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III-3-C The positions of staff and utility are apparent.
I would have th.ought this to be an economic problem that would become apparent during operation rather than under accident-conditions.
I agree with staff.
III-4-A I applaud the decision not to backfit. It's approp*riate.
- iII-5-A, III-6 I disagree on philosophic grounds with this item.
In ten years of review I have yet to find a case where piping failed from seismic
- loads and no breaks result from an unrealistic application of the design load cycles. Current analytic technique yield a false.. picture of piping response that seemingly is not recognized.
III-7-A No disagreement--okay
- 111-7-B Primarily a bookkeeping.activity to provide analytic answers.
III-7-C *I understand the need to do another examination for delamination.
I do not understand an arbitrary five-year repeat.
We don't require that on embedded'f'iaw-s in vessels.
III-8-A May shift to generic.
V-5
-A realistic approach.
I agree with staff analyses.
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. V-10-B V-11-A VI-2-D, VI-4
-VI-6 VI-10-A Action tak~n resolves issue.
This had potential to overpressurize and fail piping.
The action only resol~es it partially since case of released flapper is not covered.
VI-3 I agree with decision and PRA value.
No action required.
Removal of threaded piping is appropriate. Other decisions acceptable.
f-orced act i o*n taken--no issue.
No action.
VII-1-A*
A good example of use of PRA to require revision or accept status quo...
VII-3 DC power obviously is important.
Basically handled as generic.prob-lem.
Other actions based on a realistic assessment of tradeoffs.
VIII-3-A Important issue.
Must assume loss of diesel generator plus offsite power.
V III-4 IX-3 IX-5 IX-6
-* XV-2 XV-12 Action taken.
Presumably fix will be procedural in nature.
Not clear.
Second item procedural plus modification.
Analytic only--not complete.
In essence a generic backfit item.
I am not surprised regarding the uncertainty in failure rates.
Basically, this will be handled generically.
A ~ealistic approach to the problem.
With regard to equipment and design items, the authors addre?sed to a major degree the SEP task force* objectives as well as applying* the tiered cri-teria to resolve deviations. Generally, the approach is even-handled, riot requiring backfit arbitrarily.
I am less satisfied with the handling of oper-
.ating history.
5.
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Appendix F points.out the high incidence of loss of power.
This.combin*ed with some of the operator errors listed could yielq a definite degradation in safety margins.
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