ML17194B179

Forwards Guidelines for Info Needed to Update Unresolved Safety Issues for Facility.Info Required within 60 Days

ML17194B179
Person / Time
Site:	Dresden
Issue date:	07/06/1982
From:	Lainas G Office of Nuclear Reactor Regulation
To:	Delgeorge L COMMONWEALTH EDISON CO.
References
LSO5-82-07-008, LSO5-82-7-8, NUDOCS 8207140165
Download: ML17194B179 (9)

Text

DISTRIBUTION Docket July 6, 1982 Gocket No~ 50-237 LSOS-82-07-008 NRC PDR Local PDR ORB Reading NSIC DCrutchfield HSmith PO'Connor OELD OI&E Mri t~ OelGeorge ACRS ( 10)

SEPB Director of Nuclear Licensing Commonwea 1th Edi son Compqny - _

Post Office Box 767 Chicago, Illinois 60690

SUBJECT:

UNRESOLVED SAFETY ISSUES STATUS FOR THE DRESDEN NUCLEAR

-*. POWER STATION. UNIT NO, 2 -

The.staffis_safety evaluation report regarding the conversion of the Provisional Operating License for Dresden Unit No. 2 to-q fu11-tenn operating *11tense. must address the status of unreso 1 ved safety issues (see-discussion of ALAB-444 in Encloeere 1}.

To enable the staff to expeditiousJy review and evaluate the siiatus of these items at Dresden

.Unit No. 2, we wi 11 need up-to-date information of the type described

• in the enclosure to this letter for the unresolved safety issues listed in Enclosure 1.

Accordingly, pursuant to 950.54(f} of lo CFR 50, you are requested to furnish the -following information with regard to each of the identified unresolved safety issues within 60 days of the date of this letter:

( 1)

(2)

(3) has the issue been resolved at Dresden Unit No. 2; if so, how has it been resolved; and if ~ull resolution has not occurred- {including implementation of _n_ecessary hardware, procedures, etc.) what interim measures have been taken -to assure that continued operation would not pose an undue risk to the public.

The reporting-and/or recordkeeping requirement~ contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not

-required under P.L. 96-51'1..

Sincerely, Orig!Qal signed by Gus c. Lainas, Assistant Director

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8207140165 820706 1

for Safety Assessment PDR ADOCK 05000237 1 ' -':

1 Division of L1censing J _ ___.*

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NRC FORM 318 (10*80) NRCM 0240 OFFICIAL RECORD COP USGP0:198l-335-960

Mr. L. DelGeorge cc Isham, Lincoln & Beale Counselors at Law

• • One First National Plaza, 42nd Floor Chicago, Illinois 60603 Mr. Doug Scott Plant Superintendent Dresden Nuclear Power Station Rural Route #1 Morris, Illinois 60450 The Honorable Tom Corcoran United States House of Representatives Wash*ington, D. C.

20515

u. s. Nuclear Regulatory Commission

• Resident Inspectors Office Dresden Station RR #1 Morris, Illinois 60450 Mary Jo Murray Assistant Attorney General Environmental Control Division 188 W. Randolph Street Suite 2315 Chicago; Illinois 60601 Chairman Board of Supervisor~ of Grundy County Grundy County Courthouse Morris, Illinois 60450 John F. Wolf, Esquire 3409 Shepherd Street Chevy Chase, Maryland 20015 Dr. Linda W. Little 500 Hermitage Drive Raleigh, North Carolina 27612 Judge Forrest J. Remick The Carriage House - Apartment 205 2201 L Street, N. W.

Washington, D. C.

20037 July 6, 1982 Illinois Department of Nuclear Safety 1035 Outer Park Drive, 5th Floor Springfield, Illinois 62704 U. S. Environmental Protection Agency Federal Activities Branch Region V Office ATTN:

Regional Radiation Representative 230 South Dearborn Street Chicago, Illinois 60604 James G. Keppler, Regional Administrator Nuclear Regulatory Commission, Region III 799 Roosevelt Street Glen Ellyn, Illinois 60137

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v STATUS OF UNRESOLVED SAFETY ISSUES AT DRESDEN 2 The NRC staff evaluates the safety *requirements used in its reviews against new information as it becomes available.

Information related to the safety of nuclear power plants comes from a variety of so~rces i~cluding experience from operating_ reac_tors; research resu.l ts; NRC staff and Advisory Committee* on --

Reactor Safeguards safety reviews; and vendor, archii~ct/engineer,.and

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utility design reviews.. EaGh time a new concern or safety issue is identified I

from one or more of. these sources; *t11e-11eed iorimmedi ate act; on. to en?ure safe ciperat ion-is assessed.

This-a~sessment inel ~des consi-der-ation**of the. ge.ne~i c*

~implications of the *issue.

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In so"'e cases, immediate action is take~.tq ensure safety.

In other cases, interim measures, such as modifications to operating procedures, m'ay be sufficient to. all ow 'f-fJrTher study of the ~ s.s~e befo*re licensi_ng deci'sions are*made.* In most,cas-es*,-:-*t+re initial as.sessment*indicates that* immedi.ate lfcelising actions or ch'a'n9es in licensing criteria are not necessary.

In any event, further study may be deemed appropriate to make judgments as io whether existing NRC staff requirements should be modified to address the issue for new plants or if backfitting is appropriate for the long-term ope*ration of plants already undet.construction or in operation..

These issues are sometimes called "generic _safety issues" because they are related to a particular class or type cf nuclear facility rather than to*a specific plant.. These issues have also been referred to as "unresc;>lved safety-issues 11 (NUREG-0410,

"~RC Program for the Resolution of Generic Issues Related to Nuc 1 ear Power Pl ants, 11 dated Jan*uaf'y 1, -1978).. *However, as discussed above, su~h issues are considered on a generic basis only after the staff has made an i~itial determination that the safety significance of the issue does hot prohibit continued operation or requir~ licensing act~on$ while the lohger-term gen~ri c review is under way.

A Oeci $ion by the Atomic Safety and Licensing Appea 1 Boa rd of the Nuclear Regulatory Comm_i ss ion addresses these longer-term generic studies.

The Decision was issued on November 23, 1977

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(ALAB-444)*in connection with the Appeal Board's consideration of the Gulf States Utility Company application for the River Bend Station, Units 1 and 2.

In the view of the Appe~l Board (pp. _25-29),

The responsibilities of a licensing board in the radfological health and safety sphere are not confined to the consideration and dispo-sition of those issues which may have been presented to it by a party or an 11 Interested State 11 with. the r*equired degree of specificity.

To the contrary, i rrespect iv~ of what matters may o.r may not ilave been

• properly placed in contr9vers~. prior to authorizing the iss~ance of*

a construction permit the board must_mak~ the f_i_nding,* inter-alia, that there i S II reasonab 1 e assuran*ceif tha( "the pr*cip'osed facility Can be-constructed and operated at the pr_oRbse-d l cc.at ion. without undue risk to the health and safety of_the public.".._ Of necessity, this 10 CFR 50.35 (a) determination will entail* an inquiry i.n:to whether the*_

staff revi~w satisfactorily has come to _grips..with any unresolved generic safety problems which might have an impact-upon operation.of the nuclear facility under considerati.on.J

~he SER is, of course, the principal document before the li~ensihg board whi'ch reflects the content and outcome of the staff's safety review.

The board should therefore*be-ab11:-to look to that document to ascertain the extent to which gene'ric unresolved safety problems..

which have been previously identif~-ed fo a-n 'fSAR 'item, a Task Action Pl an, ari ACRS report or e 1 sewhere h~E!'"tle.en factored into the.* staff's analysts for the particular reactor--and with what result.

To this

. end, in our view, each SER should contain a *summary description of those generic problems under continuing study which have both rele-*

vance to facilities of the type under review and potentially *signifi-cant public safety implications.

This summary description should include information of the kind now

• contained in most Task Action Plans.

More specifically, ther~ sho~ld be an *inditation of the investigative program which has been or.will be undertaken with regard to the problem, the program 1 s anticipated time span, whether (and if s6, ~ha~) interim measures have been devised for* deal i n*g wi_th the prob 1 em pending the comp 1 et ion of the

• • investigation, and what alternative course of action might be avail-able should the P'.9gram not produce the envisaged result.

In short, the board (and the pub1ic as well) ~hould be in a position to ascertain from the SER itself--without the n*eed to resort to extrinsic documents--the staff 1 s perception of the nature and_ e_xten:t of the relationship between each significant unresolved generic

• safety question and the event~al operation of the reactor under.

scr~tiny. Once again, this assessment might well have a direct bear*ing upon' the ability of the licensing board to make the safety

.. findings required of it on.the construction permit_ level even though the generic answer to the que~tion remains in the offing.

Among other things, the furnished information would likely shed light on such alternatively important cons'iderations as whether:

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(1) the problem has already been resolved for the reactor under study; (2) there is a reasonable basis for concluding that a satisfactory solution will be obtained before the reactor is put in operation; or (3) the problem would have no safety implications until after several years of reactor operation and, should it not be.

resolved by then, alternative means will be available to insure that continued operation (if permitted at all) would not pose ~n undue risk to the public.

This section is specifically included to respond to flie decision *of the Atomk-Safety and Licensing ~ppeal -Boarct*as enunciated in ALAB-~4, anp as ~pplied to an operating 1 i cense proceeding Virgf nia E~ e'°ctr1 c -a-nd Po"wer.Company (North A*nna Nuclear Power Station Unit N.os.. T-and 2) -: -ALAB-491*,_ 8 *NRC. -245 (1978)..

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• 'In. a related ma~ter, as a result of Congp~s-sional-a*ction on the Nuclear Regulatory Commission.budget for Fiscal Yea,r 1978, the* Energy Re'organ.izatii:>ri

• Act of 197~ was amended (PL 95-209) on December 13, 1977 to include, among other things, a new Section 210 as follows:

UNRESOLVED SAfETY-- IS5UCS PLAN SEC.

~10. The Commission ~hall develop a plan providing for specifi-cation and analysis of unresolved safety issues relating to nuclear reactors and shall take such actions as may be necessary to implement corrective measures with respect to such issues.

Such plan shall be submitted to the Congress on or before January l, 1978, and progress reports shall be included in the annua 0l *'report of the Cammi ssion

• thereafter.

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The J6~nt Expl~~atory Statement of th~ House-Senate Conference Committe~ for the Fiscal Year 1978 App~6priations Bill (Bill S.1131) provided t~~ following additi6~a1 information.regarding the Committee 1 s deliberations on this portion of.the bill:_

SECTION 3 UNRESOLVED SAFETY ISSUES The House.amendment required developme~t of a plan to resolve generic safety issues.

The conferees agreed to a requirement that the p1an be submitted to the Congress o'n or before January l, 1978.

The

. conferees also expressed the in~ent that this plan should identify and.describe those safety issues*, relating-to nuclear power *_reactors,

~hich are unresolved on the date of en~ctment. It should set forth:

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(1) Commission actions taken *directly or indirectly to develop and implement corrective mea~ures; (2) futher actions planned concerning such measures; and (3).ti~etables and_co~t estimates of such actions.

The Commission sho~ld 1ndi7ate_ t~e ~r~or1ty it has assigned to each issue, and the basis on which priorities have been assigned.

In iesponse to the reporting requirements of the new Section 210, the NRC staff s ubli1i t ted to Congress on January 1, 1978, a report, NUREG-0410 ;-e 11t i t1 ed 11 NR'C Program for the Resolution_of Generic Issues Related-to Nucl"ear""".'Power Plants,."*-:-..

describing the NRC generi~ issues~rogr~m. The NRC program was.already-in p 1 ace when PL 95-209 was. enacted and *1 ~-of CO!\\S tderab ly b~oader.scope *_t:h.an the '

"Unresolved Safety Issues Plan 11 re.quired.by' s'ection 210.. *In the letter trans- -

mitting NUREG-0410 to the Cong~ess o~ December 30, 1977, NRC indicated that:

~"the progress -tepo*rts, *which are required*. ~y Secti-on 210 to be i.ncl ud~ in future NRC an*nua 1. reports, may be more us~ful) to Congr~ss if they *focus on the specific Section 210 safety ite*ms.

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• lt is the NRC's view that the intent of*~ection 210 was to ensure that*pl~ns were developed and implemented on issu.~s.. with-µD'te:ntially *significant public safe~y impl i ca ti eris":'* In 1978, the NRC: tjn(fertook a.revi ~w of more than *130.

. generic is~ues a~dressed in the N~C prcigram to d~termin~ which issues fit this

• description* and qualify as unresolved safety issues for reporting to the Congress.

The NRC revie~ included the development of proposals by the NRC staff and review and final approval-by the NRC Commissioners.

This. review is des~ribed in NUREG-0510, "Identification of Unresolved. Safety~

Issues* Re 1 at i ng to Nuclear Power Plants - A Report to Congress, 11 January 1°979.

The* report provides the following definition of an unresolved safety issue.

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An Un re so 1 ved Safety Issue is a matter-affecting a number of nuclear power plants that poses important questions concerning the adequacy of existing safety requirements for *wh1ch a final resolution has not yet been developed and that involves conditions not likely to be acceptabl~ over the lifetime of the plants it affects.

Further, the repbrt indicates that in applying this definition, matters that pose 11 ir.1portant questions concerning the adequacy of existing safety re qui !"e-ments" were judged to be those for wtiich resolution is necessary to (l_) com-

• pensate for a possible major reduction in the degree of protection of the 4

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public health and safety or (2} provide a the risk to the public health and safety.

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., y potentially significant decrease in Quite simply, an unresolved safety issue is potentially significant from a public safety standpoint, and its resolution is likely to result in NRC action on the affected plants.

All of the issues addressed in the NRC program were systematically evaluated against this definition as described in NUREG-0510.

The issues ~re listed below.

Progress on these issues was fir_st discussed.in the "19is NRC Annual : ~.

Report.

The_ number(s) of the generic task(s) (e.g., A-1).in __ the--NRC pro-gram addre~s; n~ each issue is indicated. in - pa~:n.~he_s~ :fol 1.owi.n_g_ the _title.*

• UNRESOLVED SAFETY ISSUES (APPLICABLE TASK NOS.)

!l) Waterhammer -. (A-1)

(2)

BWR MARK I Pressure Suppression Containments -

(A-6, A-7, and A-39)

(3)

Anticipated Transients Without Scram (A-9)

(4)

BWR Nozzle Cracking -

(A-10)

(5) *Reactor Vessel Materials Toughness (A-11)

(6)

Systems Interaction in Nuclear Power Plants (A-17)

(7)

Environmental Qualification of Safety-Related Electrical Equipment (A-24)

(8)

Residual *Heat Removal Requirements (A-31}

(9)

Control of Heavy_Loads Near Spent Fuel (A-36)

(10). Seismic De~ign Criteria (A-40)

(11)

Pipe Cracks at Boiling Water Reactors (A-42)

(12)

Containment Emergency Sump Reliability (A~43)

(13)

Station Blackout (A-44)

.(14)

Shutdown Decay Heat Removal Requirements (A-45)

(15)

Seismic Qualifications of Equipment in Operating Plants (A-46 (16) *Safety Implications of Control Systems (A-47)

(17) _Hydrogen Control Measures and Effects of Hydrogen Burns on Safety Equipment (A-48)

The NRC staff has issues reports providing its ptoposed resolution.of Eight of these issues.

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NRC. staff's p*~ed resolution of Eigl)~ safe9t1-ssu~s.. *

• Task number A-6 A-9 A-10

• A-24 A-31 A-36

_A-42 NUREG report number and title NUREG-0408, "MARK I Containment Short Term Program."

• NUR.EG-0661, "MARK I Containment Long Term Program."

NUR.EG-0460, VOL. 4, "Anticipated l'ransie11.ts-Without Scram for L~ght Water Reactors" NUREG-0619, "BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking."

NUREG-0588,. "Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment."

SRP 5. 4 7 and BTP 5-1, ',~Residual Heat Removal Systems" incorporate requirements of USI A-31 NUREG-0612, "Control of Heavy Loads at Nu.clear Power Plants NUREG-0313,REV.l, "BWR Coolant Pressure Boundry Piping."

With the exception of Tasks A-9, A-43, A-44, A-47, and A-48, Task Action Plans for the generic tasks above are included in NUREG-0649, "Task Action Plans for U~resolved Safety Issues Related to Nuclear Power Plants." A technical resolution for Task A-9 has been proposed by the NRC staff in Volume 4 of NUREG-0460,.issues for comment~ This served as a basis f~r the staf~'s proposal for rulemaking on this issue.

The Task Action Plan for Task A-43 was issued in January 1981, and the Task Action Plan f0r A-44 was issued in July 1980.

The information provided in NUREG-0694 meets most of the informational requirements of ALAB-:-444.

Each Task Action Plan provides a description of the problem; the staff's appr~aches to its !esolution; a general.discussion of the bases on which continued plant lie-

• ensing or operation can proceed pending completion of ~he task; the technical organization involved in the task and estimates of the manpower required; a des-cription of the interactions with other NRC offices, the Advisory Committee on Reactor Safeguard and outside organizations; estimates of funding required for contractor-supplied technical assistance; pr~spective dates for completi~g the task; and a description of potential problems that could alter the planned approach on schedule.

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In addition to the Task Action Plans, the staff issues the "Office of Nucle~r Reactor Regulation Unresolved Safety Issues Summary, Aqua Book" (NUREG-0606) on a quarterly basis, which provides current schedule information for each of the unresolved safety issues.

It also includes information relative to the imple-mentation status of each unresolved safety issue for which technical resolution

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