ML18047A330

Comments on SEP Integrated Plant Safety Assessment,Per Request.Sep Program Appears Well Organized

ML18047A330
Person / Time
Site:	Palisades
Issue date:	04/28/1982
From:	ZUDANS Z FRANKLIN INSTITUTE
To:	RUSSELL W NRC
Shared Package
ML18047A285	List: ML18047A284 ML18047A327 ML18047A328 ML18047A329 ML18047A330
References
RTR-NUREG-0820, RTR-NUREG-820 NUDOCS 8205190077
Download: ML18047A330 (7)

Text

" v Research Center A Division of The Frankiin Institute Z. ZUDANS, PH.D. Senior Vice President and Chief Operating Officer Mr. W. Russell SEP Project Manager/Technical Coordinator U.S. Nuclear Regulatory Commission Washington, D.C. 20555 April 28, 1982

Subject:

Review of SEP Integrated Plant Safety Assessment Report

References:

1) SECY 76-545 2) SECY 77-561 3) NUR.EG-0820, Integrated Plant Safety Assessment, Systematic Evaluation Program -Palisades Plant, Consumers Power Company, Docket No. 50-255

Dear Mr. Russell:

In accordance with your request I have reviewed the Palisades SEP program and offer the following comments.

At present, the SEP Program appears to be well organized and well managed. The referenced documents sum..marizing Palisades SEP review provide a sive historical review of the entire SEP program since its inception in February, 1978 by the NRG. Significant amount of thought and effort has been pu.t in development of the procedure for SEP. The procedure as shown on Figures 1 to 3 was constructed from the Referenced Documents and from various personal conversations with the SEP Program Staff. As it can be seen from Figures 1 to 3, t)-1e procedure is generally well defined and at the completion should lead to the satisfaction of the Commission's goals for the SEP program. In order to make the Integrated Assessment more responsive to reviewers related human factors, procedure blocks following item (1) (circled) should be provided with more specific guidelines as to the interfacing between SEP, USI, TMI Action Plan, and other personnel involved in the remaining steps of the procedure.

This implies that the Final Integrated Assessment Report (FIAR) should be a joint effort of SEP, USI, Tifl Action Plan, and others. Details in NUREG-0820 show that such interaction took place for topics of concern to various programs (supplement to NUREG-0820 for resolution of USI, TI!I Action Plan, and other items, for example).

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• i ! ' . ., Mr. W. Russell USNRC *e . -... *'.." ... :. April 28, 1982 SEP review for Palisades, NUREG-0820, is comprehensive and engineering arguments are sound. Following this procedure, Figure 1, 24 topics exit nt (1) identified -as gene:i:ic items related to USI and Ž1 Acti_on Plan_, 23 to;::ics exit at (2) because these are not applicable to Palisades and 90 topics :re"-':::i (3) where the actual review of SEP topics for Palisades begins: It is nc: identified in 11.TREG-0820 how many topics were handled by Method 1 and how :-:-CJ.ny by Method 2. However, at the step A (Disposition of Topics), all but 31 were left for backfit candidacy, the remaining 59 having been put in one of the categories 1 to 3. None of the topics fell in the category 4 (i.e., safety significant departure), requiring prompt action. I find that technical arguments leading to distribution of topics to various categories are acceptable.

With respect to Topics in the group of Integrated Assessment, Sections 4.1 to 4.31 of NUREG-0820, represent the Draft Integrated Assessment Report (DIAR). Since Licensee response and resolution for most Integrated Assessment Topics is already contained in NUREG-0820, it also represents Final Integrated ment Report (FIAR). However, there is no integration of 24 USI and TMI Action Plan SEP Topics until supplement to NUREG-0820 is issued. This Supplement will also form the basis for conversion from POL to FTOL. In other words, it appears that for Palisades the procedure shown in Figures 1 to 3 was not followed strictly, or stated otherwise, actual Palisades review procedure indicates that plant and licensee specific circumstances may require flexibility in the procedure itself. With respect to the specific topics reviewed in NUREG-0820, I offer the following additional comments.

For 14 of 31 topics slated for Integrated Assessment, risk assessment by Sandia (SAI) (using Calvert Cliffs unreleased PRA) provided useful insight in relative value of backfits, i.e., it provided logical support for engineering judgment in complicate situations.

Similarly, an extensive use of the plant operating experience in support of engineering judgment is probably the best decision made by the SEP staff. This practice should be followed in the review of other SEP plants. My overall impression of Palisades SEP Review is that considerably more sound engineering effort has been put in Palisades SEP review, in particular in terms of proper understanding of design, processes and consequences involved, than maybe normally done during regular licensing review process, (SEP Topic list covers essentially all safety related design aspect of a nuclear power plant). The process however, is not complete until all open items are resolved in an integrated manner.

I I. .. , Mr. W. Russell USNRC *e April 28, 1982 Topic V-11.B is listed in Section 3.1 (final list of 90 topics for :';_lisades), but it is not referred to in Sections 3.2 (topics meeting current c:::.= ign criteria), 3. 3 (meets current criteria because of mo.dificat-ions implemented by the licensee), or Section 4.1 (Integrated Assessment Topics). I believe the substance of Topic V-11.B is addressed in Section 4.16. I am particularly impressed with the discussion of high and low pressure fluid systems interaction of Sections 4.16 and 4.17. Of the proposed tive alternatives, Staff's alternative 2 is the best choice in my opinion. Section 4.7, Topic III-3.C discusses inspection program for water control system structures.

I find the five year inspection frequency proposed by the licensee not technically sound (icing season comes once a year). With respect to Topic III-5.4 (Section 4.9) I am not a strong believer of rigid piping systems. Accordingly, I suggest that the number of pipe wnip supports (for postulated 200 pipe break location) should be kept at the minimum. Section 4.11.1, Topic III-7.A, brings up an important point on need for monitoring forces in. individual tendons rather than the average of all tendon forces. Relative to the concrete crack inspection at tendon anchorages, one must note that tendons are always under* prestress load which is the bulk of the load ever seen by the tendon. If the tendons are lifted (for tendon force verification), load on anchorages may exceed the load applied due to pressure used for leak rate testing. Accordingly, anchorage concrete inspection should be done at the time when tendons.are lifted for force testing (if they are lifted). Relative to Topic VI-4, I like to point out that the internal pressure load on piping is less significant than the structural loads imposed by geometric constraints of attachment points, I agree with the staff that no backfitting is required.

Topic IX-3, flooding of intake structures, licensee proposes alarms in control room to indicate occurrence of flooding, presumably to give operator time to prevent inundation of service water pumps. If the flooding comes in a form of a 13 ft wave driven by seiche, alarm will not help to prevent water intake structure flooding nor can the operator do much to stop the wave. For Topic IX-5, the Licensee has proposed (by test or by analysis) to demonstrate the operability of AFW with loss of ventilation in pump room. I doubt that anlaysis can predict realistically the time AFW will remain operable under such conditions.

It might be possible to run a relatively short duration test, observe in room and equipment and make an tion from the test results.

Mr. W. Russell USNRC ">.: .*. ---**-*----* *. "" .***. *** *** . *.. ...., ---****-*-***-

• -: ..*...

.. April 28, 1982 Main steam line break in Containment (Topic XV-2) with postulated single failure is _clearly an issue important to risk. In general, NUREG-0820 provides comprehensive discussion of definition, safety objectives and status of all SEP topics. Adequate list of references is provided for each topic for detail study and for a complete documentation of the decision process. I am well impressed with the work done by the staff on Palisades SEP review. Very truly yours, I 1 uLr _,,,, -L--c.J: _ .r \Zenons Zudans ces Senior Vice President encls. Figs. 1 to 3 . --****-**

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SEP PHASE I IDENTIFICATION OF SAFETY ISSUES TO BE ADDRESSED, COMPLETED IN l97B AND RESULTED IN 137 SEP TOPICS DEFINED FOR REVIEW ... . . : * ... *-* .** .. " ... **-.. . ... . . . .

OBJECTIVES SYSTEMATIC EVALUATION PROGRAM

l. IDENTIFICATION, UNDERSTANDING, DOCUMENTATION OF EXISTING SAFETY MARGINS (BASED ON CURRENT CRITERIA).

RATIONALE FOR ACCEPTING DEPARTURES.

2. INTEGRATED AND BALANCED BACKFITTING DECISIONS AND RATIONALE.

3. EARLY IDENTIFICATION AND RESOLUTION OF SIGNIFICANT SAFETY DEFICIENCIES.

4. ASSESSMENT OF SAFETY ADEQUACY OF DESIGN AND OPERATION OF NPP. 5. EFFICIENT USE OF NRC AND INDUSTRY RESOURCES.

6. PROVIDE BASIS (FIAR) FOR POL TO FTOL CONVERSION.

SEP PHASE II r-------------i TOPIC SORTING REVIEW OF THE 11 OLDEST PLANTS ; PLANT POL FIL POWER TYPE SCHEDULE DRESDEN l* l 959 1960 200 BWR YANKEE ROWE 1960 1961 175 PWR 1983 BIG ROCK POINT 1962 1964 72 BWR 1983 SAN ONOFRE l 1967 450 PWR 1983 HADDAM NECK 1967 1974 575 PWR 1983 LACROSSE 1967 50 BWR 1983 OYSTER CREEK 1969 650 BWR 1982 GINNA 1969 490 PWR 1982 DRESDEN 2 1969 809 BWR 1982 MILLSTONE l 1970 690 BWR 1982 PALISADES 1971 821 PWR 1982 *DRESDEN 1 has been deferred since unit is shutdown through 1986. fi.gure l TOPICS REVIEWED GENERICALLY UNDER US! OR Tiii ACTION PLAN TOPICS DO NOT APPLY TO SPECIFIC PLANT UNDER REVIEW TOPICS REVIEWED UNDER SEP FOR THIS PLANT REVIEW METHOD l NRF STAFF REVIEWS TOPIC WITHOUT LICENSEE SAR INFORMATION SOURCES e FSAR e OP LICENSE AMENDMENTS e TECH SPECS eP&l.D. e GENERAL ARRANGEMENT DRGS

• EMERGENCY PROCEDURES e OPERATING PROCEDURES e DOCKET CORRESPONDENCE e lOCFR, SRP, BTP, REG. G PROCEDURE LEADING TO DRAFT SER POSTPONE FOR INTEGRATED ASSESSMENT DELETE WITH RATIONALE METHOD_£ LICENSEE SUBMITS SAR PROCEDURE LEADING TO FINAL SER i I I I I ;I I i I. I I l ' ** :._ ** * , .**. * *.* **** '**** *'h *--h** METHOD l PROCEDURE LEADING TO DRAFT SER NRC CONTRACTOR REVIEW REQUEST FOR ADD'L INFORMATION, RF! RF! RECEIVED CONTRACTOR REVIEWS AND PREPARES TECHNICAL EVALUATION REPORT (TER) NRC STAFF REVIEW REQUEST FOR ADD'L ltffORMA TION, RF I RF! RECEIVED NRC BRANCH REVIEW SEP BRANCH PREPARES .__ ____ ___,., DRAFT SER. INTERNAL REVIEW DRAFT SER (OSER) SEND TO LICENSEE DRAFT DISPOSITION OF TOPICS, See LICENSEE SUBMITS

• COMMENTS WHICH ADDRESS FACTUAL ACCURACY AND PROPOSES ALTERNATIVES TO RESOLUTION OF DIFFERENCES NO RESPONSE FROM LICENSEE LICENSEE HAS NO COMMENTS, CONSIDERS OSER CORRECT .:-. NRC CONTRACTOR AUDIT OF SAR METHOD 2 PROCEDURE LEADING TO FINAL SER LICENSEE PREPARES SAR NRC BRANCH AUDIT OF SAR REQUEST FOR ADD'L INFORMATION, RF! REQUEST FOR ADD'L INFORMATION, RF! RF! RECEIVED CONTRACTOR PREPARES TER RF! RECEIVED NRC BRANCll PREPARES SER FINAL SER SEND TO LICENSEE INCLUDE DIAR) ------------'FINAL DISPOSITION OF TOPICS l. TOPIC COMPLETED WITHOUT MODIFICATIONS TO DESIGN AND/OR PROCEDURES.

PLANT CONSISTENT WITH CURRENT CRITERIA.

2. TOPIC COMPLETED WITHOUT MODIFICATIONS TO DESIGN AND/OR ;. mo OF PROCEDURE PROCEDURES.

PLANT DESIGN EQUIVALENT TO DESIGN BASED 1--------0N CURRENT CRITERIA.

Figure 2 3. TOPIC COMPLETED BY STAFFS ACCEPTANCE OF LICENSEES IMPLEMENTED AND/OR PROPOSED DESIGN AND/OR PROCEDURAL CHANGES. 4. TOPIC NOT COMPLETED, PLANT NOT CONSISTENT WITH CURRENT LICENSING CRITERIA, SAFETY SIGNIFICANT DEPARTURE

-PROMPT ACTION REQUIRED.

5. TOPIC NOT COMPLETED, PLANT NOT CONSISTENT CURRENT LICENSING CRITERIA, RESOLUTION DEFERRED TO INTEGRATED PLANT SAFETY ASSESSMENT.

SEP INTEGRATED ASSESSMENT I PROCEDURE PLANT MODIFICATION IMPLEMENTED, REVIEWED, APPROVED :I f r !

i I I I *1 I! '1: ' *'.! i < .... .... '., . ; .. ,, .... DEFINITION OF !AT* INTEGRATED ASSESSMENT TEAM (IAT): l. INTEGRATED ASSESSMENT PROJECT MANAGER, SEP BRANCH , *., *** ** ,., ** .:,;.,_,.,!, ,. w,

• ' _:_,._,, .. 9 I SEP INTEGRATED J l ASSESSMENT PROCEDURE

! !AT PROJECT MANAGER PREPARES LIST OF UNRESOLVED DIFFERENCES:

e REVIEW OF EACH SEP TOPIC 2. OPERATING REACTOR PROJECT MANAGER, OR BRANCH NO. 5 , -e LIST All DEVIATIONS FROM CURRENT LIC. CRITERIA e SHORT NARRATIVE ON DEVIATIONS

3. TECHNICAL REVIEWERS

4. OFFICE OF l&E REPRESENTATIVE PRIORITY RANKING SYSTEM l. SAFETY SIGNIFICANCE High l 00 Medium 50 Low 0 2. TYPE OF IMPROVEMENT Improves operational safety (i.e. human element) 20 Improves system design to prevent accidents 20 Improves system design to mitigate accidents 0 3. UTILIZATION OF RESOURCES A. NRC staff resources required to implement Sma 11 (less than 0. l PSY) 20 Medium (O. l to 0.4 PSY) 10 Large (0.5 PSY or greater) 0 B. Licensee manpower requirements (i.e., increase in staffing)

Small (l staff or less) 20 Medium (2-5 staff) 10 Large (6 or more) 0 C. Licensee capital cost improvement Sma 11 (less than $1. 0 M) Medium ($1.0 M to $5 M) Large (greater than $5 M) D. Timing of improvement i.e., how soon the safety improvement wll l be operational Short-term (within one year) Near-term (within two years) Long-term (more than two years) 20 10 0 20 10 0 PROVIDE ABOVE TO !AT MEMBERS FOR REVIEW l !AT MEMBERS !NOIV!DUALLY REVIEW LIST OF UNRESOLVED DIFFERENCES, MEET AND RANK EACH DEVIATION ACCORDING TO

• SAFETY SIGNIFICANCE OPTIONAL e TYPE OF IMPROVEMENT (OPERATION, PREVENTION, MITIGATION)

• COST TO IMPLEMENT (BOTH NRC AND LICENSEE) e PERSONNEL RADIATION EXPOSURE, WHILE l..& -USE -IMPLEMENTING APPROACH -;usEPO!NT SYSTEM (SEE PRIORITY RANKING SYSTEM) e USE PRA IF AVAILABLE e DOCUMENT BASIS FOR EACH RECOMMENDATION l

DRAFT INTEGRATED ASSESSMENT REPORT (DIAR). THIS REPORT IDENTIFIES CANDIDATE ITEMS FOR BACKFITTING.

SUBMIT DIAR TO LICENSEE FOR REVIEW AND COMMENT I (DIAR MAY BE A PART OF FINAL SER) TOPICS REVIEWED k) GENERICALLY UNDER l US! AND TIH ACTION PLAN Figure 3 LICENSEE PROPOSES PRELIMINARY DESIGN AND/OR PROCEDURE CHANGES BY CONSIDERING:

SEP TOPIC CANDIDATE ITEMS FOR BACKFITTING IDENTIFIED US! ITEMS, AND IDENTIFIED TM! ACTION PLAN ITEMS. COMMON FIXES AND BACKFITT!NG INTEGRATION AMONG ALL ITEMS WILL BE IDENTIFIED IN LICENSEES PROPOSAL.

NRC STAFF REV! EWS LICENSEES PROPOSED BACKFITTING PLAN. REVIEW IS PERFORMED BY SEP AND OTHER BRANCUES AS REQUIRED BY US! AND TM! TOPICS. CONTRACTORS MAY BE USED. ADDITIONAL INFORMATION REQUESTED IF REQUIRED, BY NRC. ADDITIONAL INFORMATION SUPPLIED BY LICENSEE NRC PREPARES FINAL INTEGRATED ASSESSMENT REPORT ( F!AR) NRC INTERNAL REVIEW FIAR SEND TO COMMISSION FOR APPROVAL F!AR SEND TO LICENSEE FOR BACKFITT!NG AS PER l OCFR 50.5g END OF PROGRAM FIAR PROVIDES BASES FOR CONVERSION FROM POL TO FTOL CONVERSION FROM POL TO fTOL

Reference:

May 15, 1981 letter Ll.G. Eisenhut to 11.H. Denton