ML20126M825

Advises That Interim Review of Westinghouse Owners Group Submittal for Action Plan Item I.C.1, Guidance for Evaluation & Development of Procedures for Transients & Accidents, Is Complete.Dg Eisenhut Encl

ML20126M825
Person / Time
Site:	Marble Hill
Issue date:	06/16/1981
From:	Youngblood B Office of Nuclear Reactor Regulation
To:	Shields S PUBLIC SERVICE CO. OF COLORADO
References
TASK-1.C.1, TASK-TM NUDOCS 8106220279
Download: ML20126M825 (3)

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DEisenhut TERA BJYoungblood NRC/PDR KKiper L/PDR MRushbrook NSIC Docket Mcs. :.SIL 50-54 RLTedesco TIC and STN 50-547 RVollmer ACRS (16)

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RMattson Mr. S. W. Shields RHartfield, MP -V Senior Vice President WJohnston E

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Dear Mr. Shields:

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Subject:

Staff Evaluation of Iten I.C.1 for Westinghcuse Facilities

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1 We have corpleted our. interim review of the Westinghouse Owners Group subrittal for Action Plan item I.C.1, Guidance for the Evaluation and Developrent of Procedures for Transients and Accidents. A copy of Mr. Eisenbut's l'ay 28, 1981 letter to Mr. Jurcensen, Chairman, Westing-house Owners Group is enclosed for ycur infor-ation. As indicated in the enclosure, further work will be necessary in order to produce a cocument which satisfies the staff positions in a tinely matter.

Sincerely, Original signed by:

3. J. Yourablood B. J. Youngblood, Chief Licensing Branch No.1 Division of Licensing

Enclosure:

As stated cc: See next page J

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l Mr. S. W. Shields Senior Vice President Nuclear Division P. O. Box 190 New Washington, Indiana 47162 ces:

Michael J. Walro, Esq.

Charles W. Campbell, Esq.

Vice President and General Counsel Attorney for the Planning Board and Public Service of Indiana the Board of Zoning Appeals of 1000 E. Main Street Jefferson County Plainfield, Indiana 46168 427 East Main Street Madison, Indiana 47250 Mr. William Xortier Mr. Robert C. Slover Atomic Power Distribution Westinghouse Electric Corporation Save the Valley, Inc.

P. O. Box 813 P. O. Box 355 Pittsburgh, Pennsylvania 15230 Madison, Indiana 47250 Walker C. Cunningham, Jr., Esc.

Mr. P. L. Wattelet 1129 fontucky Home Life Building Sargent & Lundy Engineers Office of the Jefferson County Attorney 55 East Monroe Street Chicago, Illinois 60603 Louisville, Kentucky 40202 David K. Martin, Esq.

Harry H. Voigt, Esq.

LeBoeuf, Lamb, Leiby & MacRae Assistant Attorney Generals 1333 New Hamoshire Avenue, N. W.

Room 34, State Capitol Washington, D. C, 20036 Frankfort, Kentucky 40601 Donald J. Ridings, Esq.

George A. Leininger, Jr., Esq.

City Attorney, City of Madison Attorney for Jefferson County 610 Old Louisville Trust Building P. O. Box 326 Madison, Indiana 47250 Louisville, Kentucky 40202 Bill V. Seiller, Esq.

Mr. Robert Gray Ewen, MacKensie and Peden Rural Route #1 2100 Ccamonwealth Building Hanover, Indiana 47243 Louisville, Kentucky 40202 J. Bruce Miller, Esq.

Ms. Marie Horine, President Jefferson County Attorney Save Marble Hill 1129 Kentucky Home Life Building Rural Route #2 Louisville, Kentucky 40202 Lexington, Indiana 47138 Ted R. Todd, Esq.

Mrs. David G. Frey Attorney for the Board of Commissoners of the County Solar Energy Committee, SAS 2625 S. Smith Road of Jefferson, Indiana Sloomington, Indiana 47401 427 East Main Stree:

Madison, Indiana 47250 Mr. Ralph C. Pickard Indiana State Board of Health Thomas M. Dattilo, Esq.

1330 West Michigan Street Metford & Dattilo Indianapolis, Indiana 45205 311 East Main Street Madison, Indiana 07250 Mr. Donald L. Cox Assistant Director of Law Joesph B. Helm, Esq.

Brown, Todd & Heyburn City of Louisville Sixteenth Floor 200 City Hall Louisville, Kentucky 40202 Citizens Plaza Louisville, Kentucky 40202

1. ' John A. Eyed, President Sassafras Audobon Society 10 0' Clock Ridge Road Nashville, Indiana 47488 U. S. Nuclear Regulatory Commission Resident Inspectors Office 3738 Marble Hill Road Nabb, Indiana 47147 Mr. E. P. Martin General Manager Wabash Valley Power Association P. O. Box 24700 Indianapolis, Indiana 46224 e

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MA't 2 8 1981

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Robert W. Jurgensen, Chairman Westinghouse Owners Group American Electric Power Service Corpora tion 2 Broadway New York, tiew York -10004

Dear Mr.'Jurgensen:

In your letter dated March 18,1981.(06-54), you summarized a meeting held on February-20,19S1 between representatives of the NRC staff, i

The purposa Westinghouse Owners, and Westinghouse Electric Corporation.

. of the meeting.was.to. discuss the Westinghouse Owners Group (WOG) activities in response to NUREG-0737, Clarification of TMI Action 3

Plan Recuirements, Item I.C.1, Guidance for the Evaluation and Develoo-Following the meeting ment of Procedures for Transients and Accidents.

summary, you requested that tne staff ackncwledge the acceptability of the _ program described in the meeting.

As -indicated in a meeting with Tom Anderson, of Westinghouse, on April 8, 1981, we have concerns about the acceptability of the WOGThe Inadecuate Core Cooling Guidelines, recuired the operator'to diagnose program.

a specific event using the diagnostic procedure included in the guide-Subsecuent failures were, essentially, addressed by entry into As indicated in the lines.

one of the inadecuate core cooling guidelines.

February meeting and discussed in your letter, the guidelines do not provide smooth transitions from the event procedures to direct theThis operator if subsecuent multiple or.consecuential f ailures occu

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Furthermore, the Inadequate Core Cooling Guidelines are reached.

guidelines do not address suosecuent reevaluation of plant conditions to ensure that the expected plant res,conse is occurring.

Our second concern is your proposed schedule for completing the program recognizing that development of emergency operating procedures is aHowev dynamic process with no aosolute end point.that continual, major r

. burden on plant operating staffs and confusing to the operators who In the February meeting, WOG representa-must relearn tne procedures.

tives indicated thay they expect to have the initial development phase of the guidelines completed in July 1981, and would not exoect major changes to the guidelines to result f rcm the chases to be ccmoleted in You also state in your letter that the January 1982 and July 1982.

Haever, initial ' phase will address over 98 percent of the total risk.

we were also told in tne meeting that the guidelines to be submitted in July would probably not differ greatly from those already sucmitted.

Considering our concerns with the existing guidelines, as addressed aoove, we do not see hcw the July submittal can be resconsive to We believe that NUREG-0737, Item I.C.1 without significant change.

additional work is necessary.

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!/.f.Y 2 9 1931 The staff nas not completed its review of WCAP 9691 or the probability estimates presented in the February meeting, and the Owners Group has not addressed the broad range of initiating events, including natural cher,3mena such as earthquakes, in the analysis presented to date.

Therefore, we.cannot assess the overall adequacy of the proposed program.

Unless our concerns, as stated herein, are satisfied, the ability of licensees to meet the. schedule for revising their procedures may De ccmoromised.

As indicated in the April 8,1981 meeting, we have serious doubts that the full range of initiating events and subsecuent failures can be addressed within the event specific framework adooted by the Westing-nouse Owners Group.

If your additional work to date provides. more insight into resolution of these concerns, we would be available to meet witn you at your convenience.

By copy of this letter, each licensee and applicant of a Westingnouse-type plant, is being advised of our evaluation of your submittal.

Sincerely,

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E B )A h(Eisenhut, Director. SM

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Darrell G.

Division of Licensing cc:

E. Murphy W Licensees 5 Applicants l

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