ML17209A804

Notification of 810311 Meeting W/Util in Silver Spring,Md to Provide Contractors Participating in Independent Design Review Pilot Program W/Info on Staff Scope of FSAR Review. Agenda Encl

ML17209A804
Person / Time
Site:	Saint Lucie
Issue date:	03/06/1981
From:	Nerses V Office of Nuclear Reactor Regulation
To:	Youngblood B Office of Nuclear Reactor Regulation
References
NUDOCS 8103160536
Download: ML17209A804 (22)

Text

Docket No.:

50-389

, ~, sr MEMORANDUM FOR:

B. J. Youngblood, ChiefLicensing, Branch 5o. 1,, DL FROM:

SUBJECT:

V. Nerses, Pro)ect Manager, Licensipg,Branch,f/o.

1, DL FORTHCOMING MEETING WITH FLORIDA PgMEQ,AND,I IGHT COMPANY, DATE AND TIME:

LOCATION:

Wednesday, March 11.

1981 9:00 AM Room 130, Willste Building Silvel Spring, Maryland E

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%1 Q I 'll PURPOSE:

PARTICIPANTS:

Provide FP8Lcantractors, who are participating,ip, independent design review pilot program,, information on the staff's scope of review pf,the,/SAR..

NRC Staff.

V. Nerses, D. Shum, 0. Chopra H. Krug, J, Youngblood, R

Tedesco, F, Rosa, W. Houston, T...quay, A, Ungaro FP&L Staff G. Bradshaw, E. Dotson Inde endent Desi n Review Contractors Bechtel EDS Nuclear guadrex

Enclosure:

Agenda for IDR Pilot Program Meeting cc:

See next V. Nerses, Project Manager Licensing Branch No.

1 Division of Licensing 11

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AGENDA FOR IDR PILOT PROGRAM MEETING A.

Nerses provide introduction to kick-off the meeting.

The introduction will cover:

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- purpose of meeting

- who the reviewers are, their background and order;of presentation

- ground rules for subsequent interfacing with reviewers

. all interfaces by FPSL contractors are through the LPM for S.L.2 or his back-up.

B.

Chopra g'ives presentation on how he reviews AC power systems (SRP 8.3.1),

onsite, excluding the diesel generator.

C.

guestion and answer period on Chopra's presentation.

Bechtel discuss and compare their approach if significantly different.

D.

Shum gives presentation on how he reviews containment spray system and containment cooling (SRP 6.2.2).

E.

guestion and answer period on Shum's presentation.

guadrex and EDS Nuclear discuss and compare their approach if significantly different.

F.

Krug gives presentation on how he reviews containment spray as a fission product clean-up system (6.5.2).

G.

guestion and answer period on Krug's presentation.'DS Nuclear discuss and compare their approach if significantly different.

1 H.

Shum gives presentation on how he reviews containment cooling (6.2.2).

I.

Question and answer period on Shum's presentation.

guadrex discuss and compare their approach if significantly different.

Before adjouring the meeting, Nerses goes over any agreements.

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Dr. Robert. E. Uhrig, Vice President Advanced Systems and Technology

'lorida Power 5 Light Company P. 0.

Box 5291OO Miami, Florida 33152 cc:

Harold F.. Reis, Esq.

Lowenstein, Newman, Reis, Axelrad 5 Tol.l, 1025 Connecticut

Avenue, N.

W.

Washington,'.

C.

20036

'Norman A. Coll, Esq.

McCarthy, Steel, Hectory 5 Davis 1'4th Floor, First National Bank Building Miami, Flori da 33131 Mr. Martin H. Hodder 1131 N.

E.

86 Street Miami,, Florida 33138 Dr.,David L. Hetrick Professor of Nuclear Engineering

'he University of Arizona Tucs'on, Arizona,85721 Dr. Frank F. Hooper School of Natural Resources University'of Michigan Ann Arbor, Michigan 48104 Resident Inspector St.'Lucie Nuclear Power Station c/o U. S.,Nuclear Regulatory Commission P.

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Box 400 Jensen:Beach, Florida 33457 II

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MAR 08 1S81 MEMORANDUM FOR:

J.

H. Sniezek, Director Division of Resident and Regional Reactor Inspection, ISE FROM:

SUBJECT:

D.

G. Eisenhut, Director Division of Licensing, NRR INTERIM PROCEDURES AND TRAINING FOR STATION BLACKOUT A decision by the Atomic Safety and Licensing Appeal Board (ALAB-603) concluded that station blackout (i.e., loss of all offsite and onsite AC power) should be considered a design basis event'or St. Lucie, Unit No. 2.

Me issued a

similar requirement for St. Lucie, Unit No. 1.

The Board 40rther recommended that, in view of the 'completion schedule for Generic Task A-44 (Station Blackout),

expeditious measures should be taken to ensure that plants with a comparable station blackout likelihood can accomodate such an event.

Based on our review of ALAB-603, we have concluded that some interim measures should be taken while Task A-44 is being conducted.

As described in the memorandum to Chairman Ahear ne from H. R. Denton dated November 10. 1980, enclosed as Attachment 1, we plan to issue a generic letter to all licensees (except FPSL for St. Lucie, Unit Nos.

1 8 2) which requests that they implement interim emergency procedures and a training program for station blackout events.

A copy of the generic letter, in the process of being issued, is enclosed as Attachment 2.

Me request that IE verify that the emergency procedures and training programs are implemented for all operating plants within 6 months or an alternate date accepted by the NRR staff.

Although there are no detailed acceptance criteria for this

action, a list of the basic considerations which should be addressed in the interim procedures is contained in the sample generic letter.

Should you have any questions regarding this action, contact C. Nelson (X27563).

Original signed by Darrell G. Eisenhut Darrell G. Eisenhut, Director Division of Licensing Attachments:

As stated cc:

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CGrimes NEfSRANO i FOR:

J.

H. Sniezek, Director Division of Resident and Regional Reactor Inspection, IE FROM:

SUBJECT:

D-G. Eisenhut, Director Division of Licensing, NRR TERIN PROCEDURES AND TRAINING FO STATION BLACKOUT A decision by the Atomi Safety and Licensing ppeal Board (ALAB-603) concluded that station blackout (i... loss of all off te and onsite AC power) should be considered a design, basis vent for St.

Lug e Unit 2.

The Board further recoraaended that, in view of the completi h schedule for Generic Task A-44 (Station Blackout), espediti tous measures shou1d be taken to ensure that'p1ants with a comparable station blao out liky fhood can accoranodate such an event.

Based on our review of ALAB-60 we )Eve concluded that some interim measures should be taken while Task A-44 is hing conducted.

As described in the enclosed me ndum to Chairman Ahearne from H. R. Denton dated November 10, 1980, we pla t issue a generic letter to all licensees (except FPSL f'r St. Lucie Uni s

1

2) which requests that they ioylement interim emergency procedures nd a t ining program for station blackout events by June 1, 1981.

A sample eneric le er is contained in the enclosure.

i<e request tt>at IE verify th the emergen procedures and training program are implemented for all opere ing plants by ne 1, 198'l or an alternate date-accepted by the NRR stgff.

Although ther are no detailed acceptance criteria for this action, a list of the basic consi rations which should be addressed in the interim proce ures is contained in th sample generic letter.

Should you have a

questions regarding this ac ion, contact C. Nelson (X27563).

Encl sure:

As tated Darrell G. Eisenhu Director Division of Licensin Office of Nuclear Rea tor Regulation See next page OFFICE SURNAME

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H. Denton V. Stello R. Tedesco T. Novak E. Jordan F. Niraglia R. Reid G. Edison P. Norian P.

Haranowsky C. Nelson C. Grimes J.

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NUCLEAR R EGULATORY COtilf.'ISSION WASHINGTON, O. C. 20555 NOY 10 1980 Attachment 1

MEMORANDUM FOR:

Chairman Ahearne FROM:

THRU:

Harold R. Denton, Director Office of Nuclear Reactor Regulation Milliam J. Dircks Executive Director for Operations

SUBJECT:

STATION BLACKOUT In our memorandum dated September 26, 1980, we presented the A-44 Task Action Plan for station blackout (loss of all AC power events) and indicated that implementation of the ALAB-603 recomendations was being evaluated in response to your inquiry of August 20, 1980.

The purpose of this memorandum is to describe the action plan which we believe will resolve the Board's concern and to respond to your subsequent follow-up questions of October 24, 1980.

The Atomic Safety and Licensing Appeal Board (ALAB-603) concluded that station blackout should be considered a design basis event for St. Lucie Unit 2 and recomended that, in view of the completion schedule for Task A-44, "for nuclear power facilities with a station blackout likelihood cooqarable to that of St. Lucie Unit 2, expeditious measures be taken" to ensure that these plants and their operators are equipped to accomodate such an event i'n a manner that assures the public health and safety."

Our initial response to the Board's decision was to amend the-construction permit for St. Lucie Unit 2 (September 18, 1980) to require that station blackout be included as a design basis

event, as was ordered by the Board.

A similar requirement has been imposed on St. Lucie Unit 1, under the provisions of 10 CFR Part 50.54 (f), in order to provide consistency in the design basis for the sister plant.

As described in the attachediIIemraTIdum from R--M; Bernero dated August 22, 1980 (Enclosure 1), the probability. ofmtation blackout is not significantly different between St. Lucie and all other nuclear power plants.

This asser-tion is based on the preliminary staff study mentioned-in Section 3 of TAP A-44., All plants, including 5t. Lucie, are comparable in station-blackout--

probability within the uncertainty band.

Me are currently updating that stuQ with'oproved data and more careful documentation of the assumptions and limitations.

Section 3 of TAP A-44 provides the basis for continued plant licensing and operation.

The preliminary probabilistic stu@ provides supplementary information to the Bulletins and Orders'equirements cited-+n- '-

that section, which were the principal bases for continued operation.

The extent to which station blackout should be considered in the design of all other plants, and the criteria by which it should be considered, will be established by Task A-44.

Me have reviewed the schedule for Task A-44 and conclude that it cannot be significantly iaproved.

Nevertheless, we concur with the Board's recomendation that some interim measures should be taken while Task A-44 is being conducted.

Contact:

C. Grimes, DOL X28204

0 Chairman Ahearne Consequently, we plan to issue the enclosed generic letter (Enclosure 2),

which requires that all licensees and applicants develop interim emergency procedures and a training program for station blackout events.

We believe that this action will resolve the Board's concern for the period while Task A-44 is being conducted.

In addition, there are some short-term system improvements associated with other actions which will reduce the potential for and consequences of a station blackout event.

These are:

1.

The short-term ioyrovements to the auxiliary feedwater system in PWR plants associated with Task II.E.1.1 of the TMI-2 Action Plan (NUREG-0660).

These irrprovements are scheduled-to be completed by July 1, 1981.

r 2.

The installation of quencher safety-relief valve discharge devices in BWR plants associated with the Mark I Containment Long Term Program.

The schedules for the Mark I-related plant modifications are described in SECY-80-359 and SECY-80-359A.

3.

The recomendations for improvements to the emergency diesel gen-erators which have evolved from a recent contractor study of diesel reliability (NUREG/CR-0660).

These recomendations are currently being implemented on OL license applications and a program for implementation for the operating reactors, including improvements to the related Technical Specifications, is being developed.

We believe that the development of emergency procedures and training programs, as described in the enclosed generic letter, coupled with the stated basis for continued plant operation'described in the A-44 Task Action Plan, are suffic-ient to resolve the Board'-s concern-relative to the ability of the operating plants to acconmodate a station blackout event. 'wc.- Z+

Harold R. Denton. Director Office of Nuclear Reactor Regulation Encl osu res:

1.

Memorandum from R. M. Bernero to H. R. Denton dated August 22, 1980.

2. Station Blackout Generic Letter cc:

Comnissioner Gilinsky Colnnissioner Hendrie Coranissioner Bradford OGC OPE SECY

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t VNITEDSTATES NUCLEAR REGUI ATORY COMMISSION lYASHIPdta TOM, O. C. 20555 4UG 22 580 t i:ct cr'suRE THRU:

MEHORANDUN FOR:

. Harold R.'Denton, Director Office of Nuclear Reactor Regulation Thomas E. Morley, Actfng Director Office of Nuclear Regulatory Research FR@!:

SUBJECT:

Robert H. Bernero, Dfrector Division of Systans and Reliability Research Office of Nuclear Regulatory Research ALAS DECISION 603,DATED hlULY 30, 1980 ON STATION BLACKOUT AT ST. LVCIE UNIT 2 The purpose of this memorandum fs to offer comments on the recent ru1fng by the Appeal Board on St. Lucfe 2 (ALAB-603).

Me do not agree wfth conclusfon 4, 'that a complete loss of AC powerstation blackoutaiust be considered a design basfs event

%or St. Lucfe Vnft 2.'laws are apparent fn ALAB-603 fn a number of areas:

The quantitative crfterfon for action.

2.

The foreclosure of alternatfves to deal Hth blackout.

3.

Assumption that 5t. Lucie 2 is exceptfonally prone to blackout.

These problem areas-are-discusaed~rther-beloW 1 ~

antftatfve Crfterfon for Action It is cleat the criterion of acceptability chosen by ALAB (p. 31 of the decision) was never intended by the staff to be applied.in.such a way.

Section 2..3 of the Standard Review Plan explicitlylimits the use of the 10 criterion (areas of review) to 'accid.ents involving nearby industrial, military, and transportation facilities'nd potent)al accidents involving hazardous materials o'r scUxttfeMn the vicinity of the plant' that is, to external hazards such as nearby transportation of toxic gases or explosives.

This is not to say that a probability goal is not appropriate for station black-out-Station b1ackout lends itself aare readily to a probabflistfc goal than do some other event sequences.

I@waver, we believe:a =.-.

probabflfstfc goal fn the neighborhood of 10 per plant-year

$s Narc reasonable for a potential core damage accident resulting from sta)ion bin~tout.

As an interim goal, for say g years, a range of 10 to 10 would entaf1 a afnfmal rfsk at operating reactors

",i Harold L. Dcnton w7w

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ygG 2 2 580 whfle a rore permanent probabilfstfc staff objective fs developed.

Indeed, fmprovements over the last 7 or B years fn our knowledge of the severity of core damage accidents raise the question of whether the 10 criterion might be unnecessarily restrfctfve even for external hazards.

Me recognize that there exists no criterion fn the record,.so one can hardly blame the Appeal Board foor somewhat arbitrarily selecting Section 2.2.3 as their basis.

Clarification of the staff objective fs sorely needed, and we belfeve this should be a top priority not only for station blackout but for other important transfents such as loss of feedwater.

2.

F'oreclosvre of Alternntfves The ALAB-603 conclusfons do not provide for what we think fs an acceptable alternative to making station blackout a design basis event.

One alternative fs to reduce the probabflfty of a station blackout.

This could be done by improving the reliability of the

'mergency onsfte AC power supply system.

For example, an additional diesel generator (with diversity fn manufacturer, size, testing, etc.). or a gas turbine could make significant improvement.

Another alternatfve auld be an NRC-approved plan and procedures f'or the restoration of offsfte power and emergency onsfte power.

Note that ALAB assumed the probability of restoring offsfte power was zero and also that the probability of getting one of the diesel generators started '(after fnftfally failing to start) was zero.

Yet, the conclusion was drawn on page 69 that 'there fs a high lfkelfhood that following statfon blackout, a source of AC power can be restored before events resulting Srom its loss produce reactor. core damage.'f the Board had fncluded a probability for AC power restoration, we think (and their above-stated conclusfon supports us) ft could reduce the calculated-coreAamage-yrobabflfty from-station blackout by as much as a factor of 10.

Approved AC power restoration procedures could also sfgnfffcantly 1 fmft the time interval for which ft fs necessary to assure that the. decay-heat removal systems are fndependent

. Of AC power

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3.

Assum tfon that St. l.ucfe 3s Exce tfonall Prone to Blackout There are at least two potentfal major fmpacts of ALAB-603 on the 1fcensfng process and on operating reactors.

~ First ff the-conclusfon..-~

re fr in statfon blackout W be a design basis event at St. Lucfe s accepted, then ft surely must be applied to other operating reactop since nest are fn the same probability range, f.e., 10 to 10 per plant-year for experfencfng a station blackout.

Current estfmates of statfon blackout probability, based on operating experience, do not confirm the premise that Florida-based plants are exceptionally prone to ihat event..

Compared to other plants fn

Harold R. Denton

&3'ur, 2.2 BSO the U.S., for example, the loss of offsfte power at Florida plants fs only a little more frequent (perhaps a factor of 2) than the national average.

A crude survey of operating experfence fndicates to us that there are at least 8 plant sftes with acre frequent loss of offsite power than ~an of the Florfda plants.

This may be because different failure mechanisms such as tornadoes, fce storms, lightning, electrfcal demand surges, grid reliability, etc. are operating fn different geographical regions.

For example, two of the higher frequency plants. are fn the midwest (tornadoes7),

two're on northern great lakes (winds, fce, lfghtning7), three are on the northeast seaboard (weather, grid ties, demand surges7) and one fs near the Gulf of mexico (weather, grid connection7).

Thus, while grid reliability may be somewhat lower for Florida plants, a

number of other causes of power loss are not present fn Florida.

Furthermore, the loss of onsfte emergency AC power does not appear to be a strong function of geographical location.

thus, Florida plants (including St. Lucfe Vnft 2) auld not appear to have inherent failure mechanfsms of their emergency AC power that are peculiar to the peninsular geography.

w7 A second ~ssfble impact could occur ff the application of the 10'riterion to a potential accident sequence (such as a station blackout transient) fs accepted; it might then become a precedent by which to )udge other transients and LOCAs. It is likely that I current or planned commercial operating reactor could meet such'a severe criterion.

The probability of core damage accidents due tn other transient and LOCA sequences has fregvently Pen.esttmated by NRC over the last 8 years to be -fn the 10 to.10" range at operatfng-r eactors.

In sunroary, whf'te we agree 8th much of ALAB-603 and feel 4t fs a well-..

written lucid presentation of the station blackout concerns, we do mt agree that station blackout must be considered a design basis event at St. Lucie Unit 2.

CC M. Payton, ELD M. Olmstead, ELD R. Bfrkel, NRR K. Knfel, NRR G. Edison, RES Robert N. Bernero,D re tor....

-Sfvfsfon of Systems and Relfabflftg Research Offfce of Nuclear Regulatory Researclf P. Baranows+,

RES F. Rosa, NRR R. Fftzpatrfck, NRR P. Check, NRR D

Ross; NRR

ENCLOSURE 2

TO:

ALL LICENSEES OF OPERATING NUCLEAR POWER REACTORS AND APPLICANTS FOR OPERATING LICENSES

SUBJECT:

EMERGENCY PROCEDURES'AND TRAINING, FOR STATION BLACKOUT EVENTS A recent decision by the Atomic Safety Licensing and Appeal Board. (ALAB-603) concluded that station blackout (i.e., loss of all AC power) should be considered a design basis eveht for St. Lucie Unit 2.

An amendment to the Construction Permit for St. Lucie Unit 2 was subsequently issued on September 18, 1980.

The NRC staff is currently assessing station blackout events on a

generic basis (Generic Task A-44).

The results of this study, which is sched-uled to be completed in 1982, will identify the extent to which design pro-visions should be included to reduce the potential for or consequences of a

station blackout event-However, the Board has recomnended that acre iomediate measures be taken to ensure that station blackout events can be accowedated while Task A-44.is being conducted.

Although we believe that, qualitatively, there appears to be sufficient time available following a station blackout event to restore AC power, we concur that some interim measures should be taken.

Consequently, we require that you promptly inclement interim emergency" pro-cedures and a training program for the existing systems in your facility for station blackout events, if such procedures and training do not already exist.

The emergency procedures should consider, but are not limited to:

a.

The actions and equipment necessary to maintain the reactor coolant inventory and heat removal with only DC power available, including consideration of the unavailability of auxiliary systems such as venti lation and component zool4+g.=-

b.

The estimated limiting time to restore AC pmer and its basis.

c.

The actions for restoring offsite AC power in the event of a loss of the grid.

d. The actions for restoring offsite AC power when its loss is due to postulated onsite equipment failures.

e.

The actions necessary to restore emergency onsite AC power-The actions required to restart diesel generators should include consid-eration of the unavailability of AC pmer.

For example, unsuccessful attempts to start.diesel generators may result.dn depletion of the coo@ressed air.tanks.

After repairs or adjustm nts, further attempts to start the diesels may not be possible without recharging the air, tanks.

In the absence of AC power, provisions may be necessary for portable air tanks, manual air pumps, DC cooqressors, etc..

f. Consideration of the availability of emergency lighting, and any actions required to provide such lighting, in equipment areas where operator or maintenance actions may be necessary.

g.

Precautions to prevent equipment damage during the return to normal operating conditions following restoration of AC power.

For example, the limitations and operating sequence requirements which must be followed to restart the reactor coolant pumps following an extended loss of seal injection water should be considered in the recovery procedures.

The annual requalification training program should consider the emergency procedures and include simulator exercises involving the postulated loss of all AC power and decay heat removal accomplished by natural circulation and the steam-driven auxiliary feedwater system for PWR plants, and by the steam-driven RCIC and/or HPCI and the safety-relief valves in BWR plants.

We require that the actions described above be completed by June 1,

1981 for the licensed nuclear power reactors and plants licensed before that date, or prior to licensing for plants licensed after that date.

The staff's review of these actions will be accomplished as part of the implementation of the recommendations which evolve from Task A-44 and implementation of the long-term programs related to emergency procedures and training in the TMI-2 Action Plan (NUREG-0660).

The interim procedures developed in response to this request will eventually be placed by the final procedures which evolve from Tasks I.C.1 (3) and I.C.9 of the TMI-2 Action Plan.

Accordingly, pursuant to 10 CFR 50.54(f) licensees are requested to furnish, within forty-five (45) days of this letter, confirmation that the implementation date of June 1,

1981 will be met.

For plants licensed after this letter, these actions and the implementation schedule will be incorporated as license con-ditions.

In the event that the completion date..cannot be met, furnish a proposed revised date, justification-/or the delay,. and any planned compensating safety actions during the interim. After our evaluation of your response, the NRC staff will take action, as-necessary;-to assure that.-such requirements and comni.tments--

are appropriately enforceable.

- This may include, as needed, issuance of 'a Confirmatory or Show-Cause Order.

Darrell G. Eisenhut, Director Division of Licensing

UNITEO STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O. C. 20555 Attachment 2

TO ALL LICENSEES OF OPERATING NUCLEAR POWER REACTORS AND APPLICANTS FOR OPERATING LICENSES (EXCEPT FOR ST.

LUCIE UNIT NOS.

1 8I 2)

SUBJECT:

EMERGENCY PROCEDURES AND TRAINING FOR STATION BLACKOUT EVENTS (Generic Letter 81-04)

A recent decision by the Atomic Safety and Licensing Appeal Board (ALAB-603) concluded that station blackout (i.e

, loss of all offsite and onsite AC power) should be considered a design basis event for St. Lucie Unit No. 2.

An amendment to the Construction Permit for St. Lucie Unit No.

2 was subsequently issued on September 18, 1980.

The NRC staff is currently assessing station blackout events on a generic basis (Unresolved Safety Issue A-44).

The results of this study, which is scheduled to be completed in 1982, will identify the extent to which design provisions should be included to reduce the potential for or consequences of a station blackout event.

However, the Board has recommended that more immediate measures be taken to ensure that station blackout events can be accommodated while task A-44 is being conducted.

Although we believe that, qualitatively, there appears to be sufficient time available following a station blackout event to restore AC power,,

we are not sure if licensees have adequately prepared their operators to act during a station blackout event.

Consequently, we request that you review your current plant operations to determine your capability to mitigate a station blackout event and promptly implement, as necessary, emergency procedures and a training program for station bl'ackout events.

Your review of procedures and training should

consider, but not be limited to:

a.

The actions necessary and equipment available to maintain the reactor coolant. inventory and heat removal with only DC power available, including consideration of the unavailability of auxiliary systems such as ventilation and component cooling.

b.

The estimated time available to restore AC power and its basis.

c.

The actions for restoring offs i te AC power in the event of a loss of the grid.

d.

The actions for restoring offsite AC power when its loss is due to postulated onsite equipment failures.

e.

The actions necessary to restore emergency onsite AC power.

The actions required to restart diesel generators should include consideration of loading sequence and the unavailability of AC power.

f.

Consideration of the availability of emergency lighting, and any actions required to provide such lighting, in equipment areas where operator or maintenance actions may be necessary.

I g.

Precautions to prevent equipment damage during the return to normal operating conditions following restoration of AC power.

For example, the limitations and operating sequence requirements which must be followed to restart the reactor coolant pumps following an extended loss of seal injection water should be considered in the recovery procedures.

The annual requalification training program should consider the emergency procedures and include simulator exercises involving the postulated loss of all AC power with decay heat removal being accomplished by natural circulation and the steam-driven auxiliary feedwater system for PWR plants, and by the steam-driven RCIC and/or HPCI and the safety-relief valves in BWR plants.

We conclude that the actions described above should be completed as soon as they reasonably can be (i.e., within 6 months).

In addition, so that we may determine whether your license should be amended to incorporate this require-ment, you are requested, pursuant to 550.54(f), to furnish within ninty (90) days of receipt of this letter, an assessment of your existing or planned facility procedures and training programs with respect to the matters described above.

Please refer to this letter in your response.

In the event that completion within 6 months can not be met, please propose a revised date and justification for the delay.

This request for information was approved by GAO under a blanket clearance number R0072 which expires November 30, 1983.

Comments on burden and duplication may be di rected to the U.S. General Accounting Office, Regulatory Reports

Review, Room 5106, 441 G Street, NW., Washington, D.C.

20548.

Sincerely, Darrel G. Eisenhut, Director Division o Licensing Office of Nuclear Reactor Regulation