ML19224C182
| ML19224C182 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/27/1979 |
| From: | Scinto J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Vollmer R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7906290301 | |
| Download: ML19224C182 (10) | |
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Scinto SUBJECT.
DETAILED COMMENTS ON PROPOSED SPE S - VERSION OROVf3E3 APML 23
.ib i t e these specs may have seen directed tasard the cresent plant h
status, the transition to a lona tern coolina n,de is so near thc! t ese comments are directed toward acoli._ution of these soccifications to the tono term cooling ode.
1.2
!s 'ther-al power' used 'or any purpose in these soecs?
I' not, elininate it 1.h
'4ith t"e single operatino rode - recovery - use of 1.4 ard Ta b l e 1.I is unnecessarilv complex.
1.5 Probaolv re ains unchanced by present conditions.
Out this is a rathe obtuse statement.
l.6 1 do not believe that this is well worded even for the standard specs.
'Jhv use the language " Imp 1icit in this definition sbaI1 be the assumption by not simply say - all the listed systems sha'i also be operable.
1.7 Should be chocked with Vollmer (and Collins and ICE) to determine whethar NRC may want a broader scope of Repor ab!e Occurrences than usual, 1.3 l'at all possible it would be preferable to speci'y the penetrations that should n.t be opened ar operaale while recovery work is going on.
For those which are better off locked out, but for vehich t he re.'1a y be some use under some notential coaditions, we can always write a inec so that they are to be closed except as approved by the PORC, etc.,
in the procedures set up under Sectinn 6.
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R. Vollmer April 27, 1979 1.9, 1.10,
- Are these reallv use'ul and are they used in these 1,,1 1, 1.21 specs?
' 1.3
- Joes it make any sense to attempt to distinguisS eetween a safety limit and an L.C.O. under these circumstances?
What does either tern really signify under present conditions? See comment c-3.0.1, etc.
2.1.3 Vollrer (or Novak, etc.) should focus on whether tnis is the correct nunber for the specification.
It may be lower r or the conditions that may be involved in natural circulation.
2.1.3
- Basis.
The first portion is cisengeneous under present conditions.
3.0.1, 3.0. 2-These s tatement s as to 'l i.ii t ing condi t ions for and 3.0.3 operation" don't make a lot of sense under conditions when the mode of operation cannot be changed at will.
There should be a more approcriate statement of what an LCO is under present circunstances.
I would suggest something that indicates that an LCO under these conditions represents the anticipated bounds of safe operation under the intended mode.
In the event that they go beyond the spec they should try to get back within the spec as promptly as they can do so safely.
!# they cannot get back within the spec due to the condition of the plant then they should never-theless operate safely and come to NRC promotly or approsial of the new operating procedure.
These concepts should be used in place of 3.0.1, 3.0.2, and 3.0.3, as clearly as we can say them.
This is n,
place for implicit directions.
4.0.2 Good idea to provide some flexibility on surveillance.
Vollmer, etc. should check as to whether this is sufficient or too much.
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Ri;c.ard Vollmer 4. 0. 3, h 0. 4, - Th i s #orm of surveillance requi rement is probably not 4.0.5 a cood idea.
IE would be much better to spe'ri#iy each surveillance called for bv sections 1, 2 ana 3 and speci-fically eliminate those which cannot be dor e safel y under cresent conditions and those which may not be consie. tent with the safety status of the plant.
At the minime, it is essential to make clear that this spec only appliss to those tests etc., that can be carried out safely under cresent olant conditions.
3.i.l.1 Looks like a reasonable form.
Check the action items.
I understand that boron concentration or dilution can be overshot unless one is careful, When once a shift balances, the language of the action item (" i mme d i a t e l y initiate and continue injection o# demineralized water
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may give the impression that it is easy to do.
- Wherear, it should emphasize that this take careful attention to assume that the concentration remains sa#e.
k.1.2.2
- Rather tFan repeat throughout over and over, the ambiguous lancuage about "(ocr occupat ional exnnsure considerations)',
I sugnest that ' Accessible" be de#ined up front to include the idea that when determining whether something is accessible #or sur"eillance purposes, due consideration shall be given to occucational exposures that may be involved in the surveillance procedure.
1.2.2
- !s every 31 days enouch?
3.1 2.4
- Need some part of statement indicating that they should do the best the'/ can giving due recognition to present plant status.
See comment on. 0.I, etc.
4.!2.4
- Vollmer (or Olshinski, etc.) should cons ider whether this is the way this system should be tested under present conditinns.
Is this the right rressure? Is this the right frequency? What precuations are needed?
3.1.2.5
- See comments on 3.1.2.4 and 4.1.2.4 4.1.2.5 3.1.2.7
- See comments on 3.1.2.4 and 4.1.2.4 4.1.2.7 Also applicability to modes 1, 2, 3 and 4 is N
7 incorrect for these specs.
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Richard Vollmer 3.1.7.9
- See comments on 3.I.2.4 and 4.1.2.4 4.1.2.9 Also should be checked with Vollmer, etc. as to whether these specs are the right no-bers.
How about a demineralized water supp!v spec?
3.1.3.1
- How about locking the breakers out or o t he rw i s e removing cossible electrical connections to prevent inadvertent closure?
h.3.1.1 The matter of instrument testing has to be looked at carefully - to minimize any Datential for inad-vertantiv causing an unsafe condition.
Ta b l e 4. 3.1 - Note (6) - Why is this a f00tnote' USv isn't it cart of the spec relatinn to surveillance right up front? Why not be more positive and sneci#y that these tests not be done for instruments in containment?
3.3.2.1 and - See comments on 4.3.1.1, Are those the right sat 4.3.2.1 point? What does " trip' mean uncer the conditions die plant will be in?
For natural circulation should ECCS trip on loss of power?
1.3.3.1 and - See comments on 4.3.1.1.
Also are thes" the right 4.3.3.1 setpoints?
3.3.3.3 and - Vollmer (or someone) should go over this, to see 4.3.3.7 whether this spec is a good idea with the plant in its nresent.tatus.
Is there any potential for a spurious adverse effect on the plant under the condition that it will be in?
Isn't the spec for Unit I sufficient?
3.3.3.4
- See comment on 4.3.1.1.
Is this " action" suf#icient?
3.3.3.5 and - See comment on 4.3.1.1 4.3.3.5 3.3.3.6 and - loes the plant have all this equipment working?
4.3.3.6 See comrent on 4.3.1.1.
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Richard Vollmer 3.3.3.7
- Is there any chlorine in use?
Is there going to be?
If Unit I start could chlorine from Unit I affect Unit 2? Why not just tell them no chlorine?
Why is this spec needed?
See comment on 4.3.1.1.
3.3.3.8 and - see cc,,ent 4.3 l.i.
- h. 3. 3. 3 Are these periods good enough?
3.4.1
- Ok for the plant at present but NC for natural circulation.
For natural circulation cerhaos it should call for having them try to get or keep one or more RCP in operable standby condition if oossible.
Have Vollmer carefully consider this.
4.4.1
- Inadequate for the present.
3.4.3
- Is this what w' want?
See comment on 2.1.3.
4.4.3
- See comment on 4.0.5.
3.4.9.1
- There should be a reference to the orovisions of Section 6 which will previde for Iyw these procedures get established and approved.
4.h.9.1
- Inadequate.
4.6.1.1
- This is a lot better than 1.8 but till see my comment on 1.8 4.6.1.3
- Should locks be tested under present conditions?
Vollmer
ins should carefully consider this.
3.6.4.2
- Why only I op..able recombiner? Whv to go for 7 days without any recombiners operable?
4.6.4.2
- Is this testing sufficient? Should they be tested this way under these conditions?
3.7.2.1
- Make cross reference to section 6.
See connent on
'. 4.9.1 Numerical values it would be prefe able.
Is this the only spec on the secondary side?
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Richard Vollmer 3.7.3.1 and - See comment on 3.1.2.4.
4.7.3.1 3.7.3.2 and - See comment on 3.'.2.4 4.7.3.2 3.7.4.1 and - See comment on 3.1.2.4 4.7.L.?
1.7.7.1 and - This should be reviewed by Vollmer (and Collins etc) 4.7.7.1 1.7.9.1 and - This looks irrelevant in light of the careful HP 4.7.9.1 necessary with cleanup operations.
Should be checked with Vollmer and Collins on wisdom of this spec.
3.7.10 and - Check with Vollmer.
Looks okay.
4.7.10 h.7.11
- 18 nonth surveillance
- 1. 3.1 and
- This should be carefully check wi th Vollmer and the
- h. 3,1 electrical people.
3.9.12 and - Check with Collins and Vollmer.
Are these the right 4.9.12 numbers and procedures?
Is the testing often enough?
3.11.1
- It will be necessary to develop a release spec for this situation, the reactor specs are not really applicable anymore.
Probably it should be a couple of steps.
The lowest limit should be some fraction of Part 20 concentrations - with perhaps some Ci 'imit.
This can be as at present without prior approval but on notice (at least while we still have staf f on site who wants to be notified, tiien pe rhaps a higher fraction of Part 20 in accordance with approved procedures.
Pro-cedur's should provide for Comnittee (like a PORC but w i'.n e f fl uent tvce people) review of cotential exoosures and alternatives.
We csuld coil for i4RC approval or have NRC crior approval at a higher steo.
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Voll er Perhaps we should also impose a nini study (for NRC approval) o# cost and man rem reduction value of various alternative procedures and equipment (a va i l a b l e for use under oresent circumstances).
Have such a study in sav 3 months and thereafter eF#1uents can ce e,ntrolled as cetermined bv tnis study (af ter NRC acor_ al) to be ALARA for present cnnditions.
T Sect:u" ;
- Does it make anv sanse under present conditions?
Ther sho be cpecs on al.a t hapoens ic natural circulat i,n is lost sometine during stable period.
How do they core back? How do they switch to another mode? Nhat othe r, ode should be used? Cr'teria for these cecisions.
Sec::c, 6
- The Admi n i s t ra t i ve Procedures sect i on.
This will be very imoortant during the coming rec,very work.
To assure that the unusual activ' ties that will go on are carefullv evaluated each sten of the way.
The present provision are inadequate.
6.1, 6.2,
- These should be changed to reflect the licensee's Figure 6.2.1 organication during the recoverv period.
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example am not sure that the Unit Super is in chcrged of the
'.laste Management Activity (Rusche's work).
Their actual or gan i za t : on for the recovery work should be reflected in these sections.
There are going to be no ' uni t operations-in the traditional sense.
6.2.2 and
- The staffino should be very carefully reviewed by Tab l e 6. 2.1 Vollmer (and ul,hinski) and Collins.
The reference to when fuel i-in the reactor should be chanced to "at all times".
6.3, 6.4 same as 6.2.
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e Richard H. Vollmer 6.5.1.h
- The PORC should meet as needed and as cornered not oniv by the Chai rman but by the person in overall charge of recovery operations.
6.5.1.6.5
- Can p ro';abl y be deleted.
- 6. 's. l. 6. d
- Should add that they are to review these items "to assure that they do not adversel v a 'fect nuclear or radiological safety" 6.5.1.6.F
- Does ISE want anything more than this?
6.5.1.7.a
- The PORC shou!d review everv item under 6.5.1.6 and its and b purpose should be to assure that the olant can function safelv under present conditions and that any change can be carried out safely. It should also be made clear that the PORC should re-review all existing procedures to assure that they are still adequate and may be carried out safely under present conditions.
The PORC should notify the nerson in cha ge of recoverv operations of a safety disacreement in much less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - more like h hours.
6.5.2
- There should be a senior review committee but are these the richt people?
6.5.2.6
- The Senior Comm ttee should meet as needed or as called by the Chairman or by the person in overall charge of the recovery work.
6.5.2.1
- Paragraoh a and c sh.uld be deleted.
Paragraoh b should be changed to provide #or review of proposed procedures or changes to procedures, equipment or systems to assure that such actions may be carried out safely under present plant conditions.
6.5.2.3.f
- Should be limited to ebnormalities from expected performance under present conditions.
The Senior Committee ought to review any other matter requested by the person in overall charge.
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6.5.2.3.2
- One man review should be deleted for these conditions.
6.5.2.9
- is this desired or needed for the recovery work?
6.5.2.11
- This should call for quick notice to the person in overall charge (and to the NRC) i# they reject ar. act i on approved by PORC, etc.
Around 6.5 - There should be another Committee to do what PORC (and GRC?) does but it should deal with the waste management HP and ef fluent control work.
The POR composition does not look like it has the right background for review o' this work.
6.7
- Does this make sense under present conditions?
6.3.1
- Delete Refueling in (b).
In (f) the written procedures for new conditions should not be limited to those which are known to reduce a safety marcin.
There should be written procedures governing all activities could affect directly or indirectly core cooling, instrument testing, containment integrity, waste management, e f fl uen t control, occupa's ional exposure, operation or tesY ing or maintenance of systems im1ortant to safety as well as the activities covered by f.4.
There should be procedures to assure that they do not reduce margins of safety not just procedures when they know in advance that they may do so.
6.3.3
- Probably should be deleted.
Under these conditions all changes (except those needed to respond to emergencies) should be reviewd by PORC.
6.9.1.1 Probably can be deleted.
In any event should make clear that present status is not covered by (4) during the recovery period (since that plant has already been significantly altered by the accident).
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Richard H. Vollmer 6.9.1.4 and - Is this the report we will want next year?
6.9.1.5 6.9.1.5.6
- Since this spec is covered in the TMi ' l* cense (I believe), it does not need to be repeated here.
6.9.I.6
- Probablv an irrelevant requirement for the recovery phase.
- 6. 9.1. 8
- what is the equivalent of the list for present conditions? We should not simply repeat a list of what would indicate potential problems in an operating reactor.
A number or those have already happened here.
Under present conditions what events would indicate the same degree of ootential problems for a plant in the condition of TMI-2?
6.9.1.9
- Same comment as 6.9.1.8.
6.11 Por decontamination work and waste handling work, there probably should be a clearer requirement to follow approved HP procedures.
6.12
- Should this exemption be continued?
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}dd Joseph Scinto Office of Executive Legal Director mm
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