ML19339A225
| ML19339A225 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 10/20/1980 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Ramos S Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0696, RTR-NUREG-696 NUDOCS 8011030340 | |
| Download: ML19339A225 (5) | |
Text
.
e
(
SMUD SACRAMENTO MUNICIPAL UTILITY CisTRICT [] 6201 s street. Box 15830. sacramento, Cahfornia 95813; (916) 452-3211 October 20, 1980 Office of Iluclear Reactor Regulation Emergency Preparedness Progran Office U.S. !!uclear Regulatory Commission Washington, D.C.
20553 Attenticn:
Mr. Steve L. Ra:nos Mail Stop Phillips 242 tiUREG-0696
" Functional Criteria for Emergency Response Facilities" Rancho Seco lJuclear Generating Station, Unit 1
Dear l'r. Rauos:
The incident at Three fiile Island Unit 82 has resulted in many lessons learned throughout the nuclear industry. fiany of the lessons involved emergency planning.
The fiRC is now deeply involved with the development of documents (i4UREG-0654 and flVREG-0696) to provide guidance in imple-menting possible solutions.
The systems and facilities described in tiUREG-0696 address the followir.g dreas of frustration experienced during the TMI Unit #2 incident:
The control room operators' misinterpretation cf the status of various plant systems.
The technical advisors' inability to deal with the limited space in the control room.
The public officials' and the general population's inability to obtain timely and accurate information.
The Safety Parameter Jisplay System (SPOS), Technical Support Centar (TSC),
Emergency Operations Facility (EOF), and the Nuclear Data Lin!: (f;DL) attempt to solve each of these frustrations.
b b
so11030#0, m.
- s. c, 11.
,s
~.. - - -
- m. ~
(
~
a i
Mr. Steve L. Ramos Page 2 October 20, 1980 4
The SPDS, as described, will be similar in function to the displays currently available at the Loss of Fluid. Test (LOFT) facility in Idaho. This is a one of a kind system on a very unique reactor. There are indications that this type of system may soon be installed at various reactor simulators. The dis-plays that evolve will probably be much different than the LOFT system.
The displays between NSSS vendors and between different designs of a given NSSS vendor will also evolve to meet the needs of the various design configurations.
May I suggest that the R&D, debugging, and operator testing be done on the reactor simulators first.
Then, after the wrinkles h:ve been ironed out, imple-
]
ment the SPDS on the operating reactors.
Our concerns are:
1.
An unproven system should not be installed in an operating reactor.
This may in reality compromise the overall safety of the plant if installed without proper development and testing.
2.
Research and development, debugging, and operator training should be done on reactor simulators first.
Great expenditures of time and energy could be wasted if each operating reactor were to develop its own system.
3.
A superior SPDS may be in operation faster if done through proper R&D. An inferior system plagued with problems could result, if each operating reactor were forced to do the development on its own.
The NDL to the NRC Headquarters in Bethesda appears to be of limited value and usefulness. The TSC will have at its fingertips all necessary plant information and expertise to provide guidance to the control room. The time spent for the NRC in setting up a command center in Bethesda may best be spent in transit to the site and to be involvea at the TSC. The desire for the NRC to hold press i
l conferences in Bethesda would also diminish the effectiveness of the E0F. The EOF will have all the necessary information and be familiar with site specific conditions to provide the public with timely and credible information.
Pro-visions will be made for the NRC at both the TSC and the EOF.
I suggest that the overall emergency response best be served if the NRC exercised those provi-sions.
The concept that the media be accommodatedfor at the E0F is also questionable.
The nedia will swarm wherever information is released. The facilities and capabilities of the E0F may become severely strained if information is released at the EOF. The volume of people and equipment would compromise the overall emergency response function of the EOF. We do.not deny the need to keep the people informed via the media. We feel that the overall emergency response best be accomplished if the media center be kept separate from the EOF. And all media releases should be done at one location, in concurrence with the public officials involved, and each major group should be represented to answer questions.
m.
Mr. Steve L. Ramos Page 3 October 20, 1980 ine following comments apply to specific sections of NUREG-0696.
Page 3, Paragraph 1 "While the TSC function is centered on management of the plant in the mitigation of accidents, the EOF is designed to provide assistance in the decision making process to protect the public health and safety and to control radiological monitoring teams and facilities onsite and cffsite."
The TSC has the onsite responsibilities while the EOF has all the offsite. Why then should the E0F control the onsite radiological monitoring team? Suggested rewording:
... and to control radiological monitoring teams and facilities offsite."
Page 3, Paragraph 1 "The E0F must have radiological and meteorological data and adequate plant systems information to perform these functions."
Please specify what is meant by " adequate plant systems information".
Would a direct telephone line to the TSC satisfy this criteria? The EOF is not responsible for technical advice to the control room.
The E0F need not overlap the function of the TSC.
Page 19, Paragraph 2
" Data providing information on the general condition of the plant is also required in the E0F for utility resource management and recovery manage-cent. At minimum, the EOF data set will include data for all Type A, B, C, D, and E variables specified by R.G.1.97.
Signals from sensors pro-viding data for variables specified by R.G. 1.97 shall be input directly into the data acquisition processor serving the EOF with no previous signal processing by a plant process computer.
The EOF shall receive and have the capability to display the same plant data and radiological infor-mation that is transmitted to the NRC."
The EOF is concerned only with the offsite emergency response. The TSC is the technical advisor to the control room and an interface between the onsite and offsite groups.
Those people who will be providing technical advice concerning plant systems and operation will be in the TSC, not the EOF. The proper func-tion of the E0F does not require the variables specified by R.G.1.97 to func-tion as NUREG-0696 describes.
The dedicated communication links between the E0F and TSC should provide any additional specific data that could be desired by the E0F staff.
Suggested rewording:
deletion.
and i
(
Mr.. Steve L. Ramos Page 4 October 20,-1980
" Data trending and time history data display capability shall be provided in the E0F for evaluating radiological and environmental data and plant data."
The need for data trending and time history data display of plant data at the E0F is questionable. - This function should be with the TSC.
Suggested rewording: delete "and plant data."
Page 19, Paragraph-4 "All data transmitted to the NRC or other offsite locations shall also be available for. display in the E0F."
The NDL transmission to the NRC is not necessary for the proper function of the E0F. The TSC is the location where technical advice and guidance concern-ing plant systems and operations will be provided.
The 20F should have no need'for this volume of information.
Suggested rewording: deletion.
1 Page 20, Paragraph 2 "The EOF shall have ready access to up-to-date plant records, procedures, and emergency plans needed to exercise overall utility resources management j
and for recovery management."
j The EOF does not need plant records to satisfy its function. E a prolonged I
recovery is necessary and H it is managed from the EOF, then these records can be obtained on an ad hoc basis.
i Suggested rewording:. delete "up-to-date plant records" and "and for recovery management".
Page 20 V.
Nuclear Data Link (NDL)
I seriously doubt the usefulness of the NDL system for the following 4
reasons:
1.
Technical advice and guidance will be provided from the TSC.
2.
Plant management and plant operators will place a much higher credibility on the advice from those intimately involved with the design, construction, and operation of the plant.
Less credibility will be given to advice-from a group in Bethesda with limited experience on our particular plant design and characteristics.
1 f
-,m-,,
r-
Mr. Steve L. Ramos Page 5 October 20, 1980 3.
flRC advice and guidance should be provided at the TSC.
4.
Existing dedicated telephone links should provide Bethesda with adequate information.
Sincerely, John. Mattimoe Assistant General Manager and Chief Engineer