ML20214R549

Testimony of La Walsh & Gs Thomas on 860919 Re Seacoast Anti-Pollution League Contention 6 (Formerly Contention NH-10).Related Correspondence

ML20214R549
Person / Time
Site:	Seabrook
Issue date:	09/19/1986
From:	George Thomas, Walsh L PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
Shared Package
ML20214R528	List: ML20214R525 ML20214R535 ML20214R549 ML20214R559 ML20214R573
References
OL-1, NUDOCS 8609290207
Download: ML20214R549 (8)

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j Dated: September 19, 1986 i UNITED STATES OF AMERICA

!l NUCLEAR REGULATORY COMMISSION j before the l

1 ATOMIC SAFETY AND LICENSING BOARD i

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l' In the Matter of )

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL-1 l NEW HAMPSHIRE, et al. ) 50-444-OL-1 i ) On-site Emergency Planning

(Seabrook Station, Units 1 and 2) ) and Safety Issues j )

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TESTIMONY OF L.A. WALSH j AND G.S. THOMAS SAPL SUPPLEMENTAL CONTENTION 6 (FORMERLY NH-10) ,

(as modified by the ruling on summary disposition) i l This testimony addresses the following question:

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' Whether or not in light of the fact that

the SPDS is not currently at an optimum, i.e.

incomplete, because of the certain

! deficiencies enumerated by the Staff in a draft license and an Affidavit of Richard H.

Eckenrode of August 18, 1986 (Eckenrode Affidavit) there is reasonable assurance that j in deferring improvements to the SPDS until j the first refueling outage the safety of the '

i population in the immediate vicinity of the 1

plant will be protected.

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} At the outset it should be understood that the Safety

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I l Parameter Display System (SPDS) is not considered a safety i

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system. Operator actions are not taken at the SPDS.

l Rather, the' purpose of the SPDS is to provide operators with

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j a concise display of certain information about certain i

i relevant plant variables. <

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As indicated in NVREG-0737, Supplement 1, the SPDS is to

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1 be used in addition to existing control instrumentation and f serves to aid and augment this instrumentation. Moreover, j Supplement 1 also provides that operators should be trained

) to respond to accident conditions with and without the SPDS l

available. Therefore, even if there were no SPDS at all,

! the necessary information would be available to the i

operators from other sources within the control room and the j operators would be capable of taking the appropriate action 1

I based on this information. As will be seen below, these I

l other sources within the control room and the operators would be capable of taking the appropriate action based on

,i their information. of and by themselves, provide reasonable j assurance that the health and safety of the public in the vicinity of the plant will be protected.

J j Set forth below are discussions of the particular items proposed to be deferred under the June 26, 1986 draft of l License NPF-56.

1. Continuous display of the top level critical safety l

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function summary at the assigned SPDS control room location.

This issue raises the concept of continuously displaying the top level critical safety functions instead of calling them up when desired. Until a mutually acceptable resolution to this concern is reached, the result sought may be accomplished by having the SPDS/STA Console CRT continuously disply the top level critical safety functions during normal plant operation.

2. Addition of, or satisfactory justification for, not adding RHR flow and hydrogen concentration parameters to appropriate SPDS screens.

These parameters are presently indicated on the main control board in more than one location and are considered when using emergency procedures to respond to the plant upset conditions. Thus, the data is available to the operators even without the SPDS.

3. Addition of a containment isolation status screen on SPDS, or improvement to the current containment isolation display to be satisfactorily recognizable from the assigned SPDS location in the control room.

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This indication is also present on the main control

! board in e location other than the SPDS.

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! 4. Addition of radiation monitoring screen to display I

at least steam generator (or steam line) and stack ,

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radiation.

This information is available to the operators at the RDMS console. Thus, the data is available to the operators

even without the SPDS.

i j 5. Improvement of the heat sink screen for consistency

, in labeling, and the suberiticality and core

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a cooling screens for mode dependency so as not to mislead operators.

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l The heat sink screen has been changed and is now 1

consistent in labeling. The subcriticality and core cooling screens, without any of the changes required by Staff, will j function properly below 5% power. Although not required, we

intend to implement this enhancement prior to exceeding 5% -

power. ,

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6. Addition of approved isolation devices between the Reactor Vessel Level Instrumentation System (RVLIS) i and SPDS.

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These isolation devices have been installed. Qualifying

! tests have been completed with satisfactory results.

Set forth below are discussions of the five additional

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! deferrals which will be listed in Supplement 6 of the SER.

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j 1. The display call-up method appears awkward, i

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i The awkwardness referred to by the Staff derives from l

the fact that currently the call up of these displays i requires the operator to position a cursor and then press two Luttons simultaneously. Staff recommends that the SPDS be changed so that only a single operator action is necessary. The Staff recommendation will, if adopted, J

simplify the procedure, but the procedure presently available is certainly adequate to'the task, and thus the 3 necessary " reasonable assurance" exists.

I i 2. The data validation algorithms appear c unsophisticated.

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! As stated by the Staff in SSER No. 6 $ 18.2 at p. 4:

l The audit indicated that the data validation methodology includes only range checking, averaging, and auctioneering.

Concern was raised that a parameter value 1 could be within an acceptable range but l significantly different from other measures of the same parameter, causing the average

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value to be incorrect and possibly l misleading. A more sophisticated data validation algorithm, to ensure display of

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more valid data, is being pursued by the applicant.

In short, the Staff is recommending a more sophisticated methodology; the present methodology is not inadequate for the task. Moreover, by procedure, the operators are required to validate any SPDS conclusions prior to implementing any corrective action. Thus the necessary

" reasonable assurance" exists.

3. The usefulness of the lower level display formats is in question.

SSER No. 6 states: " top-level CSF summary display appears to aid operators in rapidly determining plant status, but lower-level display formats do not seem to be as useful." (SSER No. 6 6 18.2 at p. 6.)

The combination of SPDS top level display with operator training makes it possible to satisfactorily monitor plant status without SPDS lower-level displays being available on the main plant computer system. The staff's comments indicate a disagreement on specific usage of the SPDS lower level displays; however, the ability of the SPDS to aid the operators is not in question.

4. The availability calculations do not include RVLIS or the RDMS.

e The availability calculation cannot be completed prior to the actual interface of both units with the SPDS. In any case, the availability percentage does not affect the safety of the public because there is a backup instrumentation for the computerized SPDS.

5. A system load test is needed to verify system response time.

SSER No. 6 states: "syster. response time appears to be satisfactory but the staff observations were made during a lightly loaded sequence." (SSER No. 6 5 18.2 at p.6.)

A meaningful system load test, which will give representative SPDS response times, will be performed when the main plant computer system is loaded to support an operational plant. Performance of a system load test under nonrepresentative main plant computer conditions will not help to ensure the health and safety of the public.

CONCLUSION Like the SPDS itself, none of the above-discussed items is necessary to assure safe operation. Each is, rather, an enhancement to a satisfactory extant system. Moreover, this system, without the above-described enhancements, was accepted by a nation-wide group composed of utility e l i

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i personnel and Westinghouse Electric Corp Engineers,

! Seabrook Station hosted the verification and validation I

program for the Westinghouse Owners Group Emergency Response Guidelines. As part of this test, Seabrook Station was

! allowed to use the SPDS system on three of the five days of testing to monitor critical safety parameters. Seabrook supplied two operating crews which were presented with 35 j randomly selected accident scenarios. These scenarios j ranged from simple reactor trips to multiple pressure

! boundary failures with coincident multiple equipment and control failures. The conclusions were that SPDS facilitated prompt identification of developing challenges 1

and directed the operator to appropriate recovery

! procedures. The criteria that "the plant be placed in a safe, stable condition regardless of impoced structural and equipment failures" was adequately satisfied. In summary,

Seabrook Station has an SPDS which fully meets the goals of safe and efficient power operation.

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