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PA.C IP IC Q-A.S A.ND ZLEC T B,XC C O MPA.NTWW~K ~ 77 BEALE STREET ~ SAN FRANCISCO, CALIFORNIA94106 ~ (415) 781.4211 ~ TWX 910.372 6587

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IIVCLCAIlJONES CCNCAATION September 26, 1980

Secretary of the CommissionU.S. Nuclear Regulatory CommissionWashington, D.C. 20555

Attention Docketing and Service Branch

Dear Sir:

Pacific Gas and Electric ("PG&E") hereby submits its comments onNUREG-0696, "Functional Criteria For Emergency Response Facilities,"pursuant to Federal Register Notice 45FR54708 dated August 15, 1980. Thepotentially great impact of these criteria on nuclear plant owners andtheir emergency response capabilities make it imperative that the NRCcarefully review all comments on NUREG-0696 to arrive at a reasonable andbalanced regulatory position.

Generally, the proposed criteria do not allow sufficient flexi-bility for site specific factors or innovative design approaches. PG&Estrongly believes that emergency response is an area where no universalsolutions lie. Admittedly, the framework of an effective accidentmanagement system can be sketched in functional and conceptual terms.This is the legitimate, and indeed desirable, scope of NUREG-'0696. Butto venture further along the design specification path, through prescriptiveand narrowly detailed requirements, is to require a compromise system designthat serves no site well. The NRC should review each situation on a case-by-case basis and determine the merits of each emergency facilities designas it relates to the exigencies of the individual site. In the attachedcomments, principal areas are identified where the proposed criteria over-reach the bounds of functionalism and suggested alternate criteria areprovided. The clearest example of overprescription is the location ofthe EOF. The EOF concept that emerges from these criteria is heavilyweighted by the TMI-2 experience to the exclusion of other possibleapproaches. While the proposed criteria recognize a tradeoff in thelocation of the EOF relative to the plant, it is clear that a close-insite is preferred in the proposed NUREG-0696. This approach isreminiscent of "trailer city" across the river from TMI-2. Howeverf foraccidents with potential releases of significant quantities of radioactivematerials (unlike TMI-2) siting the EOF near the plant could make accessdifficult or impossible. This would compromise the function of the EOF

to coordinate and effectuate the offsite accident response. Further, therequirements for sophisticated communications and data links between theEOF, TSC and Control Room will allow more remote siting of the EOF whilestill assuring adequate interactive capability. As a minimum, the criteriashould make more remote siting of the EOF a viable, if not preferred option.

8 10pppgp<

4

Secretary of the CommissionU.S. Nuclear Regulatory Commission

September 26, 1980

These comments are also responsive insofar as the proposedNVREG-0696 criteria directly impact on PG&E. PG&E is committed to the

lement in the safeconcept athat emergency preparedness is an essential elattem t toWe.opera on o '.ti of: nuclear power plants and has made every a p

ca abilities.; respons ve oto the perceived need for enhanced emergency c pment of emergencyIn act, asf PG&E has proceeded with the design and procureme t

facilities for Diablo Canyon in advance of the specific cr efic criteria nowrovided in proposed NVREG-0696. Since PG&E's approach is not in all

h NVREG-0696 it is faced with the prospect of beingthis is bothenalized for taking the initiative. We believe that t s s opena ze o

unfortunate and unnecessary. If utilit ei s are to take the lead inreso v nlving nuclear safety concerns, there must bbe a corresponding willing-ness of the NRC to entertain and accept on a cooperativeve basis thesewell-engineered alternatives. PG&E is prepared to cooperate with theNRC in de~eloping effective functional criteria for emergency responsefacilities and demonstrating the ability of the Diablo Canyon facilitiesto perform those functions.

Enclosures

I I

COMMENTS OF PACIFIC GAS AND. ELECTRIC COMPANY (PGandE) ON NUREG-0696

"PROPOSED .FUNCTIONAL CRITERIA

FOR EMERGENCY RESPONSE FACILITIES"

September 26, 1980

I. GENERAL COMMENTS

1. COMMENT

The location of emergency facilities should be determined on a sitespecific basis and reflect their separate and distinct emergency functions.The current version of NUREG-0696 contains prescriptive criteria thatinhibit the ability to locate the TSC and EOF in an optimum or evenfeasible manner. At the same time, these prescriptive criteria arenot necessary for, and in some cases not consistent with, the emergencyresponse function to be performed.

~Exam le lSection III.B requires the TSC to be within two minutes walking time ofthe control room and provisions made for the safe and timely movementof personnel between the TSC and control room, under all emergencyconditions.

These criteria are not necessary to the TSC function, which is to providea location separate from the control room for the analysis of plantconditions. Interaction between the TSC, control room, and EOF is viacommunications and data links, and does not require direct physicalaccess.

For the TSC at Diablo Canyon, PGandE has selected and proceeded withconstruction in an area enclosed by the Turbine Building buttressesprior to the issuance of NUREG-0696. This area provides a spaciousand seismically designed TSC that is also strategically located withinthe plant. However, this location is approximately three minutes walkingtime to the control room. Relocation of the TSC at this time would beprohibitively costly, but of greater importance, would not materiallyenhance the functionality of the TSC.

Pro osed Criterion

The TSC shall be located within the lant securit boundar at a locationthat facilitates the erformance of its emer enc function.

This criterion will allow the selection of an optimum location of theTSC within each plant based on available space. Any location within thesecurity boundary will be within a reasonable distance of the controlroom and capable of rapid staffing in the event of an emergency. TSCinteraction with the control room will be via the dedicated data and

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COMMENTS OF PACIFIC gggAND ELECTRICCOMPANY (PGandE) ON PHAG-0696 3 September 26, 1980

requires the selection of a reliability methodology, determination andapplication of specifications, (e.g., mil specs), identification ofacceptable reliability data bases, and a reliability support effortsimilar to existing QA programs. The implications of demonstratinga .001 unavailability for an entire system are enormous, and could

'eadily increase the cost by a factor of 20, and extend delivery timesof components by two years or more. In addition specification of .001unavailability for systems that serve as operational aids if not )ustifiedor cost effective.

~Exam las

Section II.F states that the "total system shall be designed to achievean unavailability goal of 0.001 for the SPDS." A similar criterion iscontained in Section III.Ifor the TSC data systems. A precisedefinition of "system unavailability" is needed. For example, shouldsystem unavailability be defined as loss of all displays, loss of anysingle set of displays necessary to monitor a single safety function,or loss of any single display of a parameter or derived variable?Is a data display unavailable if it is completely lost or if it isoutside of some specified tolerance range?

The criteria for TSC instrumentation and power supplies presented inSection IIIH includes a criterion that states that the "total systemshall be designed to achieve a functional unavailability goal of ~ Olfor the TSC " Neither the "total system" nor "system unavailability"are well enough defined to allow this criterion to be applied in thesystem design or its successful application demonstrated to the NRC.

Section III.H also includes a criterion for unavailability of individualparameters of less than 001 'here is apparently no flexibility inthis requirement to account for variations in the safety importance ofthe individual parameters or to allow a higher unavailability if thevalue of the parameter can be determined or inferred from other parameterdisplays.

The criteria in Section IV.H on accuracy and reliability of instrumentationare so vague as to be unusable. The phrase "data vital to EOF functions"is unclear and implies that some of the data stream to the EOF is notrequired.

Pro osed Criterion

res onse data s stems and facilities should be of hi h ualit

antici ated accident conditions.

Emer encand reliabilit such that the would be ex ected to be available under

3 ~ COMMENT

Accident monitoring instrumentation signals should not be required tobe transmitted, processed, and displayed independently of the normalplant operations computer.

The requirement that signals shall be input directly into data acquisitionprocessors and not be processed in any equipment used for normal operation

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a'OMMENTS OF PACIFIC AND ELECTRICCOMPANY (PGandE) ON NUREG-0696 September 26, 1980

24 CONNENT

Section II.C requires the SPDS display to be readable from the operatingstations of the shift supervisor, control room SRO, shift technicaladvisor, and at least one RO. This factor may not be consistent withgood human factors engineering.

Pro ose'd Alternative

The SPDS shall be readable from the normal o eratin stations within thecontrol room.

III. TSC/EOF COMMENTS

The requirement in Section IIIeJ to maintain current, up-to-date drawings,schematics and diagrams down to the com onent level is not )ustifiednor necessary. Utilities should be allowed to be selective in establishingthe scope and level of drawings to be maintained current and "on-line"in the TSC. Their selection should be based on a reasonable evaluationof the potential need for them in an accident 'situation.

Pro osed Criterion

The TSC shall have available lant drawin s schematics and dia ramssufficient to erform its emer enc function.

2. COMMENT

Section IIIeH requires that circuit transients in the TSC power supplynot cause a loss of data. Circuit transients will inevitably causefluctuations in any measured data, but should not cause loss of anystored data.

Pro osed Alternative

Circuit transients or ower su 1 failures and fluctuations shall notcause a loss of TSC stored data.

3. COMMENT

Minimum data set requirements fot TSC or EOF are specified in terms ofReg. Guide 1 97. Appropriate data for each facility should be developedbased on the function of that facility and the site-specific data needsto serve that function.

~Exam le

Section III.I-requires specific Reg. Guide 1.97 variables to be providedin the TSC. These variables may or may not be appropriate to the TSCfunction depending on the final form of Reg. Guide 1.97.

Section IV.I is the same as Section III.I.

'

„COKKNTS OF PACIFIC++ AND ELECTRICCOMPANY (PGandE) ON VNRBG-0696 September 26, 1980

4 ~ COMMENT

Section X.B.2 defines the Technical Support Center as "a facility as nearto the control room as possible where plant management personnel willtili e technical data and displays necessary for assisting control

Et atroom'personnel during emergency conditions. 'his seems to infer thaplant management personnel must be in the TSC. This location may not bethe most effective location for senior plant management and the criteriamust allow the plant manager to choose the most appropriate locationdepending on existing conditions, personnel availability, shift manning,etc.

Pro osed Criterion

The onsite Technical Support Center (TSC) shall be near the controlroom. Appropriate personnel, data and documentation are gathered atthe TSC to assist plant management and control room personnel duringemergency conditions and minimize congestion in the control room.

5. COMMENT

Section XXI A, paragraph 5, requires "interactive terminal and displaycapability~" This requirement and the need for it is . not clear.If some function would be improved, the function should be stated.

6. COMMENT

The size of TSC and EOF facilities should not be stated in terms ofhow many personnel are to be accommodated. The size of each facilityshould be determined in the design process based on the function ofthe facility and the number of personnel and type of equipment neededto fulfillthat function.

~Exam le

Section XIX.D and Section IV.D.

IV NDL COMMENTS

1 COMMENT

There is no need to time-tag each parameter with a resolution of onesecond as required by Section V.B.c.l. Time-tagging should be doneon a data set basis, and a resolution of + 1 minute is more than adequatefor this purpose.