ML20063C553

Compares Format & Positions of Facilities for Integrity Plant Safety Assessments Per SEP Objectives.Wind & Tornado Loadings Need Improvement.Pipe Break Outside Containment Requires Clarification

ML20063C553
Person / Time
Site:	Ginna
Issue date:	06/14/1982
From:	Bush S Battelle Memorial Institute, PACIFIC NORTHWEST NATION
To:	Russell W Office of Nuclear Reactor Regulation
Shared Package
ML17256B100	List: ML17256B101 ML20063C553 ML20063C569
References
RTR-NUREG-0821, RTR-NUREG-821 NUDOCS 8206220267
Download: ML20063C553 (3)

Text

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1 OBaffelle Pacific Northwest Laboratories P.O. Som 999 Richland, Washinpon U.S.A. 99352 Telephone (509)

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June 14,J982 re;e, 33.:sn Mr. William T. Russell, Chief Systematic Evaluation Program Branch Mail Stop 516 U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Integrity Plant Safety Assessment - Systematic Evaluation Program -

R. E. Ginna Nuclear Power Plant I have attempted to apply the benchmarks and criteria used in the Palisades review within the. scope of the five S.E.P. objectives established by the Task Force.

Not too surprisingly there are. strong similarities in format, positions and specifics of. the writeup between Ginna and Palisadas. My initial reaction was that Ginna was judged more severely; however, I could not confirm this on fur-ther review and comparison of the two documents.

Ooeratino Historv -

I have been somewhat familiar with Ginna's operating history so I should not have been surprised with the general tenor of Appendix F relevant to opera-tion. Even to I was impressed with the overall record and rapid rate with which issues were corrected. I examined the aopendix in the context of safety-related issues and felt their record was very good. The remainder of the

appendices tend to be housekeeping items to complete the record and I feel do ,,

not warrant comment.

Format and Positions I will cite a few problems. met with. ,

. The modified fonnat of Secfion 3.1 was somewhat. confusing. It took a while for me to relate the asterisked items to Table 3.2 of the Palisades report covering resolved issues. .

e Palisade has issue VI.7.A.2 as not applicable to PWR's while Ginna addresses it.

• In some issues it was difficult to determine the safety significance from .

the words, an example is 4.7.3.

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Mr. William T. Russell, Chief June 14, 1982 C4Battelle Page 2 .

. Page 4.9, item 4.12.3, line 3--the word should be except not accept. .

e In Section 4, the policy was inconsistent in the handling of issues cited in Appendix 0 of the PRA review. In some instances there was no acknowl-

.edgment of the PRA study; in others it was cited and accepted. Finally, there were cases of citation and rejection. I have no problems with docu-mented acceptance or rejection. I do feel the Appendix 0 coverage of the issues should be recognized.

Soecific Conclusions Significant items appear in the Summary and in Sections 3.3 and 4.. I confess, I felt that the safety significance of the various issues varied a great deal.

Some I would class as trivial. Others obviously can have a major impact on plant safety.

I consider the following items to be significant to safety and generally con-cur with the staff approach. Others I am rather cool to but understand the- '

need for a consistent approach (e.g., project flood).

e Wind and tornado loadings Tepresent an area needing improvement. I include protection against missiles in this category.

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. Pipe break outside containment requires clarification. The level of-effort required is subject to some debate. .

I feel your position on containment isolation is realistic and should have little or no impact on safety margins.

An area that surf aced and may need further review is the relative safety impacts remaining at not standby versus continuing down to cold standby. I feel the critical phases are in getting to hot standby so the attention should be directed there. --

My final comment relates to many of the items in Section 4. They clear the record and get the plant in closer compliance to current criteria. I am not sure how much some of them contribute to absolute safety.

The status of TMI and USI items Sresumably will be consistent and be picked up in a supplement. This problem occurred in Palisades.

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General .-

Because of similarities in format and lead in phrases it was much easier to go through Ginna than Palisades. Presumably future plants will be even easier.

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Spencer Senior Staff H. ConsuBush { ltant 1

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