ML19317E047

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Discusses Necessary Util Action to Eliminate Reliance on Operator Action in Event of Small Break Loca.Util 780714 ECCS Analysis Must Meet NRC Position or Either New Analysis or Revised Mods Must Be Provided
ML19317E047
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 09/28/1978
From: Reid R
Office of Nuclear Reactor Regulation
To: Parker W
DUKE POWER CO.
References
NUDOCS 7912110825
Download: ML19317E047 (3)


Text

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DISTRIBUTION:

Docket File (3)

NRC PDR (3)

L PDR (3) i:

Dockets.Nos.: 50-269 M ETEMBER 4 $8 ORB #4 Rdg I

.50-270 RRoid

.ano 50-287_

RIngram MFairtile 1

Attorney, OELD OI&E (5)

DEisenhut Nr. William 0.~ Parker, Jr.

TERA, DSB

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Vice President '- Steam Production ch an Duke Power Company

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-P. O. Box 2178 TJCarter-422 South Church Street Gray File

' Charlotte, North Carolina 28242

Dear 14r. Parker:

.t-By letter dated April 21, 1978, you inforced us of an error in your ECCS Small Break LOCA evaluation nodel analyses. We authorized con-tinued operation of the Oconee Huclear Station, Units Hos.1, 2 and 3 based in part on credit to be taken for prompt operator actions. You were issued an Order dated April 26, 1978, to implement procedures.

and' training necessary h. assure'that the required operator actions could be initiated within five minutes and cocpleted within ten addi-tional minutes. In addition, you were directed to submit reanalyses along with proposals. for long-term modifications to eliminate the need for proopt operator actions including those from inside and from outside the control roon.-

Your-proposal for. long-tem modifications relies on operator actions.

i It appears.that " prompt" operator action is still required.

The staff position regarding allowable operator actions for which L

credit may be taken following a Condition III event (sna11 LOCA),

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-is as follows:

1.

Ho credit 'for operator actions required within ten ninutes of the initiating event will be allowed.

-2.. Credit may be taken for operator action from within the control room after at least ten minutes if adequate infomation is avail-i:

able.and disp 1ged,'and if the operator has sufficient time to J

l correctly analyze the ~ situation, recognize any error or malfunction

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.and to take a corrective action. The. allowed ~ operator actior.s are n!,

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liuited to " simple" actions which are characterized by the " pushing of a t utton* or the " flipping of a switch." Balancing of ECCS g\\(y '
flows by adjusting ulve positions is not considered a " simple *

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Credit may be taken for more complex operator actions which may c he assumed to begin at "tr at 1 cast ten minutes. ~ The credit

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. assumed in'the ECCS andysis should consider a reasonable time l'

' delay after initiation of the operator action for the system to

IfowcVer,

. respond to assure that design flows have been achievLd. -

,i-the credit for t.ase complex actions cannot be assumed in less l

than 20 minutes after the accident.

'If the energency core cooling system analysis for your plant, subaitted does not meet the position stated above, you should July 14, 1978, 4

-(1) provide a' new analysis which demonstrates that the modifi-

-l-either:

cation youLhave. proposed will moet the staff position with respect to j

allowable credit for operator action or (2) prepose a new modification If.your July 14 submittal does meet one of the above

. and an analysis.

positions, state the position you meet and the basis for your statement.

In your consideration of the above, you should be citare that we have t

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~ approved use of the simplified F0A11 code as proposed by Babcock &

j Wilcox in their lette-dated August 11, 1970.

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It is requested that you infona us by telephone, confimed by 1&r,

.I within -seven days of receipt of this letter which of the options you This will allow us to determine whether or not to plan to pursue.

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. continue our review of the design of your proposed modification.

l Your response should include your schedule for submittal of the re-i quired analysis and/or modification.

Sincerely,

'NMtMA 4 Robert W. Reid,. Chief Operating Reactors Branch 44 Division of Operating Reactors L

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