ML19338F962
| ML19338F962 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 10/09/1980 |
| From: | Kane W Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8010280127 | |
| Download: ML19338F962 (19) | |
Text
73xn on erog UNITED STATES
- T y
NUCLEAR REGULATORY COMMISSION
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E WASHINGTON, D. C. 20666
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OCT 9 1980 Docket Nc. 50-395 APPLICANT:
V. C. Summer Nuclear Station, Unit 1 FACILITY:
South Carolina Electric and Gas Company
SUBJECT:
SUMMARY
OF SEPTEMBER 23-24, 1980 MEETING REGARDING EMEP,GENCY OPERATING PROCEDURES 1.
General During the period of September 23-24, 1980 representatives of the NRC starf and its consultant, Pacific Northwest Laboratories, met with representatives of the applicant. The meeting was held at the appli-cant's facility in Jenkinsville, South Carolina.
A list of those persons who participated in the meeting is included as Enclosure 1.
2.
Purpose The purpose of the meeting was to discuss the NRC staff comments, developed prior to the meeting on selected emergency operating proce-dures.
3.
Discussion The comments that were discussed with the applicant are included as.
These coments were based on our review of the applicant's procedures developed from Revision 1 of the guidelines of the Westinghouse i
Owners Group. The applicant will use the discussion on these comments.
Revision 2 of the guidelines of the Westinghouse Owners Group, coments from Westinghouse, and their own internal coments to develop revised procedures are expected in mid-October 1980.
/r N,-
G~
William F. iCane, Project Manager Licensing Branch No. 2 Division of Licensing
Enclosure:
As stated t
cc: See next page j
l 8010280 %
OIN 9 1980 i
Mr. T. C. Nichols, Jr.
Vice President & Group Executive Nuclear Operations South Carolina Electric & Gas Company P. O. Box 764 Columbia, South Carolina 29281 cc: Mr. William A. Williams, Jr.
Vice President South Carolina Public Service Authority i
223 North Live Oak Drive Moncks Corner, South Carolina 29461 J. B. Knotts,ibermanJr., Esq.
Debevoise & L i
1200 17th Street, N. W.
Washington, D. C.
20036 i
Mr. Mark B. Whitaker, Jr.
Group Manager - Nuclear Engineering & Licensing South Carolina Electric & Gas Company P. O. Box 764 Columbia, South Carolina 29218 Mr. Brett Allen Bursey Route 1, Box 93C Little Mountain, South Carolina 29076 Resident Inspector / Summer NPS c/o U. S. NRC Route 1, Box 64 Jenkinsville, South Carolina 29065 w
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ENCLOSURE 1 4
LIST OF ATTENDEES 5
NRC STAFF D. Wigginton 4
B. Siegel J. Skolds PACIFIC NORTHWEST LABORATORIES W. Apley SOUTH CAROLINA ELECTRIC AND GAS COMPANY 4
i H. Babb
- 0. Bradham L. Storz K. Woodward t
SOUTH CAROLINA PUBLIC SERVICE AUTHORITY W. Williams
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ENCLOSURE 2 GENERAL 1.
Each of the E0P's contain glossaries or abbreviations of terms used in the procedure and on the control panel. While it is acceptable to include these terms in the glossary, some are not readily understandable when used in the later sections of the report.
It is not acceptable for the operator to depend upon training or recall for the lesser used abbreviations.
If there is any possibility that any operator might misinterpret an abbreviation, spell it out.
2.
Attachments are listed as Page ___ of __; the procedures should also be listed this way.
3.
The format of E0P's is such that symptoms, immediate actions, and subsequent operator actions are all grouped under the single section 3 " Conditions".
It is almost imperative that the operator go to the index to find subsequent actions.
If licensec procedure calls for this format, consider starting each subsection on a new page and " continue" the title at the top of each page.
4.
Immediate actions are to be committed to memory by the operators.
Careful consideration needs to be given to immediate action verifications as opposed to detailed subsequent actions.
5.
The control panel review may require that normal and emergency values be indicated on flow meters, temp and pressure gauges, etc.
If these indications are on the panel, it is not necessary to include the range of values in the E0P steps.
If not on the panel, the E0P steps calling for verification of flows, temp, pressure, etc., should show the expected ranges.
6.
Attachments to E0Ps should be self-sufficient, i.e., there should be instruction with the attachment on how to use it or what to do with it.
Exceptions to this are things like the subcooling graph where instructicas in its use is not needed.
7.
In all the Summer procedures, there are no lines or blocks provided so that the operator can check off or initial where he is in the procedure.
This is not necessary at this time provided the operator uses some positive means to keep track of where he is.
It is suggested that operators may cross thru each step number or letter as it is completed as-one such means.
How does Summer accomplish it?
8.
Changing modes of operation on ESF equipment from one leg to another is to be done on a train-by-train basis. This is to ensure at least one train is successfully realigned before starting any operations or realigning the second train.
9.
Valves are listed as "MOV8888A(B)" to indicate two valves MOV8888A and M0V88888.
Summer has mixed designations to also indicate "M0V888A and B ;'.
Emergency procedures must clearly indicate how many items are involved and their name and designation as shown on the control panel.
10.
f;otes should not contain action statements since operators have a tendency to overlook notes in order to get the steps accomplished.
In general, notes should only be used to remind the operator of areas covered in training that might be forgotten in stressful situations.
Cautions should also not include action statements or negative directions, i.e., "do not" do something.
11.
Actions should be reviewed to allow operators to complete auxiliary building lineups, breaker changes, and samples before the areas become 200 hot to enter.
i SAFETY INJECTION ACTUATION - E0P-1 I
1.
This procedure contains attachments for LOCA, Loss of Secondary Coolant, and SG Tube Rupture but from the standpoint that you get a safety injection.
There are also procedures for LOCA and j
Feedline/Steamline Break for circumstances where you do not get safety injection. This is not entirely consistent with the Westinghouse Guidelines which begins with events above the abnormal operating procedure level and treats each of the i-emergency situations as separate procedures. The Westinghouse l
Guidelines have provisions.in the E0 procedure for situations where safety injection is or is not actuated. The licensee l
should be prepared to discuss how their arrangement of procedures is as appropriate or more appropriate than the 1
Westinghouse Guidelines.
2.
In our general comments 3 and 4, we noted a preference to the separation of such subsections as Automatic Actions, Immediate i
Actions, and subsequent or follow-up actions.
Automatic actions can be specific as in the Summer procedures or this same specific 1
information can be in the immediate actions section.
There is a j
rational for the latter which goes as follows.
4 I
The accident has occurred and the operator performs the immediate actions from memory without the E0P being referred to.
He then opens the E0P and verifies the immediate actions were completed before starting with the follow-up actions.
If all the immediate actions were listed in immediate actions (exceptions being Appendices), the opeFa~ tor would proceed from step 3.1.3A thru I.
However, in the Summer procedure, the operator would proceed to 3.1.3A which directs him to -3.1.2A thru D, then to Appendix IV, 2
i and then to 3.1.3B thru 1.
This back and forth verification has greater potential for an operator to skip important items.
A suggested improvement would be to list under automatic actions the major events such as reactor trip, turbine trip, safety j
)
injection, ESF actuation, phase A and B isolation.
Then all i
the items under 3.1.2B (1 thru 18) and 3.1.2C (1 and 2) and the MSIV note could appear under 3.1.3A and the operator would have no need to refer back to automatic actions.
3.
_In step 3.1.38, it is our understanding from the Attachment V that Summer has ESF Status Monitor Lights which are either dim or bright on SI, Phase _ A, Phase B, or recirculation.
It is cur objective that the operator be able to quickly verify by the status lights the condition of SI, ESF, and containment isolation.
With the random arrangement of dim and bright lights at Summer, this function.is going to be done less than quickly and will
. require a dedicated operat'or to compare Appendix V with the lights.
The. licensee.should be prepared to discuss this and i
the possibility of grouping lights with clear separation lines so that Appendix V verification can follow immediate actiens possibly as a follow-up action.
i r..
. t 4.
Step 3.1.3D does not indicate that the SGs should be filled to no-load levels or at least to cover the U-tubes before the aux feedwater flow is regulated to maintain required level.
5.
Step 3.1.3F may hold the operator up during an accident if the operator is taught to respond to " verify" by making it happen if it did not and if he is taught not to go beyond a step until he completes it.
It is not clear that the SG will respond this way for all the accidents following SI.
Therefore, the operator may attempt to hold up subsequent operations until he gets the 1092 PSIG. This operation does not apptar consistent with the k'estinghouse Guidelines.
The Note following step F should be a "If" step and/or combined with step E.
6.
Step 3.1.3G is a follow-up step in the Westinghouse Guidelines and includes additional instructions for verifying natural circulation.
If the Summer E0P includes this action in the immediate steps, all the requirements for stopping a pump should be included there.
7.
Is the first Note in 3.1.4 in response to Bulletin 79-21?
How is Attachment VI used by the operator during an accident?
Are control panel indicators marked for error bands during an accident and does this error band include errors due to temperature? Be prepared to discuss.
E.
Step 3.1.4A includes too many action steps to be effective.
4 These include closing the PORV, ensuring subcooled conditions, raintaining SI, and cooldown by steam dump to the condenser /
atmosphere.
Each of these functions need to be sequentially grouped so that the operator can take the appropriate action which will lead him to step F or step B.
The first action under 3.1.4A should be to evaluate RCS pressure and if decreasing, close the PORV's.
Include the note about PORV RTD's.
The second action which can be done independently by an operator would be to verify all immediate actions were taken.
Then the evaluation of RCS pressure, if above the low pressure reactor trip setpoint and stable or increasing, should send the operator to step F.
The operator should not be hung up at this point trying to get subcooling.
Some accidents if not attended to in the proper sequence and quickly, can get worse.
Also the subcooling margin should be discussed.
Is it 40"F or 50F?
. 9.
Step 3.1.4B requires natural circulation be established if possible.
Summer should provide a step by step procedure to determine if natural circulation exists; if not, how to enhance natural circuation; if established, how to assure it is maintained.
This procedure, or attachment than can be included with several procedures, might utilize the following in determining existence of natural circulation:
subcooling meters, core exit thermocouples, wide range Th trends, wide range T trends, loop AT indication trends, heat removal from c
SGs, pressurizer pressure and level trends.
These trends may also indicate the approach to inadequate core cooling (ICC) if natural circulation does not exists.
10.
The note following 3.1.4E refers to Attachment VI for a listing of PAM instruments.
Attachment VI gives error bands for each.
Is thisBulletin 79-21 type info? The note also refers to ensuring no void formation.
The operators should be monitoring the subcooling monitors and taking action on natural circulation or ICC, if required at this time.
See comment 9 above.
11.
Is Attachment VII based on 50 F subcooling?
12.
In step 3.1.4F, there is no provision for the water level in at least one SG to be above the U-tubes.
Why is Summer E0P different from Westinghouse Guidelines.
13.
In step 3.1.4G there is a 10 minute criteria that does not appear in the Westinghouse Guidelines.
Please explain.
There are additional steps in the Westinghouse Guidelines (i,j,k,1) that do not appear in this E0P.
Are they covered in SOP-il2?
i 14.
The note in the Westinghouse Guidelines E-0-(HP)-ll is covered by 3.1.5.
However, the step 3.1.4G has directed the operator to 50P-112.
How does the operator know after going to SOP-ll2 to return to 3.1.15 which is an "if" action and re-diagnositics?
15.
The Caution on page 11 establishes a subcooling criteria of 55 F.
Earlier there was a subcooling criteria of 40 F.
The recognized subcooling in parts of the Westinghouse Guidelines is 50 F.
Please explain why Summer is different.
The remaining comments on E0P-1, Safety injection Actuation, will be addressed to each of the Attachments I thru III.
Comments on Attachments P/ thru VII have been made.
Comments on Attachments VIII thru X will appear as they are referenced in Attachments I thru 111.
l.055 0F COOLANT - ECP-1 Attachment I 1.
In step 1.1.2, the operator is directed to step 1.1.4 for the large break.
Is this on page 4 of Attachment I and is it item I?
2.
The first Caution in step 1.1.2 should be a step even though Q lists it as a caution.
It requires a positive action (monitor RWST level) and gives clear direction (go to step whatever) if a large break occurs.
The operator should not overlook any part of this caution.
3.
Attachment VI should give instruction to verify both operation and recording of PAMS.
4.
In step 1.1.2D, the levels given for the condensate storage tanks are in gallons.
Does the control panel readout gallons or feet? The caution should be included with the step as the alternative to available condensate; i.e., drop the caution and make into "if" action statements.
"If" condensate available, fill per S0P 208.
"If" condensate not available, align to service water, etc.
5.
In step 1.1.2F4, the plant is restored to normal operation per sections 4.6 of SOP 112.
Are steps C.3.F thru K of the W Guidelines included in 50P 112.
If so and if 50 F subcooling cannot be maintained, does 50P 112 refer the operator to step 1.1.2G of Attachment I of E0P-1? See step C.3.K of the W guidelines.
Does Attachment X have anything to do with S1 reset at this point?
6.
In step 1.1.2H the subcooling is based on 40 F as in Attachment VII.
See SI comments 8, 11, and 15.
7.
Step 1.1.21 may be correct if done in conjunction with step G.
If done at another time as allowed by the note in I, the high head safety injection pump operation should be verified first as part of this step.
For. comments on natural, circulation, see SI comment 9.
8.
Step 1.1.2J directs the operator to step 1.1.4A which is " Final Condition" - hot leg recirc has been established.
Should this be step 0 rather than 1.1.4A to be consistent with the W Guidelines?
Or should it be step L so as not to leave out steps E, M, N?
9.
In step 1.1.2K, the two notes are more appropriate as steps or part of the steps.
Notes are sometimes overlooked.
Steps are not.
The first Caution applies equally to the step 1 or 2.
The second Caution refers to step 1.1.4 and again, it has got to be wrong.
Does the note on evaluation of plant equipment have anything to do with Attachment VIII?
2-10.
In step 1.1.2L, it is not clear that there is sufficient criteria for terminating RB spray (RB pressure return to normal) so that potential releases remain within Part 100 limits.
The licensee should consider criteria which takes into account short-term and long-term heat in the sump and its effects on containment pressure.
The licensee should also consider criteria for initiating sprays if required to reduce pressure caused by a small break LOCA which does not quite reach Phase B initiation.
A long-term pressurization of containment below Phase 8 may offer more potential for releases than the short-term pressure peak from the large LOCA.
Containment coolers may help to reduce the temperature and pressure but if they are depended upon for this function, the emergency procedures should include verification of their operation and integrity.
In determining the criteria for manually initiating the sprays at pressures below Phase B, consideration also must be given to effects of sprays on vital equipment in containment.
11.
In step 1.1.2N, is there a H concentration lovel criteria for 2
initiation of 50P 122?
12.
In step 1.1.2, 0,1, it would be helpful to instruct the operator when " prior" should begin; if Lo-Lo is at 18%, should he start at 20!!, as an example.
13.
On Page 6 of LOCA attachment, tne first three cautions should be steps or part of steps and the last caution deserves some rewording or be combined with the previous caution.
If a sump valve fails tc open, the RHR pump is tripped.
Shouldn't the corresponding RWST suction valve be closed to the tripped RHR pump?
l '4.
For steps 1.1.2, 0, 4 thru 11, can this be done on a train by train basis? Any reason why it should not be done on a train by train basis?
In Figure 6.3-1, Sheet 3 of the FSAR, the RHR pump discharge to the charging pump suction line and MVG 8706A and B are left off.
Figure 6.3-1, Sheet 1 indicates these lines come from drawing Il4E074.
15.
In step 1.1.2, 0, IS, the operator is referred to section 1.1.4B of this attachment.
Where is that? Also see comment 10 above on criteria for sprays.
If RWST has run out at this point, and sprays have been off for some time, spray effectiveness may not be sufficient for radiation control if insufficient NaOH has not been added to Follow-on spray in recirc mode would also be ineffective.
sump.
16.
In Table E-1.1 and E-1.2 of the Westinghouse Guidelines there are contingency actions listed.
How does Summer handle these and other contingency plans for E0P events? How does approval for use of contingencies work?
--3 17.
For educational purposes, what does the last step (14) in cold leg reciculation do? List the switches and locations.
18.
In step 1.1.2Q, the action covers both situations where RB sprays were continuously run or had been stopped.
In step 3, and if the sprays had been stopped, the caustic tank will still be at the level where it was stopped butthe RWST will be at the Low-Low level.
The caustic tank will be at the Low-Low level only if the spray was run.
Shouldn't the step read...." Verify (if RB spray was not interrupted) that the.....
Step 4 is keyed to RWST level only.
Does the caustic tank low level alarm also determine when the switch to recirc mode should begin by stopping the RB spray pumps?
19.
In step 1.1.20 5, there are six valves to be closed.
These are lesser used valves.
Is their location known? Also see step 6 for some comment.
20.
The NOTE following step 1.1.20 6 is an "if" action statement with steps 7, 8, and 9 part of that statement.
The note should become a step.
21.
In step 1.1.2R, which is word for word from the W guidelines, the operators are left to their own devices as to how to take the actions.
Some of these actions should be by a check off list, some by recording values to look for degradation trends, some by reference to 50P's, etc.
It is recommended that this step be shortened to a clear statement to do the evaluation in cold leg recirc mode by " initiating Attachment ~ and its instructions".
The attachment or wherever it is included (might be an existing SOP) would be self explanatory and result in the desired comprehensive evaluation of vital equipment.
22.
In step 1.1.25, comments have been made on train-to-train switchover.
In step 1, the switches should be listed and location given.
In step 2 with loss of power, is manual action taken from the control room or must someone go to the valve?
If high radiation exists at the valve or in the area, what action is required?
The note following step 2 should be an "if" statement included with step 2.
This same reasoning apslies to the note following step 4.
Steps 5 thru 9 should be arranged in tabular form by step and by train to avoid confusion.
Operating flow values and panel locations are important.
i m
. 23.
In step 1.1.2T, the swing pump arrangement should also be put in tabular form by action by train with clear instruction to do one but not both.
24.
Step 1.1.20 should be to continue hot leg to cold leg to hot leg recirculation switchover every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using steps 0 and S.
25.
In step 1.1.4 (what happened to 1.1.3?), the final condition will be hot or cold leg recirculation with stable plant conditions, etc.
26.
In the W guidelines, cold leg and hot leg recirculation included some contingency actions.
See comment 16 above.
1 l
STI AM Glfif t:ATOR TilBI lylPTURE, l.
In step 1.1.1, reference is made to symptoms in E0P-1, Section 3.1.4.C.
Innediate actions are referenced to section 3.1.3.
See SI comment aber 2.
reth steps 1.1.1 and 1.1.2, the page number would help for the arenced section unless the steps are changed by comment 1 above.
.. note preceding step 1.1 adds nothing for the operator.
Consider removing.
4.
The last half of the caution following step 1.1.3 on the diesel generators should be made into a step following the first instruction on resetting SI.
5.
The revised W guidelines give instructions to immediately identify the faulted 5G and isolate it.
The Summer procedures should be revised accordingly.
Therefore, the note at the top of page 2 of 9 of Attachment Ill can be dropped.
6.
The third note on page 2 of 9, Attachment til should be a step and placed in the proper order to avoid operator oversight.
7.
In step 1.1.3B, the current action step, cautions, and notes should be arranged in one step to include "if" statements and actions so that nothing is lost by operator oversight in skipping notes and long cautions.
The Summer procedure is written like the W guidelines but both can be improved.
8.
Fe' lowing step 1.1.38, there should be a step to verify natural circulation.
See SI comments numbers 6 and 9.
9.
Step 1.1.3C will now follow the steps to isolate the failed SG, therefore, same word changes are needed in the step.
The note at the top of page 3 of 9 of Attachment III can be dropped.
Each action item should be delineated.
10.
Is step 1.1.3D applicable caly "if" no offsite power is available?
11.
The note following step 1.1.3D is for loss of power but includes several action items which are not fully prescribed for the operator.
Criteria for reset of 51 with loss of offsite power is not included.
All action statements must be removed from notes and placed in the appropriate order as step,s.
Attachment X i' rc;trenced as seemingly related to loss of offsite power (see note commented on ahnve).
However, there is nothirg in Attachment X to indicate this.
When and where is Attachment X to be used? Comnents on Attachment X:
- The first note appears to be e.n action statement rather than a note.
i - The second note is an "if" statement and actions to be taken.
It should be item 2 under A.
- Where are the annunciators in step 37
- What action should be taken to prevent the " caution" following step 3? Perhaps there should be a step to verify switches are in the right position before Phase A reset occurs.
- In step 4.A, is it necessary for the operator to "see SOP 220" or is it advisable for some reason?
Item 60 and the valves involved should be on the same page.
The note following item 6 contains a verification action statement.
- Step 12 needs to be put on the same page as the valves involved.
12.
Step E does include actions in the right sequence.
The statement should be revised as follows:
If condenser available, use main steam dumps.
If offsite power or condenser not available;
- reset SI per Attachment X.
- verify instrument air compressor in service.
'The caution or reinitiation of SI with reactor trip breakers not reset should be included here.
13.
The note following step F should no loncer be needed if the W revised guidelines are followed and steps H and I are moved to the front of the procedure.
The note should be replaced by either a step to verify condenser level and be prepared to switch to alternate water supply or by a note to remind operator that alternate water supply is river water or other source.
14.
Following step G, the last caution before step H regarding~the turbine driven emergency feedwater pump should be included as a step in the isolation of the f aulted SG if B or C.
15.
As inJicated above, items H and I are to be moved forward in the procedure to be consistent' with the revised W guidelines.
. 16.
In step H, item 2 and the following note, does SI have to be reset to do item 2? Is this too early to be resetting SI now that this step is to be the first?
In item 2 and 3 the monitors and procedures for sampling respectively, are not listed.
Item 4 does not list the recorders involved.
17.
The Summer procedure does not include a provision for cooldown if the faulted SG cannot be isolated, i.e., isolate all the other SGs and use the non-faulted SGs PORVs to maintain RCS at no-load conditions.
This is a note in the h[ guidelines.
18.
In step L and M, consideration can be given to including the CVCS aux spray to the pressurizer if the regenerative heat exchanger is operating and the CVCS spray water to the pressurizer is heated.
This can be an alternative to the RCS sprays to depressurize the RCS and the PORVs if neither of these are availabl e.
19.
Beginning with step 0, the Sunmer procedures are almost word-for-word like the guidelines.
Statement restructuring is advisable to provide a step-by-step direction for the ope ra tor.
This can be discussed.
20.
In step R, the criteria for subcooling is left out.
21.
The caution following step R on DG operation should be changed to a step to verify reliable offsite power and then place the D3s in standby condition.
22.
The caution following step T does not address subcooling.
21.
The b[ guidelines include a caution before step X that directs the operator to proceed thru X, Y, and 1.1.4A simultaneously or pressurizer level control could be lost.
Where is Summer caution?
24 Consideration should be given by Summer to deletion of step X and increasing the sampling of the RCS to maintain boron levels.
Cooldown would then be accomplished by bleeding the faulted SG back to the RCS but the potential for offsite releases and further contamination of the secondary side would be reduced.
Also related to this comment, the note in the W guidelines on sampling the RCS and SG and preventing exceeding 10 CFR 100 releases has not been included by Summer.
25.
The Summer format begins to show problems with step 1.1.4 entitled
" Follow-Up Actions) which is actually a continuation of 1.1.3 but the alphabet ran out.
This format adopted by Summer does not help the situation and could confuse the operator in stressful situations.
The licensee should be prepared to discuss.
26.
Step 1.1.4A2 is incomplete.
CVCS oux sprays can only be used if the regenerative heat exchanger is in operation and the aux spray is heated.
The note following step 1.1.4A references Attachment IX which has not been included.
27.
The caution following 1.1.4A should be a step and the actions clearly spelled out.
28.
Are there instructions for accomplishing steo 1.1.4C? There are breakers involved as well as switches.
29.
Steps 26 and 27 of the h[ guidelines are left out.
Are they in GOP-7?
REACTOR TRIP 1.
Step 3.3.lB indicates the operator should borate 100 PPM.
Can the operator measure 100 PPM or does the following note provide the only measurement to the operator, i.e., 16 1/2 minutes?
2.
Between steps 3.3.1 and 3.3.2, it should be clear that the operators should attempt to simultaneously trip both the reactor and turbine.
There should be no delay in tripping the turbine if the reactor does not trip.
3.
Step 3.3.3 provides verification if condenser is available.
Is there another procedure if loss of offsite power or condenser are not available as far as verification of steam dump is concerned? What specific action will the operator see to do the verification? The guidelines also call for verification that RCS avg Temp is decreasing toward no-load temperature.
4.
In step 3.3.4, the conditions for automatic initiation of SI should be included along with setpoints and monitors.
See 3.1.lB for the parameters.
If any of the setpoint conditions are approaching SI, the operator should have available E0P-1.
If the setpoints are reached, is the operator totally in E0P-1 or is there any steps in E0P-5 that should be* completed first or at some later time?
If they are to be completed at some later time after initiation of E0P-1, where in E0P-1 or the other E0Ps is this requirenent?
5.
The guidelines (item 3) call for verification that at least one RCS pump remains in operation.
This step appears immediately after verification of turbine trip.
Items 5, 6, and 7 of the guidelines are also missing from the immediate steps.
The licensee should be prepared to discuss.
6.
Step 3.4.8, the following note, step 3.4.9, and 3.4.9A all deal with starting aux feed pumps, throttling flow, 25*; levels, and low-low level alarms on the SG.
It is suggested that these could all be placed in one step and presented in an orderly manner which should help the operator.
7.
Item C.3 of the guidelines calls for monitoring the RCS avg temp (step 3.4.2), pressurizer level and pressure (step 3.3.4), and proper operation of the PORV with instruction on closing the block valves.
The licensee should be prepared to discuss placing all these actions in the Follow-Up section as suggested by the cuidelines.
8.
Item 8 of the guidelines on bnration as necessary is covered partially by steps 3.3.1B and 3.4.3 but only in the cases of ATWS and uncontrolled cooldown.
Step 3.3.1B also covers the cases for rods not fully inserted, however, these is no instructions in the follow up section to monitor the results of the boration and to reset reactor makeup controls for automatic makeup of required boron concentration.
j 9.
Is item 6 of the guidelin'es on loss of condenser covered in 50?-202 as suggested by the note following step 3.4.12?
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-2 10.
The note following 3.4.14 indicates steps 3.4.13 and 3.4.14 may not be correct if the Aux Boiler is not in operation.
The note should be incorporated with 3.4.13 and 14 and some indication given if the Aux f3 oiler is not in operation.
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9 MEETING
SUMMARY
DISTRIBUTION Docket File D. Muller NRC PDR R. Ballard Local PDR_
W, Regan NSIC D. Ross TIC P. Check TERA R. Satterfield NRR Reading
- 0. Parr LB #2 File F. Rosa H. Denton W. Butler 3
i E. Case W. Kreger D. Eisenhut R. Houston
-=
R. Purple T. Murphy a
B. J. Youngblood L. Rubenstein A. Schwencer T. Speis F. Miraglia W. Johnston J. Miller J. Stolz G. Lainas S. Hanauer R. Vollmer W. Gammill J. P. Knight F. Schroeder R. Bosnak D. Skovholt F. Schauer M. Ernst c
R. E. Jackson W. Kane R. Baer Project Manager C. Berlinger Licensing Assistant MService K. Kniel J
Attorney, OELD G. Knighton I&E (3)
A. Thadani ACRS (16)
D. Tondi R. Tedesco-D. Vassallo G. Lear J. Kramer V. Noonan P. Collins a
S. Pawlicki D. Ziemann e
V. Benaroya i
Z. Rosztoczy W. Haass
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NRC Participants.:
Others:
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P I
i BCC: Applicant & Service List j.
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