ML20004F751

Discusses Deficiencies Identified in Interim Review of Westinghouse Owners Group Submittal for Action Plan Item I.C.1, Guidance for Evaluation & Development of Procedures for Transients & Accidents

ML20004F751
Person / Time
Site:	South Texas
Issue date:	06/10/1981
From:	Tedesco R Office of Nuclear Reactor Regulation
To:	Oprea G HOUSTON LIGHTING & POWER CO.
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.1, TASK-TM NUDOCS 8106220276
Download: ML20004F751 (2)

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UNITED STATES

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'JUN 10.19 81 Ib((Vid h

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Docket Nos.: 50-498/499 g

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• T JU Mr. G. W. Oprea, Jr.

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Executive Vice Presiden.

3 m,,,m.y Houston Lighting and O wer Company 61 a>wac.

s P. O. Box 1700

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Houston, Texas 77001

Dear Mr. Oprea:

The NRC staff has completed an interim rev% of the Westinghouse Owners Group submittal for Action Plan item I.C.1, Guidance for the Evaluation and Development of Procedures for Transients and Accidents. We have Mentified the following deficiencies in the Owners Group proposal:

1.

Proposed guidelir.as do not provide smooth transitions from the event pro-cedures to direct the operator if subsequent multiple or consequential failures occur.

2.

The proposed schedule for completing the program does not appear responsive to NUREG-0737 Item I.C.1 and we believe that additional work is necessary.

3. lhe staff has serious doubts that the full range of initiating events and subsequent failures can be addressed within the proposed event specific framework.

A copy of our letter to tne Owners Gr up is enclosed for your information.

c Sincerely, M". kp-f 1\\@0'l4 -

I Robe t Ted co, Assistant Director

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for Licensing fI Division of Licensing

Enclosure:

As stated-cc: See next page.

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s Richard h', Lo..trre, Esq.

Cr.fS.-G. Barker I.::f:::nt Att:rnty Ctr.:r:1 n-

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P. O. Box 12548-P. O. Box 1700

' Houston. Texas' 77001 Caoitol.5tation Austin. Tex:s 79711

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. Central Power and Light Cor.cany--

Snarnor. H..Pnillios Es.J.:. '. Ins. d t u.* L ;th.T e,.

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_Corput Christi, Texas-78403 c/c U. S. ta; P. O. So.: 910 Mr. R. L. Hancock Bay City, Texas 77414 City cf Austin P.,

J::::i F**ctric i:: Mity Desartme.-t P. 0. Box 1085 Houston Lighting and Power Cercany

~ Austin, Texas 70767 F. O. Gox 1700 Houston, Texes 7700' Mr. J.. B. Pos ton Assistant General ttanager for Operations' Pat Coy City Public Service Board Citizens Concerned About Nuclear Pons.

P.' 0.? Box 1771 5106 Casa Oro L

Sin Antonio, Texas 78296 San Antonio, Texas 78233 L

- Jack R; Newman, Esq.

Lowenstein, Newman, Axelrad & Toll 1025 Connecticut Avenue, N.W.

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20036 Melbert Schwarz, Jr., Esq.

. Baker & Botts One Shell Plaza Houston, Texas 77002 Mr.-J. R. Geurts-Brown & Root, Inc.

F. 0. Box 3 Houston, Texas 77001 Mrs. Peggy Buchorn Executive Director

- Citizens for Equitable Utilities, Inc.

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MAY 2 B 1981 Robert W. Jurgensen. Chairman Westinghouse Osners Group American Electric Power Service Corpora tion

.2 Broadday New York, tiew York 10004

Dear Mr. Jurgensen:

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 Corp activities in response to INREG-0737, Clarification of TMI Action Plan Requirements. Item I.C.1, Guidance for the Evaluation and Develop-F ment of Procedures for Trrnsients and Accidents. summary, the program described in the meeting.

As indicated in a meeting with Tom Ande-son, of Westinghouse, on Apri 1981, we have concerns about the acceptability of the WOG Inadequate Core Cooling Guide?ines, required the operator to diagnose program.

a snecific event using the diagnostic procedure include lines.

As indicated in the one of the inadequate core cooling guidelines.

provide smooth transitions from the event procedures This operator if subsequent multiple or consequential failures oc Furthermore, the Inadequate Core Cooling Guideltnes are reached.

guidelines do not address subsequent reevaluation of plant conditions to ensure that the expected plant response is occurring.

Our second concern is your proposed schedule for completing the program recognizing that development of emergency operating procedures is aHowe dynamic process with no absolute end point.

burden on plant operating staffs end confusing to the In the February meeting, WOG representa-must relearn the procedures.

tives indicated thay they expect to have the initial development phase of the guidelines comoleted in July 1981, and would 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 t Considering our concerns with the existing guidelines, as addressed above, we do not see how the July submittal can be responsive toWe believe that imREG-0737. Item I.C.1 without significant change.

additional work is necessary, 1

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. MAY 2 8 1981 I

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

- Therefore, we cannot assess the overall adequacy. of the proposed Unless our concerns, as stated herein. are satisfied, the program.

ability of licensees 'to meet the schedule for revising their procedures may be. compromised.

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

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the full range of initiitir.g events and subseauent failures can be addressed within the event specific framework adopted by the Westing-If your additional. work to date provides nore house Owners Group.

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

incerely, 4

W Darrell G.

isenhut, Of rector

' Division 'of Licensing cc:

E. Murphy W Licensees S Applicants I

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