ML20199J904

Summary of 860604 Meeting W/B&W Owners Group in Bethesda,Md, to Discuss Owners Group Trip Reduction & Transient Response Improvement Program.Attendance List & Handouts Encl

ML20199J904
Person / Time
Issue date:	06/16/1986
From:	Paulson W Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8607080459
Download: ML20199J904 (48)

Text

June 16, 1986 LICENSEE: B&W Owners Group

SUMMARY

OF JUNE 4,1986 MEETING On June 4, 1986, the NRC staff met with representatives of the B&W Owners Group in Bethesda, Maryland. The purpose of the meeting was to discuss NRC coments on the B&W Owners Group Trip Reduction and Transient Response Improvement Program (STOP-TRIP) that was submitted by letter dated May 15, 1986. Enclosure 1 is a list of attendees. is a copy of the handouts provided by the owners group.

By letter dated June 2,1986, the. staff provided coments on the STOP-TRIP program. The owners group responded to these coments as indicated in and (1) indicated that a written response will be provided; (2) requested a list of NRC contacts for the elements of the STOP-TRIP program; (3) indicated that the May 15, 1986 report will be updated in August and October 1986; and, (4) invited the NRC to provide a representative on the peer review panel for the sensitivity study. The staff and the owners group agreed to arrange working meetings for the following program elements:

1.

Sensitivity Study 2.

Transient Assessment Program 3.

System Reviews (main feedwater, auxiliary feedwater and secondary side steam relief).

4.

Recomendation tracking system and prioritization.

/s/WPaulson Walter A. Paulson, Technical Assistant Division of PWR Licensing-B

Enclosure:

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NEETING

SUMMARY

DISTRIBUTION cket File NRC PDR L PDR OELD E. Jordan B. Grimes ACRS 10 B. Borsum AD Rdg W. Paulson F. Schroeder D. Crutchfield R. Jones C. Thomas Mm. H. Regan R. L. Ferguson F. Allenspach M. Rubin M. Gooiman G. Edison W. Beckner B. Agrawal G. A. Schwenk J. Ramsey C. McCracken J. Conran A. J. Szukiewicz D. L. Basdekas J. S. Wermiel H. Garp P. Shemanski J. A. Calvo H. Bailey R. W. Ganthner P. T. Kuo J. Taylor, B&W J. Stolz 4

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ENCLOSURE 1 ATTENDANCE LIST

. JUNE 4, 1986 MEETING - NRC STAFF & B&W CWNERS GROUP NAME ORGANIZATION W. Paulson NRC/PWR-B Frank Schroeder NRC/PWR-B Bert Simpson Florida Power Corn.

Dennis Crutchfield NRC/NRR/PWR-B George Braulke GPUN Mark Linn TVA Stuart Rose Duke Power Mark Averett Florida Power Co T.

Neal Rutherford Duke Power Co.

Robert Jones NRC/NRR/PWR-B Cecil Thomas NRC/NRR/PWR-B Wm. H. Regan NRC/NRR/PWR-B R. L. Ferguson NRC/NRR/PWR-B Bob Black B&W Fred Allenspach NRR/NRR/PWR-B Mark Rubin NRC/NRR/PWR-B Mike Goodman NRC/NRR/PWR-B Jim Ritts TVA Gordon Edison NRC/NRR/PWR-B William Beckner NRC/NRR/PWR-B Ron Wright INEL Bmarat Agrawal NRC/RES/DAE George A. Schwenk NRC/NRR/RSB-B John E. Ramsey NRC/NRR/PWR-B Conrad McCracken NRR/PDB#6 Mark Beaumont Westinghouse Charlie Brinkman Combustion Engineering Tom Daniels Duke Power Company Grey Hudson Duke Power Company J. H. Taylor B&W John Bohart B&W Gordon R. Skillman GPUNC J. Ted Enos Arkansas Power & Light Jim Conran NRC/ED0/ROGR Staff J. D. Carlton B&W Larry Reed Duke Power Company James W. Langernbach GPU Nuclear Steven E. Mays Toledo Edison Marvin S. Fertel Delian Corp.

~ ~ hil C. Jain Toledo Edison Sus A. J. Szukiewicz NRC/NRR/DSR0/EIB D. L. Basdekas NRC/RE J. S. Wermiel NRC/NRR/DPL-B Hukam Garp NRC/NRR/DPL-B Paul Shemanski NRC/NRR/DPL-B/PEICSB Jaso A. Calvo NRC/NRR/DPL-B/PEICSB Henry Bailey NRC/IE/DEPER/EAB R. W. Ganthner B&W P. T. Kuo NRC/NRR/PWR-B/EB Wally Wilgus Florida Power

MEETING

SUMMARY

DISTRIBUTION Docket File NRC PDR L PDR DELD E. Jordan B. Grimes ACRS 10 B. Borsum AD Rdg

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W. Paulson F. Schroeder D. Crutchfield R. Jones C. Thomas Wm. H. Regan R. L. Ferguson F. Allenspach M. Rubin M. Goodman G. Edison W. Beckner B. Agrawal G. A. Schwenk J. Ramsey C. McCracken J. Conran A. J. Szukiewicz D. L. Basdekas J. S. Wermiel H. Garp P. Shemanski J. A. Calvo H. Bailey R. W. Ganthner P. T. Kuo J. Taylor, B&W J. Stolz G

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June 16, 1986 LICENSEE: B&W Owners Group

SUMMARY

OF JUNE 4,1986 MEETING On June 4, 1986, the NRC staff met with representatives of the B&W Owners Group in Bethesda, Maryland. The purpose of the meeting was to discuss NRC comments on the B&W Owners Group Trip Reduction and Transient Response Improvement Program (STOP-TRIP) that was submitted by letter dated May 15, 1986. Enclosure 1 is a list of attendees. Enclosure 2 is a copy of the handouts provided by the owners group.

By letter dated June 2,1986, the staff provided comments on the STOP-TRIP i

program. The owners group responded to these comments as indicated in and (1) indicated that a written response will be provided; (2) requested a list of NRC contacts.for the elements of the STOP-TRIP program; (3) indicated that the May 15, 1986 report will be updated in August and October 1986; and, (4) invited the NRC to provide a representative on the peer review panel for the sensitivity study. The staff and the owners group agreed to arrange working meetings for the following program elements:

1.

Sensitivity Study 2.

Transient Assessment Program 3.

System Reviews (main feedwater, auxiliary feedwater and secondary side steam relief).

4.

Recommendation tracking system and prioritization.

kdM. &

Walter A. Paulson, Technical Assistant Division of PWR Licensing-B

Enclosure:

As stated I

ENCLOSURE 1 ATTENDANCE LIST JUNE 4, 1986 MEETING - NRC STAFF & B&W OWNERS GROUP NAME ORGANIZATION W. Paulson NRC/PWR-B Frank Schroeder NRC/PWR-B Bert Simpson Florida Power Corp.

Dennis Crutchfield NRC/NRR/PWR-B George Braulke GPUN Mark Linn TVA Stuart Rose Duke Power Mark Averett Florida Power Corp.

Neal Rutherford Duke Power Co.

Robert Jones NRC/NRR/PWR-B Cecil Thomas NRC/NRR/PWR-B Wm. H. Regan NRC/NRR/PWR-B R. L. Ferguson NRC/NRR/PWR-B Bob Black B&W Fred Allenspach NRR/NRR/PWR-B Mark Rubin NRC/NRR/PWR-B Mike Goodman NRC/NRR/PWR-B Jim Ritts TVA Gordon Edison NRC/NRR/PWR-B William Beckner NRC/NRR/PWR-B Ron Wright INEL Bmarat Agrawal NRC/RES/DAE George A. Schwenk NRC/NRR/RSB-B John E. Ramsey NRC/NRR/PWR-B Conrad McCracken NRR/PDB#6 Mark Beaumont Westinghouse Charlie Brinkman Combustion Engineering Tom Daniels Duke Power Company Grey Hudson Duke Power Company J. H. Taylor B&W John Bohart B&W Gordon R. Skillman GPUNC J. Ted Enos Arkansas Power & Light Jim Conran NRC/ED0/ROGR Staff J. D. Carlton B&W Larry Reed Duke Power Company James W. Langernbach GPU Nuclear Steven E. Mays Toledo Edison Marvin S. Fertel Delian Corp.

Sushil C. Jain Toledo Edison A. J. Szukiewicz NRC/NRR/DSR0/EIB D. L. Basdekas NRC/RE J. S. Wermiel NRC/NRR/DPL-B Hukam Garp NRC/NRR/DPL-B Paul Shemanski NRC/NRR/DPL-B/PEICSB Joso A. Calvo NRC/NRR/DPL-B/PEICSB Henry Bailey NRC/IE/DEPER/EAB l

R. W. Ganthner B&W P. T. Kuo NRC/NRR/PWR-B/EB Wally Wilgus Florida Power l

ENCLOSURE 2 B&W OWNERS GROUP TRIP REDUCTION AND TRANSIENT RESPONSE IMPROVEMENT PROGRAM DISCUSSION OF 6/2/86 NRC COMMENTS JUNE 4,1986

3 8

B&WOG MEETING TO DISCUSS NRC COMMENTS ON TRIP REDUCTION AND TRANSIENT RESPONSE IMPROVEMENT PROGRAM JUNE 4,1986 AGENDA I.

INTRODUCTION & BACKGROUND II.

MEETING PURPOSE AND OBJECTIVE Ill.

PROGRAM CLARIFICATIONS IV.

REVIEWOF6/2/86 CRUTCHFIELD TO TUCKER LETTER V.

DISCUSSION OF NRC ACTIONS PLANNED VI.

NEAR-TERM FUTURE ACTIONS Vll.

CONCLUDING COMMENTS I

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4 STELLO 1/24/86 LETTER HIGHLIGHTS SENSITIVITY OF B&W PLANTS TO OPERATING TRANSIENTS.

NEED TO REEXAMINE B&W PLANT DESIGN REQUIREMENTS AND NEED TO SUPPLEMENT.

SAFE TO OPERATE AT THE CURRENT TIME.

RECOGNITION OF PAST, CURRENT, AND FUTURE MODS.

NEED FOR BROAD EVALUATION OF B&W DESIGN.

INTEREST IN B&WOG PARTICIPATION & LEAD ROLE.

COMPLETE REEXAMINATION EFFORT THIS YEAR.

CHANGES TO BE PER BACKFIT RULE.

I MAIN POINT THE FREQUENCY OF COMPLEX TRANSIENTS IS TOO HIGH i

I i

9 I

TUCKER 2/13/86 LETTER HIGHLIGHTS B&WOG WILL LEAD EFFORT TO REDUCE TRIP FREQUENCY AND IMPROVE TRANSIENT RESPONSE.

B&WOG WILL DEVELOP A PLAN AND WORK WITH THE STAFF IN FORMULATING THAT PLAN.

NRC ABLETO MONITOR PROGRAM PROGRESS.

B&WOG COMMITED TO RESOLVING CONCERNS RELATED TO TRIPS AND TRANSIENT RESPONSE.

MAIN POINT PROGRAM WILL REDUCE COMPLEX TRANSIENT FREQUENCIES.

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MEETING PURPOSES RESPOND TO NRC COMMENTS ON STOP-TRIP PROGRAM

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UNDERSTAND NRC SCOPE OUTSIDE STOP-TRIP PROGRAM

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MEETING OBJECTIVES a

TO CONTINUE THE B&WOG-NRC DIALOGUE ON THE I

PLANT REASSESSMENT RELATED TO REDUCING THE FREQUENCY OF COMPLEX TRANSIENTS.

TO ASSURE A COMMON UNDERSTANDING OF THE B&WOG m

STOP-TRIP PROGRAM SCOPE.

PROGRAM CLARIFICATIONS 1.

PROGRAM ORGANIZATION 2.

PROGRAM DOCUMENTATION 3.

RECOMMENDATION TRACKING SYSTEM l

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1.

PROGRAM ORGANIZATION o

STOP TRIP PROGRAM MANAGEMENT CONCEPT CHAIRMAN G. R. SKILLMAN(GPUN)

VICE CHAIRMAN L. REED (DPC)

TEAM MEMBER J. MCCOLLIGAN(SMUD)

TEAM MEMBER S. MAYS (TED) o KEY UTILITY LIA! SONS

- ICS/NNI EVALUATION CHRIS DOYEL(FPC)

- SENSITIVITY STUDY STUART ROSE (DPC)

- SECONDARY PLANT BOB LOCKE(GPUN)

RELIEFSYSTEM REVIEW

- RISK ASSESSMENT MARK AVERETT (FPC)

- OPERATOR / MAINTENANCE MARK LINN(TVA)

INTERVIEWS

- OPERATING EXPERIENCE STUART ROSE (DPC)

REVIEW

- PROCEDURES REVIEW MARK LINN (TVA) o INDEPENDENT ADVISORY BOARD FOUR EXPERIENCED INDUSTRY REPRESENTATIVES OVERVIEW OF ENTIRE PROGRAM AND RESULTS REPORT TO STEERING AND EXECUTIVE COMMITTEE l

6 2.

PROGRAM DOCUMENTATION MAY 1986 TRANSMITTAL (BAW-1919) FORMS NUCLEUS OF FUTURE SUBMITTALS AND INCLUDES A DESCRIPTION OF THE PLAN AND SCHEDULE.

AS INDIVIDUAL PROJECTS ARE COMPLETED, THE STAFF WILL BE GIVEN COPIES OF THE FINAL REPORTS AT WORKING LEVEL MEETINGS.

UPDATES OF BAW-1919 IN AUGUST AND OCTOBER WILL INCLUDE SUMMARIES OF PROJECT RESULTS AND COPIES OF PROJECT FINAL REPORTS. THESE WILL BE FORMALLY TRANSMITTED.

FUTURE UPDATES WILL BE SCHEDULED IF NEEDED.

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B&WOG RECOMMENDATIONS TRACKING SYSTEM RECOMMENDATIONS FROM PROJECTS ARE IDENTIFIED RECOMMENDATIONS FORWARDED TO STEERING COMMITTEE FOR DISPOSITION (DECISION BASIS WILL BE DOCUMENTED)

RECOMMENDATIONS ARE TABULATED, CLASSIFIED, AND DISPOSITIONED FOR ACTION / RESOLUTION il UTILITY B&WOG TECHNICAL COMMITTEE B&WOG STEERING / EXECUTIVE COMMITTEE STATUS OF ACTION / RESOLUTION MONITORED THROUGH PERIODIC REPORTS BY STEERING COMMITTEE TO EXECUTIVE COMMITTEE.

COMPILED STATUS INFORMATION

Stop-Trip Program Process

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1. Information Gathering II. Integration Ill. Implementation I

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RESPONSE TO COMMENTS FROM 6/2/86 LETTER G.R.BRAULKE I.

EXECUTIVE

SUMMARY

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INTRODUCTION lll.

PROGRAM PROCESS IV.1,3.

PREVIOUSLY IDENTIFIED ACTIONS S.T. ROSE V.

SENSITIVITY STUDY VI.1,2.

OPERATING EXPERIENCE REVIEW M. A. LINN IV.2.

PREVIOUSLY IDENTIFIED ACTIONS Vll.

OPERATOR / MAINTENANCE INTERVIEWS XI.3,4.

NRC CONCERNS M.AVERETT Vill.

RISK ASSESSMENT REVIEW G.R.BRAULKE VI.3.

OPERATING EXPERIENCE REVIEW IX.

SYSTEM REVIEWS X.

PROGRAMMATIC & MANAGEMENT ACT!ONS XI.1,2.

NRC CONCERNS

1.1 Ni!C COMMENT:

SYSTEMS SHOULD BE REVIEWED ON PAST AS WELL AS POTENTIAL FUTURE PROBLEMS AND SHOULD INCL.UDE HARDWARE AND HUMAN FACTORS ISSUES.

B&WOG RESPONSE:

THE B&WOG PLAN DOES ADDRESS ACTUAL AND POTENTIAL PROBLEM AREAS. THE OPERATING EXPERIENCE METHOD IS USED TO FOCUS ON REAL PROBLEM AREAS AND THEN CONDUCT A BROAD BASED REVIEW OF THESE AREAS WHICH CAN INCLUDE SYSTEMS OR COMPONENTS. THIS BROAD BASED REVIEW INCLUDES MAINTENANCE, DESIGN HARDWARE, AND OPERATOR ACTIONS AS REQUIRED TO ADEQUATELY ADDRESS THE PROBLEM AREA. AS AN EXAMPLE, THE ICS HAS BEEN IDENTIFIED AS AN IMPORTANT SYSTEM AND A j

DETAILED REVIEW IS BEING CONDUCTED ON THIS SYSTEM INCLUDING AN FMEA.

1

9

11. 1 NRC COMMENT:

PROGRAM GOALS ARE NOT TECHNICALLY BASED.

B&WOG RESPONSE:

THE ULTIMATE GOAL IS TO REDUCE THE TRIPS AND TRANSIENTS TO ZERO. THE PURPOSE OF THE ESTABLISHED GOALS IS TO BE ABLE TO MEASURE IMPROVEMENT. GOALS WILL BE PERIODICALLY REEVALUATED. GOALS ARE NOT SET TO DEFINE AN

" ACCEPTABLE" RATE FOR B&W PLANTS.

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11. 2 NRC COMMENT:

l THE PROGRAM PLAN DOES NOT SHOW INTEGRATION OF VARIOUS PROJECT INPUTS AND OUTPUTS.

l B&WOG RESPONSE:

APPENDIX A SHOWS THE MAIN INTERFACES OF THE PROJECTS IN THE PLAN. THE INTEGRATION OF INFORMATION IS THE RESPONSIBILITY OF THE STOP-TRIP TEAM IN THEIR DAILY MANAGEMENT OF THE PROGRAM. THE STOP-TRIP TEAM CHAIRMAN AND THE KEY UTILITY LIAISONS ARE THE FOCAL POINT FOR THIS INTEGRATION. SEE FIGURE IX-1 FOR AN EXAMPLE.

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11. 3 NRC COMMENT:

MAKE SUBMITTALS TO NRC AS PROJECTS ARE COMPLETED.

B&WOG RESPONSE:

AS EACH PROJECT IS COMPLETED, A WORKING LEVEL MEETING WILL BE HELD AND A COPY OF THE FINAL PROJECT REPORT WILL BE PROVIDED TO THE NRC. THE UPDATES OF BAW 1919 WILL CONTAIN A

SUMMARY

. A COMPILATION OF THE VARIOUS PROJECT FINAL REPORTS WILL BE 1

INCLUDED AS APPENDICES TO BAW 1919.

Ill.1 NRC COMMENT:

WILL PRIORITIZATION PROCEDURE BE SENT TO THE STAFF; WILL IT INCLUDE RESULTS: WILL IT INCLUDE COST / BENEFIT. WILL RISK ASSESSMENT BE USED TO ASSESS THE IMPACT OF RECOMMENDED CHANGES.

B&WOG RESPONSE:

NRC WILL BE GIVEN THE GUIDELINES BY WHICH THE B&WOG PRIORITIZE THE CONCERNS IDENTIFIED AND THE RESULTS WILL BE PROVIDED. THERE WILL BE NO ATTEMPT TO USE COST / BENEFIT IN THE PRIORITIZATION GUIDELINES.' RISK ASSESSMENT MAY BE USED IN THE PRIORITIZATION OF CONCERNS BUT WILL NOT BE USED BY THE B&WOG TO ASSESS THE IMPACT OF CHANGES. RISK ASSESSMENT WILL NOT BE USED TO ASSESS THE IMPACT OF CHANGES.

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Ill.2 NRC COMMENT:

PROGRAM SHOULD INCLUDE MEASURES FOR B&WOG TO EVALUATE INDUSTRY AND UTILITY PROJECT RESULTS FOR ADEQUACY AND APPLICABILITY. WHAT ACTION WILL B&WOG TAKE IF SCHEDULES FOR UTILITY OR INDUSTRY PROJECTS CANNOT BE MODIFIED TO BE COMPATIBLE WITH B&WOG GOALS AND PRIORITIES.

B&WOG RESPONSE:

j FOR INDUSTRY PROJECTS, THE B&WOG WILL EVALUATE THE POTENTIAL GENERIC RESULTS OF THE PROJECT FOR ADEQUACY AND APPLICABILITY.

FOR UTILITY PROJECTS, THE B&WOG WILL EVALUATE THE RESULT FOR GENERIC APPLICABILITY.

FOR INDUSTRY PROJECTS, EACH CASE WILL BE EVALUATED TO DETERMINE IF THE B&WOG SHOULD TAKE UNILATERAL ACTIONS OR INCREASE THE PRESSURE ON THE INDUSTRY FOR ACTION.

FOR UTILITY PROJECTS, THE PROJECT SCHEDULE IS ESTABLISHED BY THAT UTILITY. THE B&WOG WILL TRACK THE SCHEDULE AT THE EXECUTIVE COMMITTEE LEVEL. IF SCHEDULES DEVIATE FROM B&WOG GOALS THEN THE EXECUTIVE COMMITTEE WILL IDENTIFY THIS WITH THAT UTILITY MANAGEMENT FOR RESOLUTION.

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Ill.3 NRC COMMENT:

WHAT ACTION WILL B&WOG TAKE IF THEY ARE UNABLE TO STIMUALTE INDUSTRY OR UTILITY ACTION TO ADDRESS AN IDENTIFIED CONCERN.

B&WOG RESPONSE:

FOR INDUSTRY ORGANIZATIONS, EACH CASE WILL BE EVALUATED TO DETERMINE IF THE B&WOG SHOULD TAKE UNILATERAL ACTIONS.

FOR UTILITY PROJECTS, THE EXECUTIVE COMMITTEE WILL INTERACT WITH THAT UTILITY'S MANAGEMENT.

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i Ill.4 NRC COMMENT:

WHAT MECHANISM WILL BE USED TO COMMUNICATE ACTIONS TAKEN BY UTILITIES TO THE NRC.

B&WOG RESPONSE:

BAW-1919 WILL IDENTIFY ALL STOP-TRIP RECOMMENDATIONS TO THE NRC. THE B&WOG CANNOT MAKE PLANT SPECIFIC COMMITMENTS ON ACTIONS OR RECOMMENDATION IMPLEMENTATION. THE RECOMMENDATION TRACKING SYSTEM REPORT WILL PROVIDE B&WOG MEMBER STATUS ON HOW EACH RECOMMENDATION IS PLANNED TO BE ADDRESSED. THE EXECUTIVE COMMITTEE WILL PERIODICALLY REVIEW INFORMATION COMPILED IN THE RECOMMENDATION TRACKING SYSTEM. OUTLIERS WILL BE IDENTIFIED TO THE EXECUTIVE COMMITTEE. THE NRC WILL BE PROVIDED A STATUS OF RECOMMENDATIONS DISPOSITION WHEN REQUESTED.

IV.3 NRC COMMENT:

SAFETY RELATED VALVES IN ADDITION TO THE HPI, AFW AND AFPT SUPPLY SHOULD BE INCLUDED.

B&WOG RESPONSE:

THE 1154 TASK FORCE WILL CONDUCT ITS REVIEW BASED ON l&E BULLETIN 85-03.

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V.1.a. NRC COMMENT:

WHAT TRANSIENT ANALYSES WILL BE PERFORMED?

WHY WERE THEY SELECTED?

B&WOG RESPONSE:

ANALYSES WERE SELECTED TO INCLUDE SIMPLE AND COMPOUND DISTURBANCES INVOLVING REACTIVITY, STEAM FLOW, FEED FLOW, AND RCS INVENTORY. COLLECTIVELY, THEY HAVE BEEN OBSERVED AT ALL THREE DESIGNS AND THEY EXERCISE ELEMENTS OF PLANT DESIGN THAT LEAD TO DIFFERENT TRANSIENT BEHAVIOR. A DETAILED DISCUSSION OF THIS QUESTION SHOULD TAKE PLACE AT A WORKING SESSION.

HOWEVER, AN EXAMPLE IS:

TURBINE TRIPS NORMAL STEAM RELIEF, Rx TRIP

=

NORMAL STEAM RELIEF, Rx RUNBACKS

=

EXCESSIVE STEAM RELIEF, Rx TRIPS

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V.1.b. NRC COMMENT:

HOW WILL FSAR ANALYSES BE USED?

B&WOG RESPONSE:

TO CALIBRATE SIMPLIFIED MODELS AND COMPARE DIFFERENCES IN CALCULATED SAFETY MARGINS: TO REANALYZE THE TRANSIENTS WITH DIFFERENT BOUNDARY CONDITIONS / RESPONSES TO ASSESS CHANGE IN SAFETY MARGIN, l.E., THERMAL MARGIN.

TO ASSESS THE ROUTE BY WHICH THE SAFETY MARGINS ARE ACHIEVED, AND DIFFERENCES BY DESIGN TYPE. TO ASSESS TRANSIENTS BEYOND CAPABILITIES OF SIMPLIFIED MODELS.

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V.2 NRC COMMENT:

RELEASE OF RECOMMENDATIONS FROM SENSITIVITY STUDY B&WOG RESPONSE:

THE B&WOG WILL CONSULT WITH MPR AS THE STUDY PROCEEDS IN ORDER TO ENSURE VALIDITY OF ASSUMPTIONS AND CORRECT INPUT DATA. RESULTS OF THE STUDY WILL BE REVIEWED BY A PEER PANEL OF UTILITY AND B&W ANALYSTS TO ENSURE ACCURATE ANALYSES AND VALID CONCLUSIONS. AN NRC REPRESENTATIVE WILL BE INVITED TO PARTICIPATE DURING THE PEER REVIEW. A FINAL REPORT WHICH INCLUDES RECOMMENDATIONS FOR CORRECTIVE ACTION STEMMING FROM THE STUDY WILL BE MADE AVAILABLE TO NRC.

O V.3 NRC COMMENT:

COORDINATION WITH OTHER PROJECTS.

B&W RESPONSE:

AS CURRENTLY PLANNED, THE SENSITIVITY STUDY IS A FINITE, NEAR-TERM PROJECT THAT W!LL BE COMPLETED BEFORE RESULTS FROM OTHER PROJECTS MAY BE AVAILABLE. IF CONCERNS ARE LATER IDENTIFIED THAT ARE RELEVANT TO THE SENSITIVITY STUDY RESULTS, APPROPRIATE EVALUATIONS WILL BE CARRIED OUT BY THE B&WOG. FURTHER, RESULTS OF THE SENSITIVITY STUDY WILL BE FACTORED INTO OTHER PRO.7 CTS AS APPROPRIATE. FOR EXAMPLE, THE SENSITIVITY STUDY COULD POINT OUT THE NEED FOR ADDITIONAL SYSTEM REVIEWS.

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V.4 NRC COMMENT:

USE OF SIMPLIFIED CODES B&WOG RESPONSE:

THE PURPOSE OF THE SENSITIVITY STUDY IS TO ASSESS DIFFERENCES IN PLANT DESIGN CHARACTERISTICS, NOT TO CALCULATE ABSOLUTE SYSTEM CONDITIONS. NO SPECIFIC ADDITIONAL ANALYSES WITH DETAILED SYSTEM CODES ARE CURRENTLY PLANNED. IF, HOWEVER, THE NEED FOR SUCH ANALYSES IS IDENTIFIED TO SUPPORT SIGNIFICANT RESULTS BASED ON THE SIMPLIFIED MODEL, ADDITIONAL ANALYSES WILL BE PERFORMED.

V.5 NRC COMMENT:

EVENTS BEYOND DESIGN BASIS.

B&WOG RESPONSE:

A DETAILED RESPONSE TO THIS QUESTION BELONGS IN THE WORKING MEETING. ANALYSES BEYOND THE FSAR ANALYSES ARE PART OF THE STUDY, AS THE EXAMPLE IN COMMENT V.1 SHOWS.

VARIATIONS OF FSAR ASSUMPTIONS AND BOUNDARY CONDITIONS WILL BE ANALYZED TO REFLECT OPERATING EXPERIENCE, THUS GOING BEYOND THE CLASSICAL FSAR ASSUMPTIONS.

THE SIMPLIFIED CODES WILL BE VALIDATED BY COMPARISON i

TO PLANT DATA OR MORE DETAILED CODE CALCULATIONS.

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e VI.1 NRC COMMENT:

CATEGORIZATION OF TRANSIENT REPONSE B&WOG RESPONSE:

THE THRESHOLDS BETWEEN CATEGORY "A" AND "B" TRANSIENTS WERE ESTABLISHED ON THE BASIS OF OBSERVED BEHAVIOR IN OVER 200 REACTOR TRIPS. GENERALLY, THEY REFLECT EXPECTED RESPONSE WITHOUT SYSTEM MALFUNCTION.

THE DISTINCTION BETWEEN CATEGORY "B" AND "C" EVENTS ARE BASED PRIMARILY ON THE ATOG GUIDEllNES AND l

SUPPORTING ANALYSES AND IN MANY CASES ARE BASED ON THEIR THRESHOLDS FOR OPERATOR ACTION.

j THE CATEGORIZATION PROCESS WAS DEVELOPED WITH A FOCUS ON THE PRIMARY SYSTEM. THE EFFECTS OF SECONDARY SYSTEM PROBLEMS ARE ASSESSED IN LIGHT OF RESULTANT CHANGES IN THE PRIMARY. THUS, DRYOUT OF A SINGLE STEAM GENERATOR MAY BE EITHER A CATEGORY "B" OR "C" EVENT, DEPENDING ON OTHER SYSTEM RESPONSE.

LOSS OF PRESSURIZER LEVEL AS POSTULATED COULD BE EITHER CATEGORY "B" OR "C". THE CONCURRENT EFFECTS ON THE OTHER FATEGORIZATION PARAMETERS MUST BE EVALUATED TO DETERMINE THE OVERALL CATEGORIZATION OF THE TRANSIENT. A MORE DETAILED DISCUSSION OF THESE QUESTIONS SHOULD BE HELD AT THE WORKING MEETING.

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l VI.2 NRC COMMENT:

RELEASE OF TAP REPORTS TO NRC

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B&WOG RESPONSE:

THE TRANSIENT ASSESSMENT COMMITTEE IS READY TO MEET WITH THE STAFF TO DISCUSS SPECIFIC EVENTS AND PROVIDE ALL INFORMATION NEEDED FOR COMPLETE UNDERSTANDING.

l IV.2 NRC COMMENT:

CONCERN THAT PROJECT RECOMMENDATIONS TO ELIMINATE AUTOMATIC SYSTEM PROTECTION MAY PLACE UNNECESSARY BURDEN ON THE OPERATORS.

B&WOG RESPONSE:

FOR THE EXAMPLES CITED (BTU LIMITS, MFW PUMP TRIP ON LOW NPSH) IMMEDIATE OPERATOR ACTION IS NOT NECESSARY.

THE IMPACT ON THE OPERATOR FROM REMOVAL OF AUTOMATIC SYSTEM PROTECTION IS/WILL BE INCORPORATED INTO THE DECISION TO CHANGE THE SYSTEM. IN GENERAL, OPERATOR'S FAILURE TO TAKE THE ACTIONS PREVIOUSLY PERFORMED BY THE AUTOMATIC SYSTEM PROTECTIONS ARE ACCOUNTED FOR IN THE PLANT SPECIFIC SYMPTOM BASED EMERGENCY OPERATING PROCEDURES.

4 I

Vll.1 NRC COMMENT:

STOP TRIP PROGRAM DOES NOT HAVE A BROAD COMPREHENSIVE AND SYSTEMATIC EVALAUTION OF HUMAN l

FACTORS ASPECTS FOR B&W OPERATING REACTOR EVENTS.

B&WOG RESPONSE:

ALL B&W UTILITIES HAVE COMPLETED OR ARE IN THE PROCESS OF MODIFICATIONS OF CONTROL ROOM INSTRUMENTATION IN RESPONSETO NUREG-0737 ACTIVITIES.

THE SYSTEMATIC REVIEW OF PAST TRANSIENTS IS BEING DONE IN THE TAP DATA REFINED SORT PROJECT. THE OUTPUT OF THIS WILL BE A LISTING OF HUMAN ACTIONS AND ERRORS WHICH HAVE CONTRIBUTED TO PLANT TRANSIENTS. THIS LIST WILL BE SENT TO THE OPERATOR SUPPORT COMMITTEE FOR DISPOSITION AND POTENTIAL l

RECOMMENDATIONS FOR PLANT IMPROVEMENTS IN THE HUMAN FACTORS AREAS. SENSITIVITY STUDY, RISK l

ASSESSMENT AND THE OPERATOR / MAINTENANCE INTERVIEW ACTIVITIES COULD ALSO PROVIDE HUMAN FACTORS INPUT TO THIS PROGRAM.

1

Vil.2 NRC COMMENT:

COMPLETE, ACCURATE AND VAllD INTERVIEWS OF OPERATIONS / MAINTENANCE PERSONNEL MAY NOT BE ACHIEVABLE WITH THE PROCESS DESCRIBED.

B&WOG RESPONSE:

THIS TASK WAS INTENDED TO IDENTIFY AREAS OF CONCERN BY THE OPERATIONS AND MAINTENANCE PERSONNEL WHICH COULD BE FACTORED INTO THE OVERALL STOP-TRIP PROGRAM. IT WAS NOT INTENDED TO BE A FORMALIZED AUDITABLE ASSESSMENT OF OPERATIONAL AND l

MAINTENANCE PROGRAMS. A WORKING MEETING WILL BE HELD WITH THE NRC AT THE COMPLETION OF THE INTERVIEWS TO DISCUSS THE FINDINGS.

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XI.3 NRC COMMENT:

B&WOG PROCEDURES REVIEW WILL NOT RESPOND TO THE LESSONS OF THE RANCHO SECO EVENT.

I B&WOG RESPONSE:

1 THE REVIEW OF THE PLANT SPECIFIC PROCEDURES AND THE TECHNICAL BASES DOCUMENT IN LIGHT OF THE RANCHO SECO EVENT HAS BEEN PERFORMED BY THE OPERATOR SUPPORT COMMITTEE IN RESPONSE TO AN RRG COMMITTMENT. THE RECOMMENDATIONS FROM THE REPORT WILL BE FACTORED INTO THE B&WOG RECOMMENDATION TRACKING SYSTEM. FURTHER, THE OSC IS INITIATING ACTIVITIES TO PROVIDE A COMPREHENSIVE REVIEW OF PLANT OPERATING PROCEDURES TO ADDRESS THE ISSUES OF IMPLEMENTING SYMPTOM BASED PHILOSOPHY AND LESSONS LEARNED.

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XI.4 NRC COMMENT:

PROVIDE A PROGRAM DESCRIPTION FOR ASSESSING THE PROCEDURES AND OPERATOR TRAINING FOR THE GUIDANCE PROVIDED IN THE TBD.

B&WOG RESPONSE:

THE TBD AND THE PLANT SPECIFIC ATOGS PROVIDE SUFFICIENT GUIDANCE FOR THE INDIVIDUAL LICENSEE TO DEVELOP THEIR OPERATOR TRAINING PROGRAMS AND EMERGENCY PROCEDURES. SPECIFIC QUESTIONS REGARDING THEIR ADEQUACY SHOULD BE DISCUSSED WITH THE INDIVIDUAL LICENSEE. THE TBD, WHICH PROVIDES DETAILED INFORMATION ON THE GUIDANCE REQUESTED, HAS BEEN SUBMITTED TO THE NRC.

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e Vill.1 NRC COMMENT INCORPORATE CATEGORY "A" AND "B" EVENTS IN THE ASSESSMENT OF RISK SIGNIFICANCE ALONG WITH THE CATEGORY "C" EVENTS. PRE-TAP EVENTS SHOULD BE INCLUDED.

B&WOG RESPONSE CATEGORY "A" AND "B" EVENTS ARE CONSIDERED IN THE B&WOG PLAN VIA THE COMPARISON OF INITIATING EVENTS FROM OPERATING EXPERIENCE TO PRA INITIATING EVENTS, AS DISCUSSED IN THE APRIL 30 MEETING. CATEGORY "C" 4

EVENTS ARE INITIATING EVENTS COUPLED WITH SUBSEQUENT FAILURES AND THE RISK SIGNIFICANCE OF THESE EVENTS WILL BE SPECIFICALLY ADDRESSED. THE THREE PRE-TAP EVENTS (RANCHO SECO " LIGHT BULB" EVENT, DAVIS BESSE PRECURSOR TO TMI-2, AND TMI-2) WILL NOT BE INCLUDED SINCE:

1 1.

MAJOR MODIFICATIONS TO B&W PLANTS HAVE ALREADY OCCURRED AS A RESULT OF THESE EVENTS, OR 2.

THESE SEQUENCES ARE IN THE PRAs, AND IF IMPORTANT, WILL BE LISTED AS CONTRIBUTORS.

l PRE-TAP CATEGORY "A" AND "B" EVENTS WILL NOT BE j

INCLUDED SINCE THE CATEGORY "A" AND "B" EVENTS (1980-1985) WILL PROVIDE AN ADEQUATE INITIATING EVENT DATA BASE.

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Vill.2 NRC COMMENT:

SPECIFICALLY ADDRESS THE TREATMENT OF HUMAN ERROR MODELING IN THE PRAs WITH REGARD TO OBSERVED i

OPERATOR ERROR FREQUENCIES AT B&W FACILITIES.

B_&WOG RESPONSE:

1 THE OCONEE AND CRYSTAL RIVER-3 PRAs USED STATE-OF-THE-ART HUMAN RELIABILITY ANALYSES INCORPORATING PLANT-SPECIFIC PROCEDURES, OPERATOR INTERVIEWS, AND TRAINING. DATA TO PRODUCE SPECIFIC OBSERVED OPERATOR FAILURE RATES D.OES NOT EXIST FOR ANY VENDOR.

e Vill.3 NRC COMMENT:

EXPAND SCOPE OF RISK ASSESSMENT TO INCLUDE CATEGORY "A" AND "B" EVENTS. EVALUATE PRA APPLICABILITY WITH REGARD TO OBSERVED TRANSIENTS, AND PROVIDE QUANTITATIVE INSIGHTS BASED ON THE ANALYSIS OF THESE TRANSIENTS.

.B&WOG RESPONSE:

WITH THE QUALIFICATION OF THE B&WOG RESPONSE TO Vlli.1 REGARDING"A" AND"B" EVENTS,THESE THINGS WILL BE DONE, AS DESCRIBED IN THE APRIL 30 MEETING.

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p Vill.4 NRC COMMENT:

PROVIDE ADDITIONAL INFORMATION (TAP REPORTS) FOR CATEGORY "B" AND "C" EVENTS.

B&WOG RESPONSE:

THESE WILL NOT BE PART OF THE RISK ASSESSMENT SUBMITTAL. SEE VI.2.

Vill.5 NRC COMMENT:

PROVIDE CRYSTAL RIVER-3 PRA TO NRC.

B&WOG RESPONSE:

FPC INTENDS TO SUBMIT THE CR-3 PRA TO NRC WHEN INTERNAL REVIEW AND FINAL DOCUMENTATION IS COMPLETE. THE FINAL REPORT IS EXPECTED TO BE FINISHED PRIOR TO SEPTEMBER 1,1986.

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VI.3 NRC COMMENT:

UNCLEAR ON HOW MANAGEMENT CONSIDERATIONS WILL BE ADDRESSED BY THE OPERATING EXPERIENCE REVIEW.

B&WOG RESPONSE:

MANAGEMENT ISSUES ARE BEYOND THE IDENTIFIED SCOPE OF THE PROGRAM. THE INDUSTRY-WIDE PROGRAMS AND INDIVIDUAL UTILITIES ARE THE PROPER FORUM FOR THESE i

ISSUES.

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IX.1-3 NRC COMMENT:

i THE ICS/NNI, AFW/EFW, MFW AND SECONDARY PLANT REllEF SYSTEM REVIEWS WERE IN VARIOUS STATES OF DEFINITION AT THE TIME THE BAW-1919 MAY 15,1986 SUBMITTAL WAS MADE. FURTHER INFORMATION ON SEVERAL OF THESE PROGRAMS IS REQUIRED FOR THE NRC TO PROVIDE MORE SPECIFIC COMMENTS.

B&WOG RESPONSE:

THE B&WOG BELIEVES THE SYSTEM REVIEWS BEING PERFORMED WILL ADDRESS THE NRC QUESTIONS PRESENTED TO DATE. THE STATUS OF THE SYSTEM REVIEW IS AS FOLLOWS:

ICS/NNI:

WE ARE AWAITING THE NRC COMMENTS ON THE INFORMATION PROVIDED AT THE MAY 21,1986 MEETING.

MFW:

THE B&WOG 1154TF SUBMITTAL IN JULY 1986 WILL PROVIDE RESULTS OF THE l

PROGRAM.

AFW/EFW: THE 1154TF SUBMITTAL WILL ADDRESS AFW/EFW ISSUES IDENTIFIED IN NUREG 1154 AND AN UPDATE ON THE AFW/EFW SYSTEM EVALUATION WILL BE PROVIDED.

SECONDARY PLANT RELIEF SYSTEM:

THIS REVIEW IS IN PROGRESS AND THE FINAL REPORT IS SCHEDULED FOR COMPLETION IN OCTOBER 1986.

WHEN MORE DETAILS ARE FINALIZED WE ARE WILLING TO MEET WITH THE NRC TO DISCUSS THE PROGRAM.

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XI.1 NRC COMMENT:

THE PROGRAM HAS A LESS THAN COMPLETE APPROACH TO TRAINING, MAINTENANCE AND MANAGEMENT RELATED ISSUES.

s B&WOG RESPONSE:

THE PROGRAM DOES INCLUDE TRAINING AND MAINTENANCE AS RELATED TO THE SPECIFIC AREAS BEING ADDRESSED.

MANAGEMENT-RELATED ISSUES ARE BEYOND THE SCOPE OF THIS PROGRAM. B&WOG EXECUTIVE COMMITTEE IS INTIMATELY INVOLVED IN ADDRESSING THIS TYPE OF ISSUE THROUGH THEIR PARTICIPATION IN INPO AND NUMARC.

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P XI.2 NRC COMMENT:

SEND SPECIFIC COMPARISONS ON CONFIGURATIONS AT EACH PLANT TO THE NRC.

B&WOG RESPONSE:

SYSTEM COMPARISON INFORMATION WILL BE PROVIDED TO THE NRC WHEN IT IS COMPLETED IN THE NORMAL COURSE OF PROJECTS FOR THOSE SYSTEMS FOR WHICH IT IS CONDUCTED.

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