ML20004F514

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Forwards to Westinghouse Owners Group Re Interim Review of Action Plan Item I.C.1 Re Guidance for Procedures for Transients & Accidents.Further Work Will Be Necessary to Satisfy NRC Positions
ML20004F514
Person / Time
Site: Vogtle  
Issue date: 06/15/1981
From: Youngblood B
Office of Nuclear Reactor Regulation
To: Ehrensperger W
GEORGIA POWER CO.
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.1, TASK-TM NUDOCS 8106180502
Download: ML20004F514 (2)


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WASHINGTON. D. C. 20555 JUN 151981 Docket Nos.: 50-424 l

and 50-425 Mr. W. E. Ehrensperger Senior Vice President, Power Supply Georgia Power Company Post Office Box 4545 Atlanta, Gergia 30302

Dear Mr. Ehrensperger:

Subject:

Staff Evaluation of Item I.C.1 for Westinghouse Facilities We have completed our interim review of the Westinghouse Owr. ors Grcup submittal for Action Plan item I.C.1, Guidance for the Evaluation and Development of Procedures for Transients and Accidents. A copy of Mr. Eisenhut's May 28, 1981 letter to Mr. Jurgensen, Chairman, Westing-house Owners Group is enclosed for your information. As indicated in the enclosure, further work will be nacessary in order to produce a document which sat',sfies the staff positions in a timely matter.

Sincerely, I.

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B. J. Youngblood, Chief Licensing Branch No.1 Division of Licensing Enclosu;r:

As stated cc: See next page 45 df /

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Mr. W. E. Ehrensperger Senior Vice President Power Supply Georgia Power Company P. O. Box 4545 Atlanta, Georgia 30302 cc:.Mr. L. T. Gucwa Chief Nuclear Engineer Georgia Power Company P. O. Box 4545 Atlanta, Georgia 30302 Mr. Ruble A. Thomas Vice President Southern Services, Inc.

P. O. Box 2625 Birmingham, Alabama 35202 Mr. J. A. Baily Project Licensing Manager l

Southern Company Services, Inc.

P. O. Box 2625 i

Birmingham, Alabama 35202 George F. Trowbridge, Esq.

Shaw, Pittman, Potts and Trowbridge 1800 M Street, N. W.

Washington, D. C.

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UNITED STATES

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',h NUCLEAR REGULATORY COMMISSION wAsmwarow o.c.-ossa

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.....Robert W. Jurgensen, Chairman r

Westinghouse Owners Group l

American Electric Power Service Corporation 2 Broadway l

New York, New York 10004 r

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Dear Mr. Jurgensen:

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18, 1981 (06-54), you summarized a meeting In your letter dated Marchbetween representatives of the NRC staff, held on February 20, 1981

.The purpose Westinghouse Owners, and Westinghouse Electric Corporat i

l activities in response to NUREG-0737, Clarification of TMI Action Plan Requirements, Item I.C.1, Guidance for the Evaluation and Develop-Following the meeting ment of Procedures for Transients and Accidents.

l summary, you requested that the staff acknowledge the acceptability of i

the program described in }.he meeting.

As indicated in a meeting with Tom Anderson, of Westinghouse, on April 8, '-

1981, we have concerns about the acceptability of the WOGThe l Inadequate Core Cooling Guidelines, required the operator to diagnose program.

a specific event using the diagnostic procedure included in the guide-l Subsecuent' failures were, essentially, addressed by entry into -

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one of the inadequate core cooling guidelines.

February meeting and discussed in your letter..the guidelines do not provide smooth transitions from the event procedures to direct theThis operator if subsequent multiple or consequential failures occurI Furthermore, the Inadequate Core Cooling Guidelines are reached.

guidelines do not address subsequent reevaluation of plant conditions 3

to ensure that the expected plant response is occurring.

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Our second concern is your proposed schedule for completing the program i

recognizing that development of emergency operating procedures is aHowever, w i

dynamic process with no absolute end point.that continual, major rel burden on plant operating staffs and confusing to the operators who l

In the February meetir.g. WOG representa-must relearn the procedures.

tives indicated thay they expect to have the initial development phase of the guidelines completed in July 1981, and would not expect major changes to the guidelines to result from the phases to be completed in l

You also state in your letter that the '

January 1982 and July 1982.

However, initial phase will address over 98 percent of the total risk.

we were also told in the meeting that the guidelines to be submitted in July would probably not differ greatly from those already submitted.

Considering our concerns with the existing guidelines, as addressed above, we do not see how the July submittal can be responsive to We believe that NUREG-0737, Item I.C.1 without significant change.

additional work is necessary.

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f The staff has not completed its review of WCAP 9691 or the probability estimates presented in the February meeting, and the Owners Group has not addressed the broad range of initiating events, including natural l

phenomens such as earthquakes, in the analysis presented to date.

l Therefore, we cannot assess the overall adequacy of the proposed I

.Unless our concerns, as stated herein, are satisfied, the program.

ability of licensees to meet the schedule for revising their procedures l

may be compromised.

7 As indicated in the April 8,1981 meeting, we have serious doubts that

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i the full range of initiating events and subsequent failures can be addressed within the event specific framework. adopted by the Westing-house Owners Group.

If your additional work to date provides.'more insight into resolution of these concerns, we would be available to meet with you at your convenience.

By copy of this letter, each licensee and applicant of a Westinghouse-

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type plant, is being advised of our evaluation of your submittal.

incerely,

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t Darrell G.

isenhut, Director Division of Licensing i

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E. Murphy W Licensees EApplicants i

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