ML20039B669

Submits Comments of ACRS 811117 Ltr,Per NRC 811202 Request. Util Pleased W/Positive Result

ML20039B669
Person / Time
Site:	Comanche Peak
Issue date:	12/18/1981
From:	Gary R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Harold Denton Office of Nuclear Reactor Regulation
References
TXX-3447, NUDOCS 8112230368
Download: ML20039B669 (5)

Text

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TEXAS UTILITIES GENERATING CO.ilI%NY

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• A s Mr. Harold Denton ' 2-

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Director of Nuclear Reactor Regulation

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U. S. Nuclear Regulatory Commission i~

DEC2219OI* 7 Office of Nuclear Reactor Regulation ~ u,; $"'" "' "'T3 Washington, D.C.

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SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION

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DOCKET NOS. 50-445, 50-446 j RESPONSE TO ACRS LETTER

REFERENCES:

(1) Texas Utilities Services Letter, to R. Tedesco, dated

. November 9, 1981 l (2) Texas Utilities Services Letter, to R. Tedesco, dated l November 25, 1981

Dear Mr. Denton:

We have reviewed a copy of the November 17, 1981 ACRS letter reporting on Comanche Peak Steam Electric Station Units 1 and 2 and offer the following comments as requested by your Mr. B. J. Youngblood's letter dated December 2, 1981.

For convenience and ease of understanding we have quoted directly from the ACRS letter and followed each quote with our comment. We have quoted only those parts of the ACRS letter which we think require comment.

QUOTE 1 1 The Reactor Protection System will use N-16 gamma radiation detectors to provide a signal for reactor trip. Because this system has not been proven in commercial applications, we recommend that the NRC Staff closely follow its implementation and operation. The Countttee wishes to be kept informed.

COMMENT 1 g

l TUGC0 has and will continue to provide the Staff with complete 5 and timely information about the N-16 system designed to improve sensitivity in the determination of reactor power. I U 8112230368 8112f8 /

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i l QUOTE 2 This is the first commerical nuclear power plant to be operated by TUGC0 and the first in the state of Texas. ~The Committee's

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review included consideration of the management, organization and capability and the operator training program. The training program is well planned and comprehensive, and includes simulator training at other facilities. We were favorably impressed with I the training program,-general competence,- and responsive attitude of the utility s operating organization. Nevertheless, there is.

a significant lack of hands-on experience with large commercial nuclear power plants that will only be corrected by the operation of the Comanche Peak Plant. The NRC Staff is< requiring the utility to strengthen its own organization with on-shift-personnel having experience with large commercial PWR operations until suitable experience has been developed by the operating

. staff. We endorse the NRC Staff requirement but recommend that attainment of 100% rated power should not be the only consideration in detennining that operational proficiency has been achieved.

COMMENT 2 We are pleased with this favorable report by the committee and concur in its recommendation. In fact, we stated to the committee that we intend to keep the extra experienced personnel as long as we feel that they enhance our operating capability.

Attainment of 100% rated power is by no means the only consideration in making this determination.

QUOTE 3 The Committee also recommends that the operating organization establish a list of technological matters which may have to be faced in future operation of the nucler.r plant and identify sources of skilled personnel and expertise that ought to be available to address these matters when needed. The Committee wishes to be kept informe~d.

COMMENT 3 As 1. art of the planning for technical support for operations, we have compiled lists of the types of technical expertise that will be needed for such support. We have continued to update op list of technical support needs and are engaged in an effort to ensure that we have available the necessary resources to meet these-needs. The staff will be kept informed.

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QUOTE 4 The Station Operations Review Committee, the Independent Safety J .- - Engineering Group, and .the Operations Review Group should include

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personnel from' outside the operating organization who are experienced in the ' operational management of large PWRs and related technology as well as other independent advisors with mature judgment about public safety matters.

- - COMMENT 4 y The Station Operations Review Committee (SORC) is, as its name implies, composed,of members of the station operations

? organization under' the management and direction of the Manager, Plant Operations. This committee is intended to "... provide, as part of the normal duties of plant supervisory personnel, timely and continuing monitoring of operating activities...", as is stated and required in ANSI-N 18.7, Section 4.4. The SORC as it is presently staffed meets the acceptance criteria of NUREG-75/087, Section 13.4.

It is our opinion th'at having persons who are not members of the n s operating organization serve as regular members of this committee would adversely affect this committee's ability to meet on very e sh6rt notice and provide the required timely and continuing monitoring of operating activities.

1A significant degree of independence is provided on this

' committee in that both the Operations Quality Assurance Supervisor and the Radiation Protection Engineer are full members o'f this committee and these individuals do not have any direct

- responsibility for plant operations.

, .The Independent Safety Engineering Group (ISEG) will consist of a staff of degreed engineers with training and experience in

, various engineering fields. While these individuals will be employees of Texas Utilities Generating Company, they will not be members of the-operating organization.

The Operations Review Committee (ORC) will provide the independ 4.3-and"ent uill meet review thefunction as required acceptance criteria by ANSI-N 18.7, Section of NUREG-75/087, Section 13.4. A majority of the members of this committee will be independent of the operating organization. At least one regular member of this.comnittee will not be an employee of Texas Utilities Generating Company. Other persons with specific expertise may be called upon from tirr.e to time to serve on this committee.

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QUOTE 5 TUGC0 should expand its studies on systems interaction and '

probabilistic assessment so that it will have a better understanding of the Comanche Peck nuclear systems.

COMMENT 5 The Comanche Peak staff is engaged in and will continue to expand its studies on systems interaction and probabilistic risk assessment.

QUOTE 6 Other issues have been identified as Outstanding Issues, License Conditions, and Confirmatory Issues in the Staff's Safety Evaluation report supplement dated October 1981. The ACRS is satisified with the progress on these topics and believes that they should be resolved in a manner satisfactory to the NRC Staff.

COMMENT 6 TUGC0 is working with the staff to resolve all the Outstanding Issues listed in the Comanche Peak Safety Evaluation Report. The resolutions are in large part contingent "pon completing several studies. We have no major disagreement with the staff that would hinder the resolution of any issue. References (1) and (2) provide the schedule for submission of information to close these items.

QUOTE 7 TUGC0 is evaluating potential methods of providing instrumentation for detection of inadequate core cooling as discussed in the ACRS letter to the Executive Director for Operations dated June 9,1981. The Committee believes that this equipment should not be installed until it is well established that the instruments will provide reliable information of significant value beyond that provided by the instrumentation which is already installed.

COMMENT 7 ,

TUGC0 agrees with this statement.

N In sumary, TUGC0 is pleased with this positive report by ACRS to the Commission on Comanche Peak. We are working diligently on the Committee's recommendations as discussed above.

Sincerely, R. . Gary RJG:grr r

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