ML20083H571

Filing of New Contentions 169,170,171 & 172 Re Inadequate Safety Parameter Display Sys Design

ML20083H571
Person / Time
Site:	Harris
Issue date:	01/03/1984
From:	Eddleman W EDDLEMAN, W.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20083H553	List: ML20083H551 ML20083H571
References
82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8401090346
Download: ML20083H571 (2)

Text

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UNITED STATES OF AMERICA Jan 3, 1984

.n NUCLEAR REGULATORY COMMISSION i

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Glenn O. Bright Dr. James H. Carpenter -

James L. Kelley, Chairman In,.the Matter of J Docket 50 400 OL CAROLINA POWER AND LIGHT CO. et al. )

(Shearon Harris Nuclear Power Plant, )

Units i and 2) ) ASLBP No. 82-L68-01

) OL Wells Eddleman's new contentions re SPDS

Background:

On December 3,1983 I received CV&L's " Safety Analysis of the Shearon Harris Safety Parameter Display System"(SPDS). I do not

'take it to be the information the Board ordered CP&L to produce by mid-February on SPDS human factors. But it is new informat$on. For the first time I have some descriptive data on the SPDS that enables evaluation. Therefore, under the Board's order that such new info i

compiels contentions to be filed within 30 days of having the document in hand, I now (taking into account Jan 2 was a holiday) file:

Contention 169: The Harris SPDS design. fails to adeouately provide information needed for operating personnel to protect the

' health and safety of the nublic in an accident, because (A) the og SPDS logic does not indicate loss of quality signals for paraneters +

.noo until all signals are lost, and uses "1 out of 2 logic" (how can you

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O mg logically tell which one to use?) when only 2 signals are left, thus 4

00 not providing accurate information or early indication that instruments oO or signal lines may be failing. It also uses average values only, om

.3@e. failing to alert operators to possible widely divergent readings of the same variable.

See p.25 of " Safety Analysis" of sons,

~2-

& safety on:alysis ',

Contention 170: The Harris SPDS design is defective because it does not take sufficient account of overcooling, which can cause

. pipes to break in the nrimary cooling system (and could lead to prsssure vessel failure). PAge-29-of the SPDS " Safety Analysis" indicates the core cooling will remain GREEN (OK) on the display even tho- cocling exceeds 100 degrees F per hour (the pressure

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vessel s code limit). .This could lead to urimary systen broundary failure s 'followed by rele,ase of radiation to atmosnhere, e.g. by venting, bad seals.

Contention 171: The Harris SPDS design and safety analysis is defective because in the event of a large LOCA it does not provide

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accurate information to operators. For exannle, nage h5 of the SPDS " safety analysis" says that the RCS Integrity signal during a "'large LOCA" will be GREEN (OK) . In fact, a large LOCA is a huge leak in the reactor, cooling system -- not " integrity" at all.

It also assumes the control rods will be insertable after the LOCA

begins (p.45), ignoring possible warning, stean explosions, or CRDM (or CRDM controls or perw er supply) failures.

Contention 172: Due to dropped information signals not being signaled to the operators, and due to inaccurate setups,

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e.g. the failure of RCS integrity to signal other than OK during a large LOCA (SPDS " Safety Analys s" p.45), failure to take account

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of overcooling (p.29), and variation of signals, the setup for prioritizing onerator apetions (pp 26-27) may actually confuse operators or misdirect their attention during a nuclea* accident.

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The selected parameters hava not been fleshed out for Harris (e.g. overcooling, ibid pp1h-16) and may provide actual nisinfo"mation during an accident if set wrongly,'=e.g. for overcooling.

WHAT'S NEW : SPDS Safety Analysis and description therein of how it's planned towork. WHY COULDN'T FILE EARLIER: Basis in the

" Safety Analysis" cited above was not availnble. 5 factors: Good cause, 6oAP&

• I have info not technical available nal earlfer.ysis ility do cross & may get witnesses.

Odrffesn pursuing SPDS issue.

p Noakfier o

5 No real delay, safety hearing discovery only beginning now. Broaden issues 4_ not much, SPDS always been issue. No contentions no record.%5 4 Nd rmrd, ]