ML19347A849

Comments on Draft NUREG-0696:AIF Comments Endorsed.Deletion Recommended for Sections Prohibiting Use of Plant Process Computer to Process Info for Emergency Response Facilities

ML19347A849
Person / Time
Site:	Wolf Creek
Issue date:	09/24/1980
From:	Schwoerer F STANDARDIZED NUCLEAR UNIT POWER PLANT SYSTEM
To:	Ramos S Office of Nuclear Reactor Regulation
References
RTR-NUREG-0696, RTR-NUREG-696 SLNRC-80-46, NUDOCS 8009300397
Download: ML19347A849 (3)

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, C.

SNUPPS sinne-ma.e m a.-un#

Pam.c Pl.nt Syse.m s en.=. ch-ry n e noe m.,u-vi aosso (301)8464010 September 24, 1980 l

SLNRC 80-46 FILE: 0540/8000 l

SUBJ: NUREG-0696 U.S. Nuclear Regulatory Comission Office of Nuclear Reactor Regulation Emergency Preparedness Program Office Wa hington, D.C. 20555 Attn: Mr. Steve L. Ramos, Mail Stop Phillips 242

Dear Sir:

The purpose of this letter is to transmit comments of the SNUPPS organi-zation on NUREG-0696, which has been issued as a draft report for interim use and coment.

SNUPPS endorses the comments submitted by the Atomic Industrial Forum.

In addition, we have the following specific coments. As requested by NRC representatives at the briefing meeting in Chicago on August 20, the bases and safety-related justifications for our coments are included.

1. We recomend deletion of the words on pages 4-5,13 and 19, prohibiting use of the plant prccess computer to process infomation for the emergency response facilities.

Instead, the functional requirements of the data precessing system for the Emergency Response Facilities should be stated, e.g., the data processing shall meet the reliabil-ity guidelines, shall be operable during and after a plant transient or accident, and shall have secure software.

Basis: Modern process computers, such as the one in each SNUPPS plant meet the functional requirements stated above.

That is, the SNUPPS process computer is a state-of-the-art computer, with dual processors, dual memory units, automatic Xgl failover between the primary and backup units and an uninter- $

ruptible power supply. Expansion of this computer to perform the functions of the Emergency Response Facilities can be g done by adding additional processors and read-out devices, ,

which is more cost-effective and, we think, also safer than hard-wiring certain plant parameters into a separate coinputer.

The software for the TSC, etc. will not nomally be accessible to programmers. The input / output functions for the TSC, etc.

Will not be inhibited by the alarming function. The reliability is as high as for any digital processor that could be purchased l

for the TSC.

800930039

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'- SLNRC 80- 46 Page Two

2. We recommend deletion of the requirement that the SPDS be de-signed for an OBE.

Basis: The SPDS, as currently envisioned by the NRC, would apparently display from perhaps six to twenty plant para-meters . While this parameter set may be sufficient to indicate that an accident has comenced, it is not sufficient to deter-mine that the plant is responding as it should to that acci-dent. A reading of emergency procedures demonstrates this to be the case. Therefore, the SPDS is unlikely to be a reli-ble indicator of whether operator action is necessary or what that action should be. A flexible computer-based SPDS has the potential for displaying additional parameters and infor-mation on systems status, such that it could provide indication

• of the state of the plant throughout at least the first ten to thirty minutes of any accident. Such an SPDS would be a much more powerful operating aid than the SPDS envisioned by the NRC. However, such an SPDS requires flexibility in com-puter programing and display that is not obtainable within a reasonable time schedula if the OBE requirement is imposed.

The NRC is proposing the use of an arbitrary requirement, related to a low probability event (0BE), that detracts from making a real safety improvement - in this case, use of modern computer technology for accident diagnosis. In this sense the NRC appears to be ignoring the advice of the Kemeny Commission.

The main control board is designed to an SSE. Design reviews, emphasizing human factors, will be performed of all main control boards and, as indicated necessary, changes will be made to reduce the chances of operator confusion or error.

3. We recomend deletion of the two-minute time limit governing  ;

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the location of the TSC with respect to the Control Room.

Basis: SNUPPS plans a TSC immediately adjacent to the onsite Administration Building, which will contain the offices of )

personnel who will man the TSC. This will provide the ability to activate the TSC rapidly, which we consider of greater im-portance than proximity of the TSC to the control room.

Further, the SNUPPS. arrangement pennits a single TSC for a 2-reactor site. The walking time between the TSC and the control room will be less than five minutes.

Emergency procedures will designate a lead individual in the control room and a lead individual in the TSC. Voice comuni-cations between the two locations will normally be handled by these two people. Through TSC drills, these people will have a familarity with each other and will be capable of comunica-ting effectively by telephone. We envision little need for l

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SLNRC 80 46 Page Three face-to-face contact. TMI experience in this regard is cen-sidered not relevant because TMI had no established TSC nor procedures for its use. In fact, face-to-face contact un-less carefully controlled is potentially disruptive. However, the opportunity for face-to-face contact will always exist and motor vehicles will be kept available at the SNUPPS sites to shorten the travel time.

We welcome your interest in receiving comments from this utility industry and we hope that you will give favorable consideration to these coments.

Very truly yours, F. Schwoerer Technical Director FS/jdk cc: J. A. Bailey KGE D. F. Schnell UE J. L. Sippel KCPL J. K. Bryan UE G. L. Koester KGE

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D. T. McPhee KCPL M. A. Stiller UE/ CAL F. T. Rhodes KGE/WC J. H. Smi th B R. L. Stright Itaff 1

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