ML20212N469

Forwards Draft B&W Design Reassessment Program, for Review & Comments by 860829.Revised Schedule for Completion of Program Discussed

ML20212N469
Person / Time
Issue date:	08/21/1986
From:	Crutchfield D Office of Nuclear Reactor Regulation
To:	Tucker H BABCOCK & WILCOX OPERATING PLANTS OWNERS GROUP, DUKE POWER CO.
References
NUDOCS 8608280244
Download: ML20212N469 (29)

Text

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, Mr. Hal Tucker, Chainnan Babcock and Wilcox Owners Group Duke Powar Company Post Office Ecx 33169.

Charlotte, North Carolina 26242

Dear Mr. Tucker:

SULJECT: B&W DESIGN REASSESSMENT Ir. my letter of March 13, 1986, I forwarded a copy of the staff's plan for the reassessment of the B&W plant design. On May 15, the B&W Owners Group (BWOG) submitted a description of its program, now entitled the Safety and Performance Improvement (SPI) Program, for leading the reassessment effort. Based upon your program description, the staff is preparing a revised plan which integrates the Bh0G efforts into the overall reassessment program.

Enclosed is a copy of the draft integrated plan. Please review the enclosed plan to ensure that it properly reflects the BWOG activities and schedule. In order to incorporate your comments into the final reassessment plan, your in-put is needed by August 29.

As a result of the current BWOG schedule, as given in the July 24 status report l on the SPI Program, the staff has concluded : hat it will not be able to complete the B&W design reassessment program in 1986. In order to allow the staff to fully integrate and review the BWOG activities, a projected completion date of June, 1987 has been established. The initial SER will be issued in December, 1986 with supplements issued thereafter. The staff expects the BkOG to provide sufficient resources and management oversight to ensure that the currently pro-jected schedules are met.

Original si6ned by Dennis M. Crutchfield Dennis M. Crutchfield, Assistant Director Division of PWR Licer. sing-B

Enclosure:

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UNITED STATES

8. NUCLEAR REGULATORY COMMISSION

, & WASHINGTON, D. C. 20686

% August 21, 1986 Mr. Hal Tucker, Chaiman Babcock and Wilcox Owners Group Duke Power Company Post Office Box 33189 Charlotte, North Carolina 28242

SUBJECT:

B&W DESIGN REASSESSMENT l

In my letter of March 13, 1986 I forwarded a copy of the staff's plan for the l reassessment of the B&W plant design. On.May 15, the B&W Owners Group (BWOG) submitted a description of its program, now entitled the Safety and Perfomance Improvement (SPI) Program, for leading the reassessment effort. Based upon your program description, the staff is preparing a revised plan which integrates the

.BWOG efforts into the overall reassessment program. l Enclosed is a copy of the draft integrated plan. Please review the enclosed i plan to ensure that it properly reflects the BWOG activities and schedule. In '

order to incorporate your connents into the final reassessment plan, your in-put is needed by August 29. - -

As a result of the current BWOG schedule, as given in the July 24 status report en the SPI Program, the staff has concluded that it will'not be able to complete the B&W design reassessment program in 1986. In order.to allow the staff to

, fully integrate and review the BWOG activities, a projected completion date of June, 1987 has been established. The iiiitial SER will be issued in December, 1986 with supplements issued thereafter., The staff expects the BWOG to provide sufficient resources and management oversight to ensure that the currently pro-jected schedules are met.

t Denn s . Crutchfield, Assi ant M rector Division of PWR Licensing-

Enclosure:

As stated cc: G. Skillman (GPU J. Taylor (B&W) )

F. Miraglia

DRAF" B&W DESIGN REASSESSMENT PROGRAM

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1.0 INTR 0 DUCTION Since the TMI-2 accident, there has been a growing realization of the sensitivity of Babcock and kilcox (B&W) plants to operational transients.

By letter dated January 24,1986, the ED0 infomed the Chairman of the Babcock and Wilcox Owners Group (BWOG) that a number of recent events at B&W designed reactors lead the staff to conclude that there is a need to reexamine the basic design requirements for B&W reactors. The staff sub-i sequently developed a plan for performing the reexamination and forwarded  ;

l a copy to the BWOG on March 13. '

l The BWOG committed, in a letter dated February 13, 1986, to take the lead in a planned effort to define concerns relative to reducing the  ;

frequency of reactor trips and the complexity of post-trip response in B&W plants. The BWOG effort was initially entitled the Trip Reduction and Transient Response Improvement Program (STOP-TRIP); it is currently entitled the Safety and Perfomance Improvement (SPI) Program. A des-cription of this program was submitted on May 15, 1986.

This Task Action Plan outlines the scope of work necessary to accomplish the reassessment of B&W plants. NRR has been assigned the responsibility to l

provide overall direction of this effort with support from the Regions and j all appropriate NRC offices.

In light of the BWOG commitment to take the lead for this program, the reassessment plan has been updated to integrate the BWOG efforts under

4 the SPI Program into the staff's overall reassessment program. It is recognized that the BWOG program is to be a continuing, long-term project aimed at improving the operational performance of the B&W plants. Thus, in developing this integrated Task Action Plan, only those projects of the SPI Program which are currently defined have been included.

The staff was initially directed to complete the reassessment of the B&W design by the end of 1986. In order to fully integrate the results of the BWOG SPI Program into the staff's overall safety review, the reassessment is now scheduled to be complete in June, 1987.

2.0 OBJECTIVE The overall objective of the NRC staff generic evaluation of B&W plants is to reassess the basic design requirements and operational character-istics of the B&W nuclear reactors. Also, the study will compare the overall safety of the B&W reactors to other PWRs. The need for potential improvements to improve the performance of B&W nuclear t eactors will be studied. -

3.0 DISCUSSION To achieve the objectives discussed above, this Task Action Plan was  !

l developed by the staff. The plan is based upon a multi-faceted approach, l by the BWOG and the NRC staff, which will include review of operational

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, n transients which have occurred on B&W plants; feedback from operational and maintenance personnel along with the views of Regional personnel and Resident Inspectors; deterministic assessments; probabilistic assessments, and computer simulations. The findings from these tasks will be integrated to identify potential improvements to reduce the frequency of complex post-trip response to anticipated operational transients, and thereby improve the overall safety

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of B&W reactors, and to identify potential revised regulatory criteria for these reactors. D. Crutchfield, Assistant Director, Division of PWR Licensing-B, NRR, has been designated the senior staff manager responsible for this program. G. R. Skillman, GPU Nuclear, is the Chairman of the BWOG SPI Program. Table 1 lists the Regional and other NRC Office contacts.

Figure 1 shows the major tasks, and interfaces between tasks.

An overview of the specific tasks is provided in the following paragraphs.

The study and required information will be based upon the following B&W designed plants for which the following utilities hold operating licenses:

Arkansas Nuclear One, Unit 1 (ANO-1) - (Arkansas Power & Light Company)

Crystal River, Unit 3 - (Florida Power Corporation)

Davis Besse, Unit 1 - (Toledo Edison Company)

Ocenee, Units 1,2and3--(DukePowerCompany)

Rancho Seco, Unit 1 - (Sacramento Municipal Utility District)

Three Mile Island, Unit 1 - (Metropolitan Edison Company)

A safety evaluation report, to be issued as a NUREG document,'ill w be prepared documenting the results of the staff's reassessments.

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4.0 TASK DESCRIPTIONS i

In the subsequent sections, brief descriptions of the various tasks necessary to perform the B&W design reassessment are provided. For each task, the responsible organization, e.g. BWOG, PWR-B Branch, PWR-B PD, etc., is identified.

4 4.1 INFORMATION GATHERING The objective of this task is to gather and review infonnation from various sources. The results of these reviews will be used to identify problem areas, complications during events, root causes and sensitive systems.

Additionally, the review should also identify any human factors problems, including operator errors, procedural deficiencies and control room in-adequacies. Issues identified during these reviews will be integrated and prioritized in Task 4.2.

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4.1.1 OPERATING EXPERIENCE REVIEWS (BWOG, PEICSB, RSB, F08, EB)

Operating experience forms a major source of data for understanding per- l formance problems which have occurred in B&W designed reactors. This activity consists of the re-review of past B&W operational occurrences.

The intent of this effort is to look at these events as a set of oper-ational experiences that may indicate common problems, deficiencies, and/or i system weaknesses. The review should include the applicable License Event

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Reports (LERs) Inspection and Enforcement (IE) Bulletins, Circulars and i

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4 Notices, INP0 reports, EPRI/NSAC reports, AE0D reports, and BWOG Transient Assessment Program (TAP) reports. Reviews of events beginning with the March 20, 1978 Rancho Seco " light bulb" event should be included. This review is to be performed by the BWOG. Details on their effort is provided in their May 15 submittal.

With respect to the TAP reports, th~e BWOG considers these reports to be "the single best data source available on B&W plant trips and transients." The data is being used by the BWOG to classify transients and determine components, systems and procedures which contribute most to trips and transients. The purpose of the classification is to define the most significant events from the standpoint of the complexity of post-trip response, and to review these events first. At this time, the BWOG has identified 10 Category "C" events and 35 significant Category "B" events. Details on the BWOG class-ification scheme and the use of the TAP reports is provided in Section VI of the May 15, 1986 submittal.

The staff will audit the UWOG efforts by performing a limited, independent review of B&W plant operating experience. A detailed review of the TAP reports for all Category "C" events will be performed; a more limited j review will be performed for the other TAP reports. Previous NUREGs, e.g.

NUREG-0667,-Il54,-1195, on B&W operating events will also be reviewed by j l

the staff.

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4.1.2 INTERVIEWS (BWOG)

The BWOG will perform interviews of maintenance and operations personnel at all B&W plants. The objectives of the interviews are to: (1)look for transients which may not have resulted in reactor trips but were sig-nificant, (2) look for areas where improvements could reduce the need for post-trip cperator actions, and (3) identify and define concerns in pro-

cedures, maintenance and human factors areas.

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l 4.1.3 REGIONAL OPERATIONS EXPERIENCE FEEDBACK i

(REGIONAL / PERSONNEL RESIDENT INSPECTORS /TA for AD) l This task is aimed at utilizing the experience, judgements and concerns coming from the NRC's Regional staff, particularly the Resident Inspectors.  !

These individuals have extensive first-hand knowledge of B&W reactor operations, procedures and design-related deficiencies that must weigh in the NRC's overall evaluation of the adequacy of the B&W plants.

i The views of present and former Senior Resident Inspectors having experience at B&W reactors should be especially sought. Also, the I&E training staff should be involved in this effort since their hands-on experience is in-valuable.

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4 4.1.4 STATUS OF UTILITIES COMPLIANCE TO NRC ACTIONS (PD# 6)

As a result of' previous B&W operational transients, the NRC has issued various reconnendations to improve the overall safety of B&W plants.

~The objectives of this task are to: (1) compile the results of previous reviews of B&W operational occurrences, and (2) sunnarize the status of the implementation of modifications #at each B&W plant resulting from the requirements developed during the previous reviews. Of specific interest will be the identification of previous staff actions, not yet implemented, which could have had significant impact ca actual plant response.

i' 4.2 INTEGRATION OF ISSUES /PRIORITIZATION OF CONCERNS (BWOG, ALL PWR-B BRANCHES)

As a result of the infonnation gathering tasks, a list of issues and 4

concerns, will have been developed. Areas needing improvement which are defined by the staff will be forwarded to the BWOG for consolidation into

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their program. It is expected that the staff's concerns will be incor-porated into the appropriate projects of the SPI Program. The staff will monitor the BWOG efforts to assure the identified concerns are addressed.

From the BWOG information gathering efforts, the BWOG will fortailate defined concerns upon which specific work activities can be assigned. Based upon these concerns, the BWOG will categorize, prioritize and assign resources to address these concerns. The prioritization procedure to be utilized, along with the results, will be submitted for staff review.

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9 4.3 EVALUATION OF BWOG ACTIVITIES As a result of the information gathering phase, and the categorization and prioritization of concerns, specific projects will be identified by the BWOG. The current SPI Program identifies several work projects already underway by the BWOG; additional projects are expected to be de-veloped during the continued implemehtation of the SPI Program plan.

The subtasks described below incorporate those SPI Program activities which are currently defined.

In developing the subtasks below, the various BWOG projects underway have been consolidated into functional areas. In this manner, the staff can perform an integrated assessment of the BWOG activities as well as assessing .

the adequacy of the actions recommended to address the prioritized concerns from Task 4.2. In addition, by performing an integrated examination, the staff -

will be able to address the need for potential revised regulatory criteria for the B&W plants.

4.3.1 HUMAN FACTORS (F0B)

The BWOG has several activities related to the human factors area. These activities include the BWOG responses to the December 26, 1985 Rancho Seco event, human factors concerns raised by the re/iew of operating experience, interviews of operator / maintenance personnel and the procedures review.

The specific activities planned in these areas are discussed in the May 15, 1986 submittal. However, the specific integration of these tasks by the BWOG has not yet been fully explained.

9-The staff will review the BWOG activities. Of interest, will be the scope, i.e., have previously identified problems been resolved, and integration of the BWOG activities. The staff will perform a comparison of operator (emergency) actions required for B&W plants relative to plants of other PWR vendors to assess whether the demands on operators at B&W plants are greater. This information will the'n be used to determine whether the demands on B&W operators are reasonable given the quality of the operating environment (i.e., control room layout, procedures, training, etc.). In this manner, the staff will be able to independently judge whether the burden placed on operators at B&W plants is excessive.

4.3.2 PRA REVIEWS (BWOG, F0B)

The BWOG Risk Assesstaent Review project is described in Section VIII of the May 15, 1986 submittal. The objectives of that program are to:

(1) Determine if B&W plant transient event history is properly reflected in the plant PRAs.

(2) Assess the risk significance of the category "C" transient by comparison to other sequences leading to core melt.

The BWOG Risk Assessment Review will be accomplished using the Oconee and Crystal River 3 PRAs. General conclusions will be drawn for other B&W

- 10 plants by evaluating the differences in dominant accident sequences and system importances between the Oconee and Crystal River 3 PRAs.

The staff is initiating work at this time in order to be able to review the results of the BWOG project which is currently scheduled for completion in April of 1987. Specifically, the staff will, through a technical assistance contract with Brookhaven National L5boratory, perform the following:

(1) Review existing PRAs for B&W plants to assure that operating experience is properly reflected into the PRAs.

(2) Modify plant PRAs, to the extent feasible, to attempt to reflect the impact of operational experience on the PRA results. '

(3) Compare PRA insights for B&W plants to those for other PWRs.

(4) Evaluate the overall safety of B&W plants to that of other PWRs.

(5) Define potential risk beneficial items.

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4.3.3 SYSTEMS /0PERATIONALIssues(BWOG,RSBl In order to examine the sensitivity of B&W ' plants to operational occur-rences, the BWOG has contracted with MPR Associates to perform an inde-pendent comparison of the response of different PWR designs to operational transients. The BWOG expects the study to result in a comparison of the key response characteristics between B&W plants and other PWR designs along with reccommendations for possible enhancements to B&W plants to reduce sensitivity to operational transients. Details of the BWOG program is provided in Section V of the May 15, 1986 submittal. 1 The staff will review the BWOG efforts. It is anticipated that part of the review will include audit calculations. The staff will also ensure that the performance of " sensitive systems," i.e., those systems identified by the review of operating experience on the PRA review as important to miti-gating transients or complicating post-trip behavior, are specifically examined by the MPR study. In addition, the staff will review plant FSAR ,

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analyses, for both B&W plants and other PWRs, and existing thermal hydraulic l

analyses to identify causes for differences in plant response and to assess the safety significance of these differences. The staff will also assess the impact of BWOG or staff proposed system design changes to reduce the .

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sensitivity of the B&W design.

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4.3.4 SYSTEMS / DESIGN Issues (BWOG/PEICSB)

In the preceeding subtask, the impact of system design on plant response are examined. This subtask will examine the hardware design aspects (e.g., power supply adequacy, failure modes and component response, backup control capability, etc.) of the systems. Clearly, however, this subtask must be fully integrated with the sy' stems / operational subtask in order to

, fully assess the adequacy of current, and proposed, system designs.

The BWOG already has underway several tasks related to systems reviews. These include:

ICS/NNI Evaluation Main Feedwater System Review EFW/AFW System Review Secondary Plant Relief Systems Review Instrument Air System Design Review l

I These systems were identified by the BWOG as " sensitive systems" as a result of previous examinations of B&W plant operational experience. Additional system reviews may be initiated by the BWOG if they identify, as part of the information gathering phase, other systems which have contributed signi-ficantly to trips and transients and post-trip control. The system review plans are described in Section IX of the BWOG submittal of May 15, 1986.

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The staff will review the BWOG efforts in these areas. Specifically, the stTff will ensure that the " sensitive" systems have been properly identi-fied from the information gathering task. Additionally, the staff will work with the BWGG to ensure that the detailed efforts of the BWOG address the priortized concerns wilich arise from Task 4.2. Ultimately, the staff will assess the adequacy of proposed BWOG recommendations. This will in- j clude, as part of Task 4.3.3, an examination of the effect cf the proposed changes on the sensitivity of B&W plants to operational transients.

4.4 FINDINGS (ALL pWR-B BRANCHES) i As a result of the BWOG efforts and the independent staff reviews, the staff will reassess the overall safety of B&W plants and determine whether the present set of requirements for B&W plants are appropriate for the long-term and lead to a level of safety at B&W plants that is comparable to other PWRs. The staff will consider the recommendations of the BWOG and judge the adequacy of the proposed short and long-term actions.

. i The staff recognizes that the BWOG recommendations must be appropriately implemented at the B&W plants in order to improve their overall safety.

l The implementation phase will be monitored separately from this generic j reassessment using the normal regulatory processes. Staff-proposed changes, if any, will be handled via the backfit rule. Actual implemen-tation is expected to follow the completion of the reassessment program.

- 14 5.0 RESULTS (ALL PWR-B BRANCHES)

Following the completion of the generic reassessment, the staff will publish a NUREG report documenting the findings of the generic re-assessment. The ' oft of the initial SER is to be completed by December 1986. Supplements to the 5ER will be issued thereafter; the i final supplement is to be completed in June 1987.

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j 6.0 SCHEDULE AND MILESTONES As noted above, the staff's reassessment of the B&W plant design is to be completed in June 1987. In order to achieve this schedule, and monitor the progress of the program, the staff has developed a set of key milestones.

In light of the BWOG 1ead in the reassessment program, these milestones include both staff and BWOG activities.

The milestones for the program are given on Table 2. [heprogramschedule is shown on Figure 2.

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l Table 1 Regional and Office Contacts Region I - W. Kane  !

Region II - A. Gibson '

Region III - C. Paparello ,

i Region IV - J. Gagliardo 1 Region V - J. Crews IE - E. Jordan RES - B. Morris AE0D - J. Heltemes t

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4 Table 2 i

Program Milestones Projected Actual Milestone Organization Completion Completion MFW Problem Rpt. BWOG 6/17/86 ICS Input Failure Rpt. BWOG 6/30/86 ICS Design Features Rpt. BWOG 7/4/86 Draft ICS Recomm. BWOG 8/4/86 TAP Reports Available BWOG 8/15/86 Results/ TAP Data Review BWOG 8/15/86 DEF Scope /MFW Review BWOG 8/19/86 FMEA on ICS BWOG 8/26/86 Operator Interviews BWOG 8/27/86 Prioritization Proc. BWOG 8/30/86 EFW/AFW Recomm. BWOG 9/15/86 Identify B&W Des. Issues REGIONS 9/15/86 Inst. Air Final Rpt. BWOG 9/26/86 Review TAP Reports - EB,PEICSB,RSB, FOB 9/30/86 Summarize Implem. Status PDf6 9/30/86 Other Data Review BWOG 10/7/86 Mtg./BWOG PRA Activities BWOG/F0B 10/15/86 Latest RTS Report BWOG 10/15/86 l

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Table 2 (Program Milestones) Milestone Organization Projected Actual Completion Completion Relief System Recomm. BWOG 10/16/86 Staff Concerns to BWOG EB,PEICSB,RSB,F08 10/30/86 Sensitivity Study Rept. BWOG/MPR 11/15/86 Draft NUREG EB,PEICSB,RSB,F0B 11/30/86 Issue NUREG EB,PEICSB,RSB,F0B 12/30/86 Final ICS Recomm. BWOG ,

2/27/87 Emer.0per. Proc. Review BWOG 4/1/87 MFW System Review BWOG 4/15/87 Suppl.1 to NUREG EB,PEICSB RSB,F0B 4/15/87 4

Latest RTS Rpt. BWOG 4/15/87 Risk Assess. Report BWOG 4/17/87 Suppl.2 to NUREG EB,PEICSB,RSB,F0B 6/15/87 l

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FIGURE 1 B8W DESIGN REASSISSMENT PROGRAM fxf'rmation Gathering Evaluation 4.1.1 Operating 4.3.1 Experience Review Human Factors

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BWOG, RSB, FOB, PEICS EB BWOG, FOB l 4.1.2 Interviews of

• 4.3.2 Maintenance and PRA Reviews Operat1ons Personnel BWOG BWOG, FOB _

4.1.3 Regional Operations 4.2 Integration of 4.4 Experience Feedback Issues / Concerns a Issues /Prioritiration Specific m Long & Short _ Findings of Concerns Work Term Actions - *WREG Activities EB, F08. RSB, PEICSB Report Region, TA for AD BWOG. RSB, PE!CS, F08. EB 4.3.3 -

Systems / Operational 4.1.4 Status of issues l Utility Compliance ' -

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to MRC Actions BWOG, MPR, R$B 1

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4.3.4 Systems / 8 Implementatton I Design Issues I

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