ML19305A477
| ML19305A477 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/25/1979 |
| From: | Scholl R Office of Nuclear Reactor Regulation |
| To: | Hanauer S Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19305A478 | List: |
| References | |
| NUDOCS 7907260442 | |
| Download: ML19305A477 (9) | |
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HOTE 70: Dr.
S.
H.
Hanauer. Assistant, 0.rnctor for P 1. er n t !wstems, DSS FROM*
R.
F.
Scholl Jr..
Section A.
ICSD/PS/ DSS ICSTN b \\
'J I A :
R.
h.
Satterfield, Chief ALead'a((1b-C.
F.
Miller, Secticn
SUBJECT:
1.
ENVIRONMENTAL QUALIFICATION 2.
INSTRUMENTATION TO FCLLOW THE COURSE OF Ad ACCIDENT 3
EMERGENCY RESPONSE I have.ocepared the enclosed set of three notes tn resnanse to sour Fridas afternoon note.
Althoush voor note on19 reaues ted.w comment; on items 1 and 2 abo"e-I took the liberts of addins the third c.a le s o rs as a result o l' the very short time that I spent in the Eme r<jenew Cai s te r and mw several years of shipboard e::Perience.
I hope that this material satisfies sour needs.
Very Respectfullu.
- J, ev Rawmand F.
Scholl Jr.,
P.E.
7 907 2 6cM4 2-J
ENVIRONMENTAL GUALIFICATION ABSTRACT: This note addresses two topics on environmental oualification which have arisen out of the Three Mile Island Accident.
INTRODUCTION: Dr. Hanauer asked that the followins two topics be addressed bw members of the staff as a result of their observations of the Three Mile Island Accident:
1.
Environmental Qualification Envelope and 2.
Things which have to be cualified.
DISCUSSION:
1.
ENVELOPE:
The discussion of a Qualification Envelope must be conducted in terms of specific Plant areas (e.s.
inside of containment) and must be Plant specific.
The reasons for such Preconditions on a realistic discussion are that the envelope inside of containment is much more severe and that no two containments are eaual.
Because the events at Three Mile Island have involved failures inside of containment, the discussion which follows is limited to the accident envelope inside of containment. For reasons which will become apparent in this discussion, onlw the Three Mile Island containment design is addressed in this note.
Several daws ago, while discussing the oualification of the Barton transmitters for the newer Westinshouse plants, Mr. Miller made the point that the cualification envelope for eouipment inside of centainment should be a composite of the LOCA and MSLB events. His Justification for this Position was that the committee members who wrote the standard recogniced the fact that smaller breaks or other events could, for manw reasons, create worse conditions.
To mens individuals on the staff, this position maw seen to be too conservative. As an alternative to a Protracted and wastefull argument on this subject, I Propose that we test our abilitw to predict containment conditions. The specifics of the test I wish to Propose are Presented in the recommendations below.
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2.
THINGS:
The Three Mile Island Accident demonstrated that non-Class 15 eautsaent (e.g. Reactor Coolant Pumps and in-core thermocouples) can survive conditions which are outside of the normal operatins conditions. It is mw professional Judsoment that the eauipment survived for as lons as it has because of the marsin which was destaned into the eautement for financial reasons (ie. the need for lons Periods between maintenance).
That this eautement will survive lons enough at Three hile Is1snd or that we will be so locks the ne::t time is wishfull thinkins. We have no wa9 to know what the marsin is or what is needed. Because the staff has been unable to determine what instruments are needed for desisn basis events and because the Three hile Island Accident has shown that other events reauire other instruments and additional eautPment, it is necessary to e::Pand the list of Class lE enuipment. The easiest wa9 to delimit the ranse of oualification is to reautre that all oouipment inside of containment be oualified. This is Probably too e::Pensivel and, therefore, some lesser menue is desireable.
As with the ouestion of aualification envelope, a Prosram for further defining those things which are inside of containment and which must be environmental 19 aualified is presented below.
RECOMMENDATIONS:
1.
EXECUTE A PROGRAM TO EVALUATE THE STAFF'S ABILITY TO PREDICT THE CONDITIONS INSIDE OF THE CONTAINMENT.
The elements of the prosram should be' a.
The LOCA and MSLB conditions sh6uld be determined bw use of the currently approved computer models, b.
The combined aualification curve should be determined from the results of
'a' above.
- c. The actual conditions at Three Mile Island should be compared to the results of
'a' and
'b' above to determine which is the best descriptor and still provide some marsin.
d.
Determine if ans of these envelopes is acceptable and, if not, modifw the LOCA and MSLB models until step
'a' or
'b' describes the actual event with marsin.
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? 2. CREATE A LIST OF EQUIPM' INT INSIDE OF CONTAINMENT WHICH MUST BE QUALIFIED, THE LIMITS OF GUALIFICATION, AND THE TIME FOR WHICH IT MUST BE GUALIFIED.
The elements of the program should be
- a. For each Nuclear '3 team Supplw and reactor model prepare a list of those instruments and cauipment which is usually and customairlw aualified as Class lE.
b.
Identifw those iristruments and enuipment which were used or which the crew wished to use during the Three mile Island Accident.
- c. Provide a composite list fr m
'a' and
'b' above.
- d. Evaluate the conposite list for alternative eauipment which is alreadw cualifted or which maw be more easilw tavalified.
- e. Evaluate the reeised list resultins from step
'd' above to determine which elements do not need to be seismicallw aualified.
f.
Modifw the Stardard Review Plan and prepare a Regulatorv Guice to reflect the result of this effort.
- s. As an alternative to steps
'a' throush
- f*
- above, we maw find it more expedient to adopt Mr. Miller's position that everwthins inside of containment should be aualified for the LOCA/MSLB composite unless the app 3.icant can provide a definitive Justification #or exempting individual items or auslifwins to other conditions.
- 3. RE-EVALUATE THE SOURCE TERMS FOR THE RADIATION ENVIRONMENT.
The major a'.ements of this effort should be:
- a. Evaluation of the presentlw approved estimates against the Three Mile Island Unit 2 evente
- b. Evaluation of the proposed Sandia model (which takes l
daughter products into account) against the same evente and
- c. Modification of the best of
'a' or
'b' above to raflect the' actual conditions.
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TNSTRUMENTATION TO FOLLOW THE COURSE OF AN ACCIDENT ABSTRACT: This note addresses two topics on instrumentation to follow the course of an accident which have arisen out of the Three Mile Island Accident.
INTRODUCTION: Dr. Hanauer asked that the followins two topics be addressed bw members of the staff as a result of their observations of +he Three hile Island Accident:
1.
Implementation of Regulators Guide 1.97 and 2.
Backfitting.
DISCUSSION
- 1.
REGULATORY GUIDE 1.97:
Regulators Guide 1.97 has not enJowed anw Popularits with either the staff or applicants. It is mw Personal belief that the document has not been well received because it has two maJoe faults. These faults are:
a.
The ranges which are specified for some instruments are too large. Not onlw do the ranses exceed the Phwsical capabilities of the sustems thew are monitorins but thew also result in a loss of the Precesion which is necessars to make sound operations-Judgements.
b.
The second fault is that the document does not Provide anw definitive suidance and appears to r
have been prepared bw a dr auP ' of people who did not know exactlw what thew really needed to protect public health and safet9. The formation of the Task Group to evaluate the implementation of this suide appears to have had the effect of preventing anw usefull application of this guide bw Permitting it to die from beneian neglect.
Recommendations as to how to correct this situation and as to how the instruments which must be subject to the guide can be identified are'Provided below.
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- 2. BACXFITTING:
The Commission has recognized the need to control backfittins for some time. The RRRC has done, what I believe is, a sood Job. M9 on1w complaint has been that the RRRC has deemed some matters which have been reouired on Past CP applications as orward fit onis. This then becomes a case of giving the apeticant a chance to ratchet-the staff durins the OL review.
I have a recommendation which should prevent this twee of a Problem in the future.
RECOMMENDATIONS:
1.
REVISE REGULATORY GUIDE 1.97 TO PROVIDE TRUE GUIDANCE.
Major elements of this revision should incide a.
Direct and positive reautrements which give guidance 7n the staff's positions, b.
Instrument range reauirements which are compatable with the capabilit9 of the system beins monitored,-
and c.
Instrumentation liets which result from the Program which has been Proposed under the recommendations on environmental cualification.
- 2. REVISE THE CRITERIA FOR APPLICABILITY OF REGULATORY GUIDES.
The Present practice of the RRRC in establishing backfit reautrements should be changed to reflect the current practice of the branch which has responsibilitw for implementing the guide.
- 3. ANY BACKFIT REGUIREMENTS WHICH MAY ARISE OUT OF THE THREE MILE ACCIDENT'SHOULD BE REVIEWED BY THE RRRC.
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1 EhERGENCY CENTER AND ITS OPERATIONS i
I ABSTRACT: This note Presents the observations of the author and some proposals for improvins the operations of the NRC emersenew center. The basis for the sussestions are the author's experience in the US Navw.
INTRODUCTION: To those of us who became involved in suPPortins the Headauarters efforts during the Three hile Island Accident, it is obvious that the operations at the Emersenew Center were less than a paragon of calm and orsani=ation. This note presents a discussion of the author's conclusions as to the reasons for the problems and some sussestions for avoidins similar Problems in the future. The sussestions are based on the author's shipboard experience in the Navw.
DISCUSSION: The events at Three Mile Island struck as a series of events which were compounded bw poor communications and a lack of adeouate information on the design of the plant and the status of its sustems. These additional problems in communications and a lack of adeauate information are the fault of the staff and the staff alone.
First of all there were too mans People at the Emersenew Center. The resultant frantic atmosphere was not condusive to accurate analwsis of anw problems.
Second1w the Emersenew Center was not adeoustelv eauipped to serve the need of ensene' ring personel. Such work is better conducted in the normal
- atmosphere of the work a daw office were suitable references are available as needed.
The Emersenew Center did not have adeauate services for the conduct of engineerins work. Calculators were in short supp1w and no larse scale computer facilities were evident.
The best staff personel to respond to the needs of Three Mile Island were not immediatelw Provided. In the case at hand, it was several daws before a working team of instrumentation and control tspes were in place who knew-somethins about the B&W designs.
Even when a working team was available, there was little detailed information about the plant design on hand to work with.
There does not appear to have been anw provision made for a maJoe or Prolonsed emersencs. Therefore, personel were over extended in terms of workins hours served and were at less than Peak efficienew.
There did not appear to be a single source of clear and concise information about the Pl. g gst
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. RECOMMENDATIONS: The followins recommendations are made in the hope that their implementation will improve our abilitw to react to future Problems of the Three Mile Island ilk.
1.
Do not send engineerins people to the emersenew center.
-ISE should handle the communications with the siter regions, and other external organizations as a seneral rule. When it is necessarv or even desireable for engineering twpes to communicate with a Parts outside of our own headauarters, ISE should make the necessars arrangements.
2.
Permit the engineering teams to work as close to their own offices as is possible. This action will ease access to references and engineering aids. However meeting rooms to law out Plant specific references and to conduct scouP activities such as those conducted in P118 and P422 will also be reauired.
- 3. As Part of the Pre-Planning for the next major happening the followins should be Provided for each operating facilitu:
a.
Packases of office supplies should be prepared for the use of engineerins perscnel and kept readw for use of the staff. These supplies should include calculators, communications eauipments and computer services.
- 6. Engineerins Personel should be identified bw the following categories and assisned to one of three eight hour shifts:
(1) Engineerins specialtw, (2) Familiarits with:
(a) Specific Plant model (b) Nuclear Steam Supplier (c) Archetect/Ensineer (3) Prior experience on the specific Plant 4.
The use of such heroic measures as cots should be avoided unless the weather conditions preclude easw travel.
The concept of being so critical as to be needed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a das is not compatable with such things as cots and sleepins.
- 5. The Present methods for documentins Plant designs must be expanded to include standard formats and contents for drawinss. ASBUILT drawings should be available for each operating facilitw. In addition to a complete set of
=
drawingst some form of visual Presentation such as steriodraphic slides to assist in visuali:ing the plant desisn should be Provided.
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- 6. A series of status boards should be designed for-emersenew operations which involve each tvPe of Plant and included in the emergency Package of recomendation 3.a above.
- 7. A definite set of operatins Procedures should be Prepared which should include'a definitive set of Job assisnments and clearlw establish a chain of command. It is imParitive that the Past' Practice of formins Press sangs and serrumanderins of Personel should not be repeated.
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