ML18047A329

Submits Draft Review of Integrated Plant Safety Assessment of Sep.Review of Operating Experiences Needs to Be Updated & Augmented

ML18047A329
Person / Time
Site:	Palisades
Issue date:	04/23/1982
From:	Isbin H ISBIN, H.
To:	Russell W NRC
Shared Package
ML18047A285	List: ML18047A284 ML18047A327 ML18047A328 ML18047A329 ML18047A330
References
RTR-NUREG-0820, RTR-NUREG-820 NUDOCS 8205190072
Download: ML18047A329 (8)

Text

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HERBERT S. ISBIN 281 5 MONTEREY PKWY ..

ST. LOUIS PARK, MN SS416 (61 2) 920-6417 April 23, 1982 '

To: Project Officer W. Russell Mailstop 516 7920 Norfolk Avenue Bethesda, Maryland 20014 From: H. S. Isbin Draft Review of Integrated Plant Safety Assessment Syst~atic Evaluation Program Palisades Plant Draft NUREG-0820 Enclosed please find my draft review in response to your request to 11 * . *

• provide

• an .evaluation of the adequacy of the rationale used by the staff in identifying and making recommendations for backf*i t requirements. 11 In addition to Draft NUREG-0820, I received SECY.77-561 (October 26, 1977), SECY 76-545 (November 12, 1976), a November 15, 1977 memorandum from S. J. Chilk to L. V. Gossick, and a draft Statement of Work. I have not had the benefit of any discussions with the SEP staff nor with any reviewers. Please let me know if you desire any changes in the focus of my review.

The highlights of my review are as follows:

• The planning used for SEP is outstanding from the point of view of identifying safety items.

• The objectives have been well conceived; however one major objective may have been inadvertently omitted in the NUREG report.

• The review of operating experiences needs to be updated and augmented.

• Lim1ted assistance was provided by the probabilistic risk assessment for this plant.

• The reporting of the Topics and the ensuing approach to the decision making, in general, are well done.

• Too many events and changes have occurred in the past three years to be able to evaluate whether the SEP program is efficiently and economically using NRC and Ind~stry resources.

• An important finding is that no SEP Topic was considered to be of sufficient importance to require a prompt resolution.

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• 9 HERBERT S. ISBIN 2815 MONTEREY PKWY.

ST. LOUIS PARK, MN 55416 (61 2) 920-6417

• Attention has been focussed on achieving an " ..* integrated and balanced ... " decision, considering that the SEP program is being

.j. carried out in conjunction with major NRG and Industry efforts for implementing TMI Action Plan Items, and responding to IEBulletins and Generic Letters. Resolution of Unresolved Safety Issues remains a continuing activity along with mandated annual reports to the Congress concerning identification of any new issues.

overall assessment of safety of the plant must utilize all these inputs.

Additional SEP supplements have been planned for the Palisades plants. The Status of the SEP Topics, presented in Appendix A, is for the date April 1977, with some having been updated to May 1981 for inclusion of *TMI tasks, USI, and severai IE Bulletins. I understand that no changes were-made in Topic definitions. Has consideration been given to updating all the SEP Topics regarding status and References?

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HERBERT S. ISBIN 2815 MONTEREY PKWY ..

ST. LOUIS PARK. MN SS416 (61 2) 920-6417 DRAFT REVIEW

'I by H. s. Isbin COMMENTS ON SECTIONS OF NUREG-0820 1.2 Systematic Evaluation Prqgram Objectives

.Only three objectives are presented. I believe that the fourth objective is essential and from the referenced material I extract "and (4) an overall evaluation of all safety topics evaluated in the SEP and other ongoing programs .*. "

I would emphasize overall, all, other ongoing programs.

I assume that the presentation of the original five SEP object~ves is to augment the present objectives. Any program that seeks " ... to make integrated and balanced decisions with respect to any required backfitting" and to

" **. efficiently us*e. available resources and minimize requirements for additional resources by NRC or industry."merits our standing ovation.

A variety of actions taken during the last three years on generic matters, including the TMI related items, have considerably altered priorities. In my review, I have chosen to focus on what elements need to be included to achieve the " *.* integrated and balanced ... " backfitting decisions.

1.4 Summary of Operating History and Experience This section is inadequate because it is not updated.

The ORNL detailed review is a worthy study up to and including the year 1979 and represents an "external" appraisal. More emphasis needs to be given on implementation of corrective actions.

The summary of Escalated Enforcement Actions presents significant events through March 1981. I suggest including more "internal" reviews, including the Region III "Systematic Assessment of Licensee Performance" (SALP), and the periodic Inspection Reports by the resident inspector(s) and by the special teams. The updating might include the Licensee's Annual Report of Changes, Tests and Experiments.

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HERBERT S. ISBIN 2815 MONTEREY PKWY.

ST. LOUIS PARK. MN 55416 (6, 2) 920-64, 7 The listing of the civil penalties and orders is not as important as the thorough evaluation of the Licensee's response in terms of corporate policies, management and staff control measures, training and requalification programs, procedures, and quality assurance. What are the lessons learned and how are the improvements being implemented? Are these actions contributing to overall plant safety?

Corrective features are embodied in the TMI Action Plan. Analysis and feedback of operating experiences must be achieved in a realistic program.

The SEP report does not reflect any improvements in training nor even the considerable augmentation of staff (which I assume must be taking place) .

In my opinion, it is too early for the NRC to reference INFO reports and documents; however, if the Licensee has made or is making improvements as a consequence of INPO evaluations, such information assists in making " ... balanced and integrated .*. "* decisions.

Programs involving SEE-IN and NOTEPAD should be checked for updating operating experiences and reference should be made to the NRC Generic Letter 82-04. Have the SEP reviewers made any use of the improvements underway on handling and managing the collation of LERs? Is the Sequence Coding and Search System operational?

A feature of the SEP program that I had expected to find, but did not, is concerned with "aging" of components and systems. Have.there been any dis-cernible trends? Not all events are reportable, and thus some important trends might be missed if recourse is made to just LERs. The cooperation of the maintenance and inspection groups is needed. Are the IE Information Notices helpful in ascertaining whether any special aging effects could h~ve an impact on safety?

2. Review Method 2.2 Sel~ction of Topic List The identification of the more than 800 candidate items took place in 1976 and 1977~ and the methods used are impressive. The process of reducing this number to 90 topics applicable for the Palisades SEP review has an acceptable rationale, providing all current items involving Unresolved Safety Issues, TM~

Action Plan Items, and other generic matters are to be included. The draft SEP report indicates that a supplement is to be issued which will designate the status of the USis and TMI Action Plan Items. I consider this supplement to be a *key factor in balancing overall decisions to be made on the SEP items. The magnitude of this task should not be underestimated~

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HERBERT S. ISBIN 281 5 MONTEREY PKWY *.

ST. LOUIS PARK. MN SS416 (612) 920-6417 2.3 Topic Evaluation Procedures The two methods used for the preparation of the final Safety Evaluation Reports for the 90 topics have involved Licensee participation to ascertain that correct information was used. I have not seen any of t~e SERs, but I

-think that the approach used is good.

The finding by the NRC Staff that no topic identified in the.SEP review required immediate action is significant.

Topics were grouped into categories regarding no further action, action initiated by the Licensee which is acceptable to the NRC, and finally those which require d~cisions on whether backfitting is needed. This approach is logical.

2.4 Integrated Plant Safety Assessment.

The overall planning of the SEP. review to achieve a " .*. balanced and integrated .*. " decision on each topic appears to be good. The approach used by the NRC Staff appears to be consistent with the designated objectives.

I was not able to judge how the SEP work loads have impacted on the Licensee's resources. Nor have I been able to judge how the NRC plans to mold the backfitting decisions with decisions made and to be made on the USis and TMI Related Safety Items. Perhaps this subject will be treated in a. supplement.

COMMENTS ON SELECTED TOPICS 3.3 Topics for Which Plant Design Meets Current Criteria

• Based on Modifications I~plemented by the Licensee 3.3.1 Topi*c III-6 Seismic Design Considerations The Licensee must be responding to IE Bulletins, dealing for example with structural integrity of masonry walls and safety related piping systems. The report would be improved if the relationships of the programs involved for the IE Bulletins to the SEP concerns were clearly presented.

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HERBERT S. ISBIN 281 5 MONTEREY PKWY.

ST. LOUIS PARK, MN 55416 (6, 2J 920-64, 7 Integrated Assessment 4.6 Topic III-2 Wind and Tornado Loadings 4.6.1 Safety Injection and Refueling Water (SIRW) and Condensate Storage Tanks The approach taken by the Staff is good.

" .*. if the SIRW tank or condensate storage tank is lost **. "

Rather than just "or", don't you mean either or both? Further, wouldn't you need to comment4 that the failure(s)' in themselves, do not produce any undue flooding ef.fects?

This is one of the few items where the TMI Action Plan, Item I.C.l, "Guidance for the *Evaluation and Development of Procedures for Transients and Accidents," is mentioned. This. SEP topic is a part of a much broader and more complete task, with priority on Licensee's resources t6 be given to the TMI Item.

4.10 Topic III-6 Seis"tTtic Design Considerations Once again, for an " ... integrated and balanced ..* " approach, SEP concerns need to be factored into the broader a~eas being addressed through responses to IE Bulletins.

4.15 Topic V-5 Reactor Coolant Pressure Boundary (RCPB) Leakage Detection

• The rationale used by the Staff in arriving at conclusions fits the objective set forth for SEP. Is there any impact on radiation exposure to workers?

4.16.2 Use of Safety-Grade Systems for Safe Shutdown On page A-42, modification of the Branch Technical Position RSB5-l is being suggested. What is th~ current status?

4.19 Topic VI-3 Containment Pressure and Heat Ra~oval Capability The emphasis of this resolution is on the capability of the containment to withstand the increased pressure resulting from a two-steam generator blowdown.

A " ... balanced and integrated ..* " approach should avoid exacerbating other possible issueG.* For e~ample, would there by any impact on resolving the con-cerns presented in IE Bulletin 79-0lB, d~aling with the* environmental *

• conditions for the qualification of safety-related electrical equipment?

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,. " HERBERT S. ISBIN

,...5-281 S MONTEREY PKWY.

ST. LOUIS PARK, MN 55416 (6, 2) 920-6417 4.23 Topic VII-1.A. Isolation of Reactor Protection System from Nonsafety Systems, Including Qualification_ of Isolation Devices.

No reference is given to the completion of Technical assignment Control No. 6696, nor whether there have been any continuing studies.

4.24 Topic VII-3, Systems Required for Safe Shutdown I had expected to find a discussion on what can be done outside the control room " ... to achieve and maintain a safe shutdown condition of the plant ..* "

(See A~66) .

The SERs started with the general topic and then determined specific items. Using this Topic as an example, I suggest that both the specific and overall conclusion be stated.

4.27 Topic IX-3, Station Service and Cooling Water Systems Again, as noted in 4.24, not all the safety objectives given for this topic (see pages A-77 and -78) are addressed. Further, under the heading of Status, reference is made to pr'oposed generic reviews and technical *activities.

Were these proposals carried out? Additionally, are there any current probabilistic studies of flood hazards and flooding effects which should be noted?

4.29 Topic IX-6, Fire Protection The application of 10CFRSO, Appendix R, concerning fire protection and safe shutdown analysis and compliance, is a major undertaking. All that is noted is that associated circuits will be reviewed generically and outside the context of the SEP.

Additional Comments on Achieving An

" *.. integrated and balanced ... " Decision From the descriptions given of the methods used to identify topics of safety significance in Phase I of SEP, I conclude that the identification process was thorough, at least for the conditions known up to and including 1977. I appreciate the need for restricting expansion of the topics so that designated goals can be assigned. The developers of SEP recognized that resolution of generic items would proceed independently of SEP, but that some-how there would be an integrationof emerging NRC positions into an effective and efficient molding for the " ... final safety assessment of the plant." Since

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I HERBERT S. ISSIN 281 5 MONTEREY PKWY.

ST. LOUIS PARK, MN S5416 (6, 2) 920-64, 7 the approach to the "final" safety assessment may be asymptotic, I recommend deletion of "final".

Supplements. are to be issued to present the status of the generic i terns.

Additionally, the NRC, in special reports to the Congress, prepares the "Identification of New Unresolved Safety Issues Relating to Nuclear Power Plants." For example, NUREG-0705, March 1981, identified four new USis and listed a number of candidate issues for consideration as USis. (I have not seen the 1982 report.) Along with the moving target of USis, SEP reviewers need to include the TMI Action Plan Items, a variety of IE Bulletins, and Generic Letters. Attention *has to be given to the man~gement and incorporation of the information being generated into overall safety assessments.

The ...... integrated and balanced approach ... " should recogni~e the concerns

• of the Licensees regarding any possible unwarranted diversion of engineering staff from needed tasks. For example, see NUREG-0839, "A Survey by Senior NRC Management to Obtain Viewpoints on the Safety Impact of Regulatory Activities from Representative Utilities Operating and Constructing Nuclear Power Plants,"

August 1981. On the other hand, a dissenting viewpoint within the NRC, such as given by Demetrious L. Basdekas (published in the Minneapolis Star and Tribune, April 9, 1982) cannot go unchallenged, particularly when he writes that " .** the government and industry are unable or unwilling to deal honestly and urgently with far reaching nuclear-safety problems." I know in .the past that dissenting views were acknowledged and answered. Perhaps this has already been done for the present case.

Peripheral issues may need to be included. For example, proposed changes for Technical Specifications purport to reduce the number and level of detail in the technical portion and permit the use of a supplementary category. The criteria being developed for these changes should be consulted before implementing resolution of SEP Topics through added Tech Specs.

Only a limited, but useful, application could be made of the probabilistic risk assessment study for this plapt. Considering the large NRC budgeted research in this area for the past several years, the emphasis on development of methodologies, and the various current applica.tions, I expect more feedback into the SEP activities.

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