ML19337B215

Forwards Comments & Recommendations Re Draft NUREG-0696 & Proposed Implementation Schedule.Encl Comments Reflect Serious Reservations Re Implementation Schedule for Emergency Response Facilities After Final Rept Is Issued

ML19337B215
Person / Time
Site:	Comanche Peak
Issue date:	09/24/1980
From:	Schmidt H TEXAS UTILITIES SERVICES, INC.
To:	Ramos S Office of Nuclear Reactor Regulation
References
RTR-NUREG-0696, RTR-NUREG-696 TXX-3198, NUDOCS 8010010556
Download: ML19337B215 (3)

Text

4 Log # TXX-3198 File # 10140 TEXAS UTILITIES SERVICES INC.

2003 HRY AN TOWEH . DALLAM. TEXAS 7520t l

September 24, 1980 Mr. Steve L. Ramos Emergency Preparedness Program Office Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555 SU'3 JECT: COMANCHE PEAK STEAM ELECTRIC STATION COMMENTS ON DRAFT NUREG-0696

Dear He. Ramos:

On August 1,1980, the Nuclear Regulatory Commission issued draft NUREG-0696, " Functional Criteria for Emergency Response Facilities," and a proposed implementation schedule for meeting the criteria. In response to your request for review of these criteria, Texas Utilities Services offers the attached comments and recommendations.

In addition to the attached technical comments, we have serious reservations regarding the proposed schedule for implementing emergency response facilities. We believe that it will require between two and two and one-half years to design, procure, construct and implement efficient data system; after the NRC promulgates final criteria. This schedule would be consistent with your proposed schedule for the Nuclear Data Link.

We appreciated the opportunity to provide comments on this subject. If you have any questions, please contact this office.

Si ncerely, ,

L H. C. Schmidt Manager, Nuclear Services FWM:tls O/

5 ih ADD: 1i

s. Wss I I 8040010 hg A

e COMMENTS ON NUREG-0696

. " Functional Criteria for Emergency Facilities" (Draft Report)

1. In general NUREG-0696 is overly precriptive in defining the various data systems. Existing plant computers should be allowed to perform all of the emergency response facility data functions if the avail-ability and data security criteria are met. An integrated system utilizing existing or upgraded plant process computers would reduce the possibility of operator confusion that could occur when the operator is confronted with a multiplicity of data. More flexible criteria and a reasonable implementation schedule will permit licensees to develop control room /SPDS/TSC data systems that are optimum for each facility.

2. The requirement for seismic qualification of the SPDS is overly restrictive and unnecessary. The intended function of the SPDS is to aid operating personnel in the control room make quick assessments of plant safety status. The SPDS is not necessary to mitigate the consequences of an accident nor perform post-accident monitoring. In the event of failure of the SPDS, adequate, seismically qualified, Class 1E instrumentation is available to control room operators. Furthermore, it will be infeasible to effect seismic qualification for certain components (e.g., minicomputers and CRT displays) within the proposed implementation schedule.

3. Data system design availability (or unavailability) criteria should be better defined and acceptable techniques for ascertaining availability should be suggested. Availability should be defined with respect to the overall function of the SPDS and TSC. Unavail-ability should not mean loss of a single parameter (e.g., due to loss of an input sensor), but rather loss of function of each emergency response facility. l The proposed unavailability criteria of 0.001 is difficult to  !

achieve and unnecessary. As pointed out in NUREG/CR-1451 an availability of 99.3% (five hours per month unavailability) for the proposed NRC Operations Center data system cannot be achieved unless redundant major equipment is employed. According to the March 21, 1980, letter from Mr. R. J. Budnitz to Mr. G. R. Oley, no redundancy is planned for the NRC data system.

As an alternative to design availability criteria, we suggest that operability of the SPDS and TSC data systems be included in a Technical Specification Limiting Condition for Operation (LCO).

4. The proposed duplication of the SPDS in the EOF in unnecessary.

The SPDS will be in the control room and the TSC. Duplication of all plant data in all facilities is not required to accomplish ,

the separate and distinct activities at each emergency response facility.

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5. The prorosed criterion specifying that the EOF have a permanent ventilation system which includes particulate (HEPA) filters and charcoal filters should not be universally applied. Depending on the specific location of the EOF in relation to the plant, it is possible that E0F will satisfy the habitability criteria of GDC19 and Standard Review Plan 6.4 without filtration systems.

6. The September 5,1980, letter of Mr. D. G. Eisenhut (

Subject:

Preliminary Clarification of TMI Action Plan Requirements) requests {

detailed description of the extreme natural phenomena used for ,

design of the TSC and EOF. This is not a clarification, but rather a new criterion not previously delineated in NUREG-0696. This additional and unnecessary requirement should be deleted.

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