ML20206T467
| ML20206T467 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 06/05/1989 |
| From: | Hodges M Office of Nuclear Reactor Regulation |
| To: | Hebdon F Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20206S598 | List: |
| References | |
| FOIA-99-28 NUDOCS 9902110392 | |
| Download: ML20206T467 (8) | |
Text
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JUN 5 1989 4
MEMORANDUM FOR:
Fred Hebdon, Project Director Project Directorate IV Division of Reactor Projects - III, IV, Y and Special Projects FROM:
M. W. Hodges, Chief Reactor Systems Branch Division of Engineering & Systems Technology
SUBJECT:
EMERGENCY OPERATING PROCEDURES CONCERNS AT ARKANSAS NUCLEARONE(ANO) UNIT 1 g
k The Region 11 emergency operating procedures (EOPs) inspection program found g
N that there is a lack of suitable generic guidelines for plants equipped with B&W nuclear steam supply systems. The B&W Owners Group has developed a program to address this deficiency, but ANO is not participating. Rather, ANO is continuing to use part of an obsolete generic document that contains no
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guidelines and has many deficiencies. Thus we have a condition of insufficient, unapproved generic guidelines at ANO with no apparent program for resolution.
We believe this situation must be corrected promptly.
Enclosure I contains background information for your use. Enclosure 2 is a suggested letter to send to AND to expedite resolution of this issue.
I NS suggest we discuss this at your earliest convenience.
originai sened by thr
- Hodeus M. W. Hodges, Chief Reactor Systems Branch Division of Engineering & Systems Technology
Enclosures:
As stated l
DISTRIBUTION cc w/ enclosures:
Central F11es A. Thadani SRXB R/F C. Harbuck MWHodges C. Poslusny RJones S. Sun WLyon WLyon R/F i
Contact:
W. Lyon, SRXB Ext. 20891 9902110392 990203 PDR FOIA KELLY 99-28 PDR
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ENCLOSURE I EMERGENCY OPERATING PROCEDURES AT ARKANSAS NUCLEAR ONE (ANO) UNIT I THE GENERIC PICTURE i
Region II is inspecting emergency operating procedures (EOPs) at all plants
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i containing B&W nuclear steam supply systems (NSSSs). Gibson reported that the most significant deficiency disclosed in the inspections is the lack of suitablegenericguidelines(Ref1).
Identified problems include:
1.
B&W plant E0Ps have not received broad peer review, utility and vendor engineering analysis, and NRR in-depth assessment of the accident i
mitigation strategy.
2.
Utility technical personnel have trouble determining if proposed changes deviate from the mitigation philosophy and, if so, to what extent.
l 3.
Utility management finds it equally difficult to provide suitable
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controls.
4.
NRC inspectors cannot evaluate E0Ps unless they have a personal, detailed knowledge of potential B&W accidents.
5.
B&W plant E0P maintenance programs are weak.
6.
E0P quality is uniquely important because B&W facilities are vulnerable to operator error.
7.
Licensees assign a low priority to correcting E0Ps.
S 2
l Gibson recommended "... that NRR assign a priority to the review and approval of a detailed B&W accident mitigation strategy; either on a site-by-site basis or using a generic model." A complete strategy does not exist, and the first step is to develop such a strategy.
The B&W Owners Group (BWOG) is supporting a generic emergency procedures guidelines-(EPG) effort that should correct this weakness.
It has led to resolution of many old issues identified in the staff's original ATOG review (Refs5and6). Other issues remain, including:
1.
Steamingofsteamgenerators(SGs)withbrokentubes. Steaming increases release of radioactive material in some accidents, but appears to reduce the release in others. This is a sensitive issue due to potential planned exposure of the public. A carefully planned resolution is required.
2.
Loss of AC power.
10 CFR 50.63 addresses the minimum time a plant must survive and recovery following that time. We believe EPGs and E0Ps provide additional coverage.
3.
Treatment of containment. Coverage must be broadened as discussed in the original ATOG SER.
4.
Severe accident conditions. The NRC has not provided broad guidance, but our SER identified this as a long term item.
We recommend the ongoing generic approach because it is efficient and uses the knowledge of both B&W and the B&W NSSS owners. Therefore, we are working with the BWOG on this generic program. We do not have the resources to address a site-by-site approach.
THE' ARKANSAS NUCLEAR ONE (ANO) PICTURE We understand all B&W NSSS owners are supporting the BWOG program except ANO.
Callan.(Ref 2) reported that "... ANO had no NRC approved document to serve as a basis for development of the ANO specific guidelines."
ANO continues to i
3 use Part II of the obsolete ATOG (part of the old BWOG EFG), which contains no guidelines and has many deficiencies (Refs 3 - 6). Thus we have a condition of insufficient, unapproved generic guidelines at ANO. Additionally, there is no apparent program at ANO for resolution of previous staff concerns on AT0G nor does there appear to be a program for continuing to improve the guidelines.
We can better understand this condition if we examine historical development of the BWOG EPGs. The BWOG provided the Oconee Abnormal Transient Operating Guidelines (ATOG) as a " generic" EPG.
It consists of two parts:
Part I - A guideline containing the major operator actions Part II - Bases material Each licensee with a B&W NSSS agreed to use this version of ATOG as a basis for preparation of plant specific versions of EPGs. Therefore, we reviewed AT0G from the viewpoint of a generic basis document (Refs 5 and 6). Many open items were identified as a result of this review.
Many changes have occurred since our 1983 review. Data have been obtained, analyses performed, plant specific EPGs have been upgraded, and a new technical bases document, the TBD, has been prepared (Ref 7) to address the open issues. The TBD is being upgraded and a section equivalent to ATOG Part I is being added (Ref 8) as a response to the generic E0P inspection findings. Both the upgrade and the added section will address steam generator tube rupture (SGTR), an area of significant staff concern for B&W designed NSSSs.
The following status exists:
1.
All B&W plant licers-es except ANO - The upgraded TBD will be the generic bases document. ATOG will not be used.
2.
ANO - ATOG Part II is the official generic bases document.
Before April 1, 1989, ANO also used material from the TBD in upgrading plant specific E0P material. Neither ATOG nor the TBD represent AN0's status.
k 4
Strictly speaking, our 1983 SER applies to a document that is no longer in use except ostensibly at ANO.
In reality, it is no longer in use at ANO because:
1.
ANO has made many plant specific changes which are inconsistent with AT0G Part II 2.
ANO does not use ATOG Part I and Part II has never been considered a stand-alone document from which adequate procedures may be generated 3.
ANO never used certain sections of ATOG Part II.
Thus, the SER issues are unresolved, and many are still applicable to today's plant bases material. There appears to be no program for resolution at ANO, a situation that should be corrected.
REFERENCES 1.
A. F. Gibson, "B&W Plant E0P Inspection, Conclusion, and Recommendations,"
NRC Memorandum for J. W. Roe, Division of Licensee Performai:ce and Quality Evaluation, September 1, 1988.
2.
L. J. Callan, "NRC Inspection Report No. 50-313/88-17," Letter from NRC Director, Division of Reactor Projects, Region II to Arkansas Power &
Light Company, Docket No. 50-313, License No. DPR-51, July 25,1988.
3.
"AbnormalTransientOperatingGuidelines(ATOG)," Oconee Nuclear Station, Unit 3, Parts I and II, Babcock & Wilcox, Nuclear Power Generation Division, 74-1123297-00, March, 1982.
i 4.
D. A. Naptor, " Resolution of NRC Comments on Oconee ATOG," letter from B&W to BWOG Operator Support committee, 582.7108/T1.2, ESC-075, March *4, 1983.
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Y l4 5
5.
D. G. Eisenhut, " Safety Evaluation of ' Abnormal Transient Operating Guidelines'(GenericLetter83-31)," letter from NRC to all operating reactor licensees, applicants for an operating license, and. holders of construction permits for Babceck & Wilcox pressurized water reactors, September 19, 1983.
6.
Supplement to ATOG SER, December 1983.
7.
"The B&W Owners Group Operator Support Committee Emergency Operating Procedures Technical Bases Document," Babcock & Wilcox, Nuclear Power Division, 74-1152414-01, March 7, 1988.
8.
R. C. Jones, " Minutes of January 17-19 Meeting with B&W on the Technical Basis Document," Memorandum for M. W. Hodges, Reactor Systems Branch, Division of Engineering & Systems Technology, March 1, 1989.
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ENCLOSURE 2 SUGGESTED LETTER TO ANO 1
Mr. Gene Campbell Vice President, Nuclear Operations Arkansas Power & Light Company
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P. O. Box 551 Little Rock, Arkansas 72203
Dear Mr. Campbell:
i
SUBJECT:
EMERGENCY OPERATING PROCEDURES GUIDELINES i
Reference:
L. J. Callan, "NRC Inspection Report No. 50-313/88-17," Letter l
from NRC Director, Division of Reactor Projects, Regicn II to Arkansas Power & Light Company, Docket No. 50-313, License No.
DPR-51, July 25, 1988.
\\
The NRC is inspecting emergency operating procedures (EOPs) at all plants j
containing B&W nuclear steam supply systems (NSSSs). The most significant deficiency found is the lack of suitable generic guidelines.
The B&W Owners Group (BWOG) is supporting a generic emergency procedures guidelines (EPG) effort that should correct this weakness. We recommend this generic approach because it is efficient and uses the knowledge of both B&W and the B&W NSSS owners.
It has led to resolution of many of the old open issues that remain from the ATOG review. We originally understood all B&W NSSS owners would use the results of the BWOG program. Now we understand ANO is not participating in the program and may not use the results.
Our inspection report of your facility (see reference) stated that "...
ANO had no NRC approved document to serve as a bases for development of the 1-
Lk Gene Campbell l ANO specific guidelines."
We understand you are continuing to 'use the Oconee ATOG Part II as the licensing basis for your plant-specific EPGs. However:
1.
ANO has made many plant specific changes which are inconsistent with ATOG i
Part II.
l l
2.
ANO does not use ATOG Part I and Part II is not a stand-alone, staff-approved generic document from which procedures may be generated consistent with TMI action item I.C.I.
Part II contains no operator guidelines. Further, most of the outstanding issues from Part I pertain to the bases for the EPGs, and a user of Part II will have to address each of these issues.
l 3.
ANO never used certain sections of ATOG.Part II.
i If your plans are to use the BWOG program results and the program resolution that we believe will result, then please inform us of this immediately.
Otherwise, please arrange to meet with us on at our White Flint Building in Rockville, Maryland to discuss this potential safety concern. You should be prepared to address (1) your program for issue resolution and, (2) your program for adequate saintenance of your EPGs and E0Ps, if such a meeting is held.
I Fred Hebdon, Project Director Project Directorate IV l
Division of Reactor Projects - III, IV, Y and Special Projects Office of Nuclear Reactor Regulation 2
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