ML20041B055
| ML20041B055 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 02/09/1982 |
| From: | Dale L MISSISSIPPI POWER & LIGHT CO. |
| To: | Beltracchi L Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0835, RTR-NUREG-835 AECM-82-50, NUDOCS 8202230216 | |
| Download: ML20041B055 (2) | |
Text
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e MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi P. O. B O X 164 0. J A C K S O N MIS SIS SIP PI 3 9 2 05 Y
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Attention:
Mr. Leo Beltracchi
Dear Mr. Beltracchi:
SUBJECT:
Grand Gulf Nuclear Station Units 1 and 2 Docket Nos. 50-416 and 50-417 File 0260/J-200.0 Comments on NUREG-0835 AECM-82/50 Enclosed are Mississippi Power & Light's comments en " Human Factors Acceptance Criteria for the Safety Parameter Display System," NUREG-0835, Draft Report for comment.
Yours Truly, I
I g L. F. Dale Manager of Nuclear Services PJR/JDR:ph Attachment cc:
Mr. N. L. Stampley Mr. R. B. McGehee Mr. T. B. Conner Mr. C. B. Taylor Mr. Richard C. DeYoung, Director Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Washington, D. C.
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O202230216 820207 PDR NUREG Om35 C PDR Member Middle South Utilities System
o Attachment to AECM-82/50 COMMENTS ON NUREG-0835 Section 4.7.2 Technical Specifications (TS) should not be required for operator compensatory measures for loss of the Safety Parameter Display System (SPDS). The 0.01 unavailability design goal as requested by NUREG-0696 assumes that the SPDS is normally functional. The SPDS is not required for safe shutdown and is not required in the Emergency Operating Procedures (EOPs), but is merely an operator aid to more logically determine plant status. This position is even more strongly substantiated due to the additional requirements for safety related post accident instrumentation for those parameters that are Category 1 or Category 2 in accordance with Reg. Guide 1.97.
MP&L recognizes that this is presently required by NUREG-0696 also.
Section 4.9.2 The requirement in both this NUREG and NUREG-0696 for a and 4.9.3 seismically qualified SPDS is unfounded. As indicated in our position to 4.7.2 the SPDS is only an operator aid and therefore does not need to be seismically qualified. Loss of the SPDS either from a seismic event or for any other reason should not jeopardize the ability of the operator to perform the emergency functions needed to safely shutdown the plant.
The SPDS will serve as a useful tool for operator action, but it should be recognized that too much dependence on the SPDS by the operator may develop a negative effect on emergency operations by making it a first line of accident event recognition.
This requirement should be removed.
Section 5.0 Final verification and Validation of the SPDS should be performed af ter the SPDS is fully operational (based on the implementation date of NUREG-0696). The scheduling of verification and validation has not been established by this NUREG or NUREG-0696. NSAC-39 on " Verification and Validation for the SPDS" provides a useful program on performing this review.
General The design criteria and unavailability requirements should only apply to the SPDS in the control room. The SPDSs in the TSC and the EOF should be identical in format but need not meet the same design criteria or the 0.01 unavailability goals.
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