ML20005B328

Submits Interim Review of Westinghouse Owners Group Submittal for TMI Action Plan Item I.C.1 Re Guidance for Evaluation & Development of Procedures for Transients & Accidents.Nrc to Owners Group Encl

ML20005B328
Person / Time
Site:	McGuire, Mcguire
Issue date:	06/18/1981
From:	Adensam E Office of Nuclear Reactor Regulation
To:	Parker W DUKE POWER CO.
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.1, TASK-TM NUDOCS 8107070200
Download: ML20005B328 (2)

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Subject:

Staff Evaluation of Item I.C.1 for Westinghouse Facilities (McGuire Nuclear Station, Units 1 and 2)

We have completed our interim revieel 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. A copy of Mr. Eisenhut's M e 28, 1981 letter to 11r. Jurgensen, Chairman, Westing-house Owners Group is enclosed for your information. As indicated in the enclosure, further work will be necessary in order to produce a document which satisfies the staff positions in a timely matter.

Sincerely.

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Elinor G. Adensam, Acting Chief Licensing Branch No. 4 Division of Lice 71ng

Enclosure:

As stated cc: See next page 8107070200 8106 PDR ADOCK 05000 9

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Vice Presidcnt, Steam Production Duke Foner Company P. O. Box 2178 422 South Church Street Charlotte, North Carolina 28242 cc: Mr. W. L. Porter Robert M. Lazo, Administrative Judoe Duke Power Company Atomic Safety and Licensing Poard P. O. Box 2178 U. S. Nuclear Regulatory Commission 422 South Church Street Washington, D. C.

20555 Charlotte, North Carolina 28242 Dr. Emmeth A. Luebke, Administrative Judae Mr. R. S. Howard Atomic Safety and Licensing Board Power Systems Division U. S. Nuclear Regulatory Commission Westinghouse Electric Corporation Washington, D. C.

20555 P. O. Box 355 Pittsburgh, Pennsylvania 15230 Dr. Richard F. Cole, Administrative Judge Atomic Safety and Licensing Board Mr. E. J. Keith U. S. Nuclear Regulatory Commission EDS Nuclear Incorportated Washington, D. C.

20555 220 Montgomery Street San Francisco, California 94104 Mr. J. E. Houghtaling NUS Corporation 2536 Countryside Boulevard Clearwater, Florida 33515 Mr. Jesse L. Riley, President The Carolina Environmental Study Group 854 Henley Place Charlotte, North Carolina 28207 J. Michael McGarry, III, Esq.

Debevoise & Liberman 1200 Seventeenth Street, N. W.

Washington, D. C.

20036 Ms. M.' J. Graham Resident Inspector McGuire NPS c/o U. S. Nuclear Regulatory Commission Post Office Box 216 Cornelius, North Carolina 28031 Shelley Blum, Esq.

1402 Vickers Avenue Durham, North Carolina 27707

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... iluberL W. Ja gensen, Chairman Westinghouse Owners Group toerican Clectric Power Service Corporation 2 Broadway

?!cw York, tiew York 10004

Dear Mr. Jurgensen:

18, 1981 (06-54), you summarized a meeting f

In your letter dated Marchbetween representatives of the flRC staff.

held on February 20, 1981 Westinghouse Owners, and Westinghouse Electric Corporation.

The purpose of the mec' ting was to discuss the Westinghouse Owners Group (WOG) 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.

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

l As indicated in a meeting with Tom Anderson, of Westinghouse, on April 8, 1981, we have concerns about the acceptability of the WOG

. The last submittal of generic WOG guidelines, includi.ng the program.

Inadequate Core Cooling Guidelines, required the operator to diagnose a specific event using the diagnostic procedure included in the guide-Subsequent' failures were, essentially, addressed by entry into lines.

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 consequential failures occur.

lesyes 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 a However, we are concerned dynamic process with no absolute end point.

that continual, major rewriting of emergency operating procedures is a burden on plant operating staffs and confusing to the operators who In the February meetir.c WOG representa-must relearn the procedures.

tives indicated thay they expect to have the initisl 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 You also state in your letter that the January 1982 and Jul., 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 %nge.

additional work is necessary.

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RAY E B 196; The :t:ff has nst completed its review of WCAP 9591 cr the probability esu...utes prese.. Led in the february meeting, cr.d tr.c 0,iners Group has not addressed the broad range of initiating events, including natural phenomena such as earthquakes, in the analysis presented to date.

Therefore, ue 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 serious 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 nore insight int'o 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, Darrell G.(Eisenhut, Director Division of Licensing cc:

E. Murphy W Licensees EApplicants e

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