ML20039D002
| ML20039D002 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/14/1981 |
| From: | Burwell S Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8112310202 | |
| Download: ML20039D002 (13) | |
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DEC14 N Docket Nos.:
50-445 and 50-446 APPLICANT:
Texas Utilities Generating Conpany FACILITY:
Comanche Peak Sten Electric Station, Units 1 and 2
SUBJECT:
SU3tARY OF MEETING ON TRANSFER OF CONTAIINENT SPRAY FROFi INJECTION TO RECIRCULATION tiODF Summary A meeting was held at NRC Headquarters, 7920 Norfolk Avenue, Bethesda, Maryland on Tuesday, Decenber 8, 1981. The purpose of the meeting was to discuss the applicant's response to the staff's concerns regarding the use of a manual initiation to transfer the contaimient spray system from the injection mode to the recirculation node as described in SER Section 6.5.2.
This matter is identified as outstanding issue (5) in Supplement No.1 to the SER, Section 1.7.
The basis for the staff's position on this matter was discussed. lhe applicant described a design change proposed in response to staff concerns. The staff specified the additional information needed to resolve the matter; i.e. this information would define the impact of the design change on each of the design
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objectives for the containment spray system.
An attendance list is given on Enclosure 1.
Copies of the slides used by the applicant in the meeting discussion are contained in Enclosure 2.
Meeting Details The discussion started with an effort to clarify the NRC's requirements or restrictions on the use of manual actions by the operator following an accident.
In the SER the staff stated that manual initiation of the switchover from injection to the recirculation mode does not guarantee continous operation for two hours. Since the SER was issued, the staff has adopted the practice of evaluating the transfer against the criteria given the draft standard ANS 58.8,
" Time Response Design Criteria for Safety-Related Operator Actions," Revision 2, dated fiarch 1981. This standard establishes a conservative time margin of 20 minutes between the first event alarm and the required operator action for Condition IV Events. The use and applicability of this draft standard was discussed in depth using the slides of Enclosure 2.
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The staff acknowledged that this draf t standard is a design standard that is not intended for backfit. thvertheless the staff considers it a useful guideline in evaluating the acceptability of applications for an operating license.
The applicant pointed out that the laroe break loss-of-coolant accident was the only event in which the systen did not fully satisfy the 20 minute guide-line, and this event is easily diaqnosed by the operator.
The applicant acknowledged that it was considering a design change to add orifice plates to the contairmant spray pump discharge line to reduce the flow rate, and thereby extend the tine before the operator nust take action to approximately 19-1/2 minutes. The applicant's studies indicate that this design cnange would satisfy all design objectives for the contain1ent spray systen.
The staff specified that it would need to see the results of analyses of two design basis large-break loss-of-coolant accidents before it could complete its evaluation of the proposed design change. These are as follows:
1.
Assume that the operator does not take any manual actions to reduce the water withdrawal from the RWST until the last second before the RNST is enpty, and at that point the operator nakes the required actions.
2.
Assuae that the operator does close one of th> 1 solation valves between the RtlST and the RHR pump suction (isolates one RHR train) in response to the alarn for this action.
Again at the last second before the RWST is empty the operator makes the required actions.
For both events, assuming the ECCS and containment spray system operate as described, specify:
1.
The time from the first accident alarm to the point the operator nakes the required actions.
2.
The inpact on the core cooling during the event.
3.
The impact on the containnent pressure during the ev ent.
4.
The impact on iodine fission product renoval and its consequential change in offsite accident doses; 0-2 hour and 0-30 day total s.
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The change in stap chemistry and pH of contaiment spray system.
6.
The impact, if any, on the ability to use the containment spray system to promote hydrogen mixing within the containment.
The applicant indicated it would give~ a schedule for responding to the above questions in the near future.
Original signea 57 Spot.ts. ood c:: r e11 Spottswood B. Burwell, Project Manager -
Licensing Branch No. 1 Division of Licensing cc w/ encl.:
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fir. R. J. Gary Executive Vice President and General Manager Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201
-cc: Nicholas S. Reynolds, Esq.
J. Marshall Gilmore Debevoise & Liberman.
1060 West Pipeline Road 1200 Seventeenth Street Hurst, Texas 76053 Washington, D. C.
20036 Resident Inspector / Comanche Peak Spencer C. Relyea, Esq.
Nuclear Power' Station Worsham, Forsythe & Sampels c/o U. S. Nuclear Regulatory 2001 Bryan Tower Commission Dallas, Texas 75201 P. O. Box 38 Glen Rose, Texas 76043 Mr. Homer C. Schmidt Manager - Nuclear Services Richard Fouke Texas Utilities Services, Inc.
Citizens for fair Utility Regulation 2001 Bryan Tower
_ 1668-B Carter Drive Dallas, Texas 75201 Arlington,-Texas 76010 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
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ENCLOSURE 1-MEETING ATTENDANCE Comanche Peak' Steam Electric Station, Units 1 and 2 NRC/NRR Staff Texas Utilities Services, Inc; S. B.'Burwell F. Madden T. R. Quay A. N. Dicesaro K.
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Dempsey De H Beckham g
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D. Popp J. J. McInerny E. C. Arnold.
.Gibbs & Hill
.G. Gisondo
- 0. K. Schaefer.
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ENCLOSURE 2 INTRODUCTION
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SER OPEN ITEM o
WHAT IS AN APPROPRIATE TIME FOR THE OPERATING CREW TO REALIGN CONTAINMENT SPRAY PUMP SUCTION TO THE CONTAINMENT SUMP FOLLOWING A LOCA
'o THIS OPEN ITEM FOCUSES ON OPERATOR ACTION TIME OPERATOR ACTION REQUIREMENT o
FOR COMANCHE PEAK THE STAFF IS EVALUATING OPERATOR ACTION TIMES BASED ON DRAFT ANS STANDARD 58.8 DATED MARCH 1981.
o THE LATEST VERSION OF DRAFT ANS 58.8 REQUIRES AUTOMATION OF ACTIONS kHICH MUST BE PERFORMED IN THE FIRST TkENTY (20)
MINUTES OF THE EVENT (STARTING WITH THE FIRST SIGNIFICANT ALARM).
O IT IS OUR UNDERSTANDING THAT PRIOR TO ISSUANCE OF THE LATEST DRAFT OF ANS 58.8 NO DEFINITIVE STAFF CRITERIA EXISTED FOR THE EVALUATION OF OPERATOR ACTION TIMES.
'THE 10 MINUTE RULE WAS COMMONLY USED OPERATOR ACTION TIMES AS HIGH AS 30 MINUTES HAVE BEEN USED IN VARIOUS ACCIDENT ANALYSES THE ACCEPTABILITY OF OPERATOR ACTION TIME ASSUMPTIONS HAVE GENERALLY BEEN EVALUATED BY THE STAFF ON A SPECIFIC PLANT BASIS Sheet 1 of 7
ANS 58.8 (MARCH, 1981 DRAFT)
TIME RESPONSE DESIGN CRITERIA FOR SAFETY-RELATED OPERATOR ACTION APPLICABILITY 0
THE STANDARD IS INTENDED TO APPLY TO FUTURE PLANT DESIGNS TO DETERMINE WHETHER A SAFETY-RELATED ACTION SHOULD BE AUTOMATED OR COULD BE PERFORMED BY THE OPERATOR (SEE FORWARD).
o THE STANDARD IS NOT INTENDED TO SERVE AS A BASIS FOR ACTUAL OPERATOR ACTION TIMES (SCOPE).
O THESE CRITERIA ARE INTENDED TO SERVE AS DESIGN BASIS FOR FUTURE PLANTS AND NOT FOR BACKFIT TO EXISTING, DESIGNED, IN l
CONSTRUC((}DN,OROPERATINGPLANTS(SECTION10.1).
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IN LIEU OF THE TIMES SPECIFIED IN THE STANDARD THE DESIGN MAY USE DATA FROM AN INDEPENDENT SOURCE (SECTION 10.2).
CONTENT l
o DEFINES TIME CRITERIA (TESTS) THAT THE DFSIGNER SHOULD USE IN DETERMINING IF A SAFETY RELATED ACTION SHOULD BE AUTOMATED.
o THE STANDARD ASSUMES THAT THE CONTROL ROOM AND INSTRUMENTATION IS ADEQUATELY DESIGNED, OPERATORS ARE QUALIFIED, PROCEDURES ARE USED, AND PLANT STAFFING IS ADEQUATE.
o THE TIME CRITERIA DEFINED FOR CONDITION IV EVENTS IS NO OPERATOR ACTION FOR 20 MINUTES g up:37:3 nur urunrg ogo uauronia7Tnu rn enupierg-DECUII.:D SAFEii nttATED ACTIONS 10930 Sheet 2 of 7
ANS 58.8 (CONT.)
_ STATUS o
DRAFT ANS 58.8 WAS BALLOTTED BY NUPPSCO IN MAY,1981 o
NUPPSCO APPROVED THE STANDARD WITH COMENT ALTHOUGH THERE WERE FF.GATIVE BALLOTS o
NUPPSCO DIRECTED THE ANS 58.8 WORKING GROUP TO MAKE THE FOLLOWING CHANGES IN THE STANDARD REDEFINE INITIATION POINT FOR TIME TEST i MODIFY SECTION 10 TO PERMIT THE USE OF ALTERNATE CRITERIA MODIFY SECTION 10 TO PERMIT MORE FLEXIBILITY IN APPLICATION OF THE STANDARD NRC POSITION (AT NUPPSCO MEETING) o NRC (GUY ARLOTTO) V0TED " APPROVED WITH COMMENT" o
INDICATED THERE WERE SIGNIFICANT NRC COMMENTS ON THE STANDARD o
NRC MANAGEMENT PREFERRED THE CURRENT STANDARD TO NO STANDARD AT ALL o
THE STANDARD WOULD PROVIDE MORE CONSISTENT STAFF REVIEW 0F OPERATOR ACTION ISSUES AND SERVE AS A GUIDELINE FOR STAFF REVIEWERS DURING LICENSING REVIEWS 10930 Sheet 3 of 7
OPERATOR ACTION DATA BASE o
THE DATA USED TO DEVELOP OPERATOR ACTION TIME CRITERIA FOR ANS 58.8 WAS BASED ON A CONSERVATIVE EVALUATION OF WESTINGHOUSE AND GENERAL PHYSIC DATA COLLECTED ON TRAINING SIMULATORS o
THE METHODS AND TECHNIQUES USED BY WESTINGHOUSE AND GENERAL PHYSICS WERE ESSENTIALLY THE SAME WESTINGHOUSE DATA o
DATA COLLECTION METHOD COLLECTED DATA DURING TRAINING SESSIONS ON ZION SIMULATOR RECORDED SIMULATOR STATUS CHANGES AND OPERATOR ACTIONS ON COMPUTER TAPE PROCESS TAPE TO EVALUATE OPERATOR PERFORMANCE o
OPERATORS LICENSED OPERATORS UNDERG0ING RETRAINING PHASE III TRAINEES OPERATOR'S FAMILIARITY WITH CONTROL BOARD VARIED
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Sheet 4 of 7 10930
OPERATOR ACTION DATA BASE (CONT.)
0 DATA COLLECT 70NJNVIRONENT DATA WAS GENERALLY COLLECTED PRIOR TO IMPLEMENTATION OF POST-TMI REQUIREENTS SIMULATED AS CLOSELY AS POSSIBLE. ACCIDENT CONDITIONS O
CONCLUSIONS FROM DATA OPERATORS DIAGN0' SED THE EVENT CORRECTLY RESPONDED QUICKLY TO THE TRANSIENT OPERATORS USED PROCEDURES OPERATORS DID MAKE MANIPULATIVE ERRORS i
ERRORS WERE INDEPENDENT OF TP1E 10930 Sheet 5 of 7
WESTINGHOUSE OPERATOR ACTION DATA ID NO.
REACTOR TRIP TO RCP TRIP REACTOR TRIP TO RESET SI 14 9
405 19 108 417 21 11 497 25 21 705 32 75 160 40 9
1216 42 50 721 46 48 575 48 22 542 51 10 582 52 25 453 53 44 265 54 227 0
57 50 247 59 19 537 61 50 944 64 34 213 65 12 104 68 106 449 74 15
_316 471.4 - MEAN 47.25 - MEAN 453 MEDIAN 25 MEDIAN i
10930 Sheet 6 of 7
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e APPLICABILITY TO COMANCHE PEAK o
THE DATA CONSERVATIVELY REPRESENTS THE PERFORMANCE OF OPERATORS ON A WESTINGHOUSE REACTOR WHICH IS SIMILAR TO COMANCHE PEAK o
ONE WOULD EXPECT COMANCHE PEAK OPERATORS TO PERFORM ADEQUATELY WITHIN THE GIVEN TIME CONSTRAINTS o
AT COMANCHE PEAK THE FOLLOWING OPERATOR AIDES WILL BE IMPLEMENTED IMPROVED TRAINING NEW EMERGENCY PROCEDURES SHIFT TECHNICAL ADVISOR TECHNICAL SUPPORT CENTER CONTROL ROOM EVALUATION IMPLEMENTATION OF REGULATORY GUIDE 1.97 o
BASED ON THE AB0VE IT IS CONCLUDED THAT THE CURRENT COMANCHE PEAK DESIGN PERMITS SUFFICIENT TIME FOR OPERATORS TO PERFORM REQUIRED ACTIONS DURING THE SWITCH 0VER PROCESS Sheet 7 of 7 10930
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MEETING
SUMMARY
DISTRIBUTION Oy@.!$M
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S. Pawlicki TIC /NSIC/ Tera V. Benaroya gO b$
Z. Rosztoczy H
LB#1 Reading W. Haass j8
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B. J. Youngblood P. Check A. Schwencer F. Congel F. Miraglia
- 0. Parr J. Miller F. Rosa G. Lainas W. Butler R. Vollmer W. Kreger J. P. Knight R. Houston l
R. Bosnak F. Schauer L. Rubenstein
- R. E. Jackson T. Speis Project Manager S. B. Burwell M. Srinivasan Attorney, OELD J. Stolz M. Rushbrook S. Hanauer 0IE (3)
W. Gammill ACRS (16)
T. Murley I
i F. Schroeder I
E. Adensam D. Skovholt M. Ernst
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Participants:
P. Baer C. Berlinger l
S. B. Burwell K. Kniel T. R. Quay G. Knighton K. C. Dempsey A. Thadani D. H. Beckham D. Tondi J, Kramer D, Vassallo P. Collins i
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Ziemann bec: Applicant & Service List 9
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