ML20213E031

Forwards SER Input Re Operating & Maint Procedures,Including TMI Items 1.C.1,1.C.7 & 1.C.8

ML20213E031
Person / Time
Site:	Columbia
Issue date:	02/04/1982
From:	Thompson H Office of Nuclear Reactor Regulation
To:	Tedesco R Office of Nuclear Reactor Regulation
References
CON-WNP-0453, CON-WNP-453, CON-WPN-453, TASK-1.C.1, TASK-1.C.7, TASK-1.C.8, TASK-TM NUDOCS 8203090580
Download: ML20213E031 (10)

Text

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I ISTRIBUTION e g< Docket 50-397)

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Docket No. 50-397 HLThompson JJKramer LPCrocker FEB 0 4 682 DLziemann HBClayton ItEMORANDUM FOR: Robert L. Tedesco, Assistant Director LPhillips for Licensing ,

Division of Licensing , , , cy , , s

( . -g, i e FROM: Hugh L. Thompson, Jr., Acting Director os p; 2 *._*Q(.9 Division of Human Factors Safety [

SUBJECT:

SAFETY EVALUATION REPORT INPUT: $ Y-WASHINGTON PUBLIC POWER SUPPLY SYSTEM, UNIT 2 FE3;3 22s $

OPERATING AND MAINTENANCE PROCEDURES AND C

.dc:mEfic[@gta ANTICIPATED TRANSIENTS WITHOUT SCRAM h A /f I #-

Enclosed are our SER inputs for Section 13.5.2, Operating and Maintenance -

Procedures, which include consideration of the 1NI Task Action Plan (TAP)

Items I.C.1 - Short-Term Accident Analysis and Procedures Revision, I.C.7 -

NSSS Vendor Review of Procedures and I.C.8 - Pilot Monitoring of Selected Emergency Procedures for Near-Term Operating License Applicants and Section 15.8 - Anticipated Transients Without Scram (ATWS).

Emergency operating procedures based on the reanalysis of transients and accidents developed in response to TAP Item I.C.1, as clarified in NUREG-0737, will be developed by the applicant in lieu of interim procedures developed from the Short-Term Accident Analysis. Therefore, the program for Pilot Monitoring of Emergency Procedures for NT0L's as required by TAP Item I.C.8 will not be performed for WNP-2. This approach is acceptable to the Procedures and Test Review Branch (PTRB).

However, NRC approved Technical Guidelines must be available in time for the applicant to prepare and implement emergency operating procedures prior to fuel load. PTRB will r.eview the applicant's program prior to issuance of the operating license.

This review is being performed by Brent Clayton, Principal Operational A Safety Engineer (X24582), of the Procedures and Test Review Branch.

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SAFETY EVALUATION REPORT INPUT WASHINGTON PUBLIC POWER SUPPLY SYSTEM, UNIT 2 OPERATING AND MAINTENANCE PROCEDURES AND ANTICIPATED TRANSIENTS WITHOUT SCRAM 13.5.2 OPERATING AND MAINTENANCE PROCEDURES A. General (h' A review has been conducted of the applicant's plan for development and implementation of operating and maintenance procedures. The review was conducted to determine the adequacy of the applicant's program for assuring that routine operatings off-normale and emergency activities are conducted in a safe manner. The following description and evaluation are based on information contained in the applicant's FSARi the applicant's response to NRC TMI Action Plan Items (NUREG-0660 and NUREG-0737), and supplemental information obtained during the review.

f In determining the acceptability of the applicant's programe the criteria of NUREG-0800, Standard Review Plane Section 13.5.3 were used. The review consisted of an evaluation of (1) the applicant's procedure classification system for procedures that are performed by licensed operators in the control room and the classification system for other

1 I operating and maintenance procedures; (2) the applicant's plan for completion of operating and maintenance procedures during the initial plant testing phase to allow for correction prior to fuel loading; (3) the applicant's program for compliance with the guidance contained in Regulatory Guide 1.33, Rev. 2, March 1978 regarding the minimum procedural requirements for safety related operations; (4) compliance with the guidance contained in ANSI N18.7-1976/ANS 3.2; and (5) the applicant's program for compliance with Task Action Plan (NUREG-0660)

Item I.C.1, " Guidance for the Evaluation and Development of Procedures for Transients and Accidents", for the development of Emergency Operating Procedure Guidelines.

Additionally, the applicant's program for compliance with Item I.C.1 of NUREG-0737 for the development of Emergency Operating Procedures will be reviewed and reported in a supplement to this Safety Evaluation Report.

l B. Operating and Maintenance Procedure Program i

d The applicant has committed in FSAR Chapter 17e Quality of*h I Assurance, to a program in which all activities are to j

be conducted in accordance with detailed written and approved procedures meeting the requirements of Regulatory Guide 1.33r Rev. 2e March 1978, " Quality Assurance Program l Requirements (Operation)", and ANSI N18.7-1976/ANS 3.2.

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jhTheapplicant uses the following categories of procedures for those operations performed by licensed operators in the control room:

System Operations (Including Radioactive Waste Systems)

General Operation Abnormal Conditions (Including Annunciator Response) -

Emergencies Surveillance Other procedures include the following areas:

Fuel Handling and Refueling Activities Operatie41 and Engineering Tests Chemistry Health Physics Maintenance Nuclear Performance Evaluation Emergency Plan Implementation

,, Security Plan Implementation Our review disclosed that the applicant's program for use of operating and maintenance procedures meets the relevant requirements of 10 CFR 34, and is consistent with the guidance provided in Regulatory Guide 1.33 and ANSI N18.7-1976/ANS 3.2. Thereforer we conclude that the applicant's program is acceptable.

i C. Reanalysis of Transients and Accidents; Development of Emergency Operating Procedures

(' / In letters of September 13 and 27, October 10 and 30, and t

i November 9, 1979, the Office of Nuclear Reactor Regulation required licensees of operating plants, applicants for operating Licenses and licensees of plants under construction to perform analyses of transients and accidents, prepare emergency operating procedure guidelinese upgrade emergency operating procedurese and to conduct operator retraining.

Emergency operating procedures are required to be consistent with the actions necessary to cope with the transients and accidents analyzed. Analyses of transients and accidents were to be completed in early 1980 and implementation of procedures and retraining were to be completed three months after emergency operating procedure guidelines were established; howevere some difficulty in completing these requirements has been experienced. Clarification l of the scope of the task and appropriate schedule revisions f

were vecluded in Item I.C.1 of NUREG-0737.

In a submittal dated June 30, 1980s the BWR Owners' Group provided a draft of generic Emergency Operating Procedure 1

Guidelines for Boiling Water Reactors. The guidelines were developed to comply with Task- Action Plan Item I . C .1 (3 ) as clarified by NUREG-0737 and incorporated i

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_5-i the requirements for short-term reanalysis of small break loss-of-coolant accidents and inadequate. core cooling (Task Action Plan Items I.C.1(1) and I . C .1 (2 ) ) . In a letter dated October 21, 1980s from D. G. Eisenhut to S. T. Rogers, the' staff indicated that the, generic guidelines prepared by General Electric and the BWR Owners' ,

Group were acceptable for t r.i a l implementation at,, Wash'ington Public Power Supply System' Unit 2.

Additional informationi requested by the staffe was submitted by the Owners' Group on January 31, 1981.

~Th'e staff will complete its' review of this additional information prior to making a' final conct'usion on the acceptability of the guidelines for, implementation on all Boiling Water Reactors.

$k#In Amendment No. 17 to the FSAR (dated July 1981), the applicant committed to implement a program of emergency operating procedures based on the General Electric Owners' Group Guidelines, when approved by the staffe in acterdance with the schedule of NUREG-0737.

In addition to the General Electric Owners' ' Group efforts, the staff has prepared draft guidelines._for long-term upgradihg of emergency operating procedures (NUREG-0799) in accordance with Task Action Plan Item I.C.9. These guidelinese as revised durino the resolution of public commentsi also should be used in the preparation of the e

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Washington Public Power Supply System Unit 2 emergency operating procedures. Therefore, the staff does not plan to conduct a Pilot Monitoring Review of Selected Emergency Operating Procedures in accordance with TMI Task Action Plan Item I.C.8 for this plant. However, we will review the applicant's submittal for compliance with the final staff guidelines r e s u l't i n g from resolution of public comments on NUREG-0799. The final staff guidelines will include consideration of the General Electric Owners' Group technical guidelines. Our review of the emergency operating procedures submitted by the applicant will be completed prior to issuance of the operating license and will be addressed in a.

supplement to this Safety Evaluation Report.

1. In accordance with NUREG-0737, Item I.C.7, NSSS vendor review of low power testingi power ascension and emergency operating procedures is necessary to further l verify adeouacy of the procedures. Amendment No. 17 l

l to t h e- F S A R stated that the NSSS Vendore General Electric Corporatione will review the low power testinge power ascension test and emergency operating procedures by July 1982. This is several months prior to the currently scheduled fuel load date. The staff will .

confirm that this review is completed prior to issuance of a full power license.

15.8 ANTICIPATED TRANSIENTS WITHOUT SCRAM

/ Anticipated Transients Without Scram (ATWS) are events in which the scram system (reactor trip system) is postulated to fail to operate as required. This subject has been under generic review by the Commission staff for several years.

f/ In December 1978, Volume 3 of NUREG-0460, " Anticipated Transient Without Scram for Light Water Reactors" was issued describing the proposed type of plant modifications we believe are necessary to reduce the risk from anticipated transients with failure to scram to an acceptable level. We issued requests for the industry to supply generic analyses to confirm the ATWS mitigation capability described in Volume 3 of NUREG-0460.

Subsequently, we recommended to the Commission that rulemaking be used to determine any future modifications necessary to resolve ATWS concerns as welL as the

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required schedule for implementation of such modifications.

Washitston Public Power Supply System, Unit 2 is subject to the Commission's decision in this matter.

d It is our expectation that the necessary plant modi *ications will be implemented in one to four years following a -

Commission decision on ATWS. As a prudent courses to

'further reduce the risk from ATWS events during the interim 4

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i 8-period before completing the plant modifications determined by the Commission to be necessary, we require that the following steps be taken

1. An emergency operating procedure should be developed for an ATWS eventi including consideration of scram indicators, rod position indicators, average power range flux monitorse reactor vessel level and pressure indicatorse relief valve and isolation valve indicatorsi and containment temperaturer pressure and radiation indicators. The emergency operating procedures should be sufficiently simple and unambiguous to permit prompt operator recognition of an ATWS event.

2. The emergency operating procedure should describe actions to be taken in the event of an ATWS including consideration of manually scramming the reactor by using the manual scram buttonse changing the operation mode switch to the shutdown positione

, t ripping- t he feeder breakers on the reactor protection sgstem power distribution busesi scramming individual control rods from the back of the control room panele tripping breakers from plant auxiliary power source feeding the reactor protection systems and valving l

out and bleeding off instrument air to scram solenoid l .

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_9-valves. These actions must be taken immediately after detection of an ATWS event. Actions should also include prompt initiation of the residual heat removal system in the suppression pool cooling mode to reduce the severity of the containment conditions; and actuation of'the standby liquid control system if a scram cannot be made to occur.

The GE Owners' Group is currently developing a set of Reactivity Control Guideliness which will incorporate i

the abose steps for mitigating ATWS events. The applicant's procedure for mitigating,ATWS will be reviewed under the emergency operating procedure program as described in Section 13.5.2. The results of the staff review will be reported in a supplement to this Safety Evaluation Report.

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