ML20004F755

Advises That Interim Review of Westinghouse Owners Group Submittal for Action Plan Item I.C.1, Guidance for Evaluation & Development of Procedures for Transients & Accidents, Is Complete.Dg Eisenhut Encl

ML20004F755
Person / Time
Site:	Comanche Peak
Issue date:	06/11/1981
From:	Youngblood B Office of Nuclear Reactor Regulation
To:	Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.1, TASK-TM NUDOCS 8106220282
Download: ML20004F755 (2)

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DEisenhut TERA BJYoungblood NRC/PDr SBurwell L/PDR Docket Nos.: 50-445 RTedesco NSIC and 50 446 MRushbrook TIC RVollmer ACRS (16)

TMurley Mr, R. J. Gary, Executive RMattson Vice President and General Manager RHartfield, MPA Texas Utilities Generating Company OELD 2001 Bryan Tower OIE(3)

Dallas, Texas 75201

Subject:

Staff Evaluation of Item I.C.'. for Westinghcuse Facilities We have completed our interim review of the Westinghouse Owners Group submittal for Action Plan item I.C.1, Guidance for the Evaluation and Devcicpment 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 infomation. As indicated in the enclosure, further work will be ! ecessary in order to proouce a document which satisfies the staff positions in a timely matter.

Sincerely,

~0rigt:ml signed by:

B. J. Youngblood B. J. Yeunablood, Chief Licensing Branch No.1 Division of Licensing

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Mr. R. J. Gary Executive Vice President and General Manager--

Texas Utilities Generating Canpany 2001 Bryan Tower Dallas, Texas 75201 cc: Nicholas S. Reynolds, Esq.

Mr. Richard L. Fouke Debevoise & Liberman Citizens for Fair Utility Regulation 1200 Seventeenth Street 1668-B Carter Drive Washington, L C.

20036 Arlington, Texas, 76010 Spencer C. Relyea, Esq.

Resident Inspector / Comanche Peak Worsham, Forsythe & Sampels Nuclear Power Station 2001 Bryan Tower c/o U. S. Nuclear Regulatory Commission Dallas, Texas 75201 P. O. Box 38 Glen Rose, Texas 76043 Mr. Homer C. Schmidt Manager - Nuclear Services Texas Utilities Services, Inc.

2001 Bryan Tower Dallas, Texas 75201 Mr. H. R. Rock Gibbs and Hill, Inc.

393 Seventh Avenue New York, New York 10001 Mr. A. T. Parker Westinghouse Electric Corporation P. O. Box 355 Pittsburgh, Pennsylvania 15230 David J. Preister Assistant Attorney General Environmental Protection Division P. O. Box 12548, Capitol Station Austin, Texas 78711 Mrs. Juanita Ellis, President Citizens Association for Sound Energy 1426 South Polk Dallas, Texas 75224 Cwiht H.-Moore, Esq.

West Texas Legal Services 100 Main Street (Lawyers Bldg.)

Fort Worth,, Texas 76102 emme P90R ORIGINAI. ;

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IEAY 28 1981 Robert W.'Jurgensen, Chairman Westinghouse Owners Group American Electric Power Service Corporation 2 Broadway New York, New York 10004 0 7 Mr. Jurgensen:

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

.The purpose Westinghouse Owners, and Westinghouse Electric Corporatio activities in response to NUREG-0737, Clarification of TMI Action Plan Requirements Item I.C.1, Guidance for the Evaluation and sevelop-Following the meeting ment of Procedures for Transients and Accidents.

summary.you requested that the staff acknowledge the acceptability of the program described in the meeting.

As indicated in a meeting with Tom Anderson, of Westinghouse, on April 8, 1981, et have concerns about the acceptability of the WGG The last submittal of generic WOG guidelines, including the Inadequate Core Cooling Guidelines, required the operator'to diagnose program.

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

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As indicated in the 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 consecuential failures occur.

leaves the operator with no guidance until entry conditions for the Furthermore, the Inadequate Core Cooling Guidelines 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 aHowever, dynamic process with no absolute end point.that continual, major rewrit burden on plant operating staffs and confusing to the ooerators who In the February meeting, WOG representa-must relearn tne 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 pnases to be c mpleted in You also state in your letter that the January 1982 and July 1982.

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

we ware riso 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 l

above, we do not see how the July submittal can ce resconsive to We believe that NUREG-07T/, Item I.C.1 without significant change.

additior.a'. work is necessary.

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MAY 2 8 1981 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 dr.te.

Therefore, we cannot assess the overall adequacy of the proposed program. Unless our concerns, as stated herein, are satisfied, the ability of licensees to meet the schedule for revising their procedures may be compromised.

As indicated in the April 8,1981 meeting, we have sericus doubts that 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 convenieace.

By copy of this letter, each licensee and applicant of a Westinghouse-type plant, is being advised of our evaluation of your submittal.

incerely, p

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Carrell G.

isenhut, Director Division of Licensing cc:

E. Murphy W Licensees 5 Applicants m

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