ML18047A327

Submits Technical Evaluation Rept on Facility Integrated Plant Safety Assessment Per Draft NUREG-0820.Rept Fulfills Intent of SEP

ML18047A327
Person / Time
Site:	Palisades
Issue date:	04/27/1982
From:	Hendrie J BROOKHAVEN NATIONAL LABORATORY
To:	Russell W Office of Nuclear Reactor Regulation
Shared Package
ML18047A285	List: ML18047A284 ML18047A327 ML18047A328 ML18047A329 ML18047A330
References
CON-FIN-A-3367, RTR-NUREG-0820, RTR-NUREG-820 NUDOCS 8205190061
Download: ML18047A327 (8)

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BROOKHAVEN NATIONAL LABORATORY

[~ Q~ ~ ASSOCIATED UNIVERSITIES, INC.

Upton. Long Island, New York 11973 (516) 282,2443 Department of Nuclear Energy FTS 666/

April 27, 1982 Mr. William T. Russell, Chief Systematic Evaluation Program Branch Mail Stop 516 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 REF: INTEGRATED PLANT SAFETY ASSESSMENT, PALiSADES PLANT, SYSTEMATIC EVALUATION PROGRAM

Dear Bill:

This letter is my technical evaluation report on the Palisades Integrated Plant Safety Assessment as set down in NUREG-0820 (the draft report). It fulfills the requirements of Task 1 of the project "Consultant Services to Review SEP Integrated Plant Safety Assessment Reports," FIN A-3367, B&R_ No.

20-19-20-21-1.

CONCLUSIONS I believe the Systematic Evaluation Program, as represented by the Draft Integrated Plant Safety Assessment Report on the Palisades Plant, is fulfilling the intent of the commission when it authorized Phase II of the program in late 1977. I consider the staff recommendations for backfitting (and in other areas for no backfitting) for the Palisades Plant to be reasonable and appropriate and the bases upon which those recommendations are made to be adequate.

At this stage of the Palisades evaluation, several of the staff recommenda-tions (requirements, really) are for further analysis, evaluation, and testing by the licensee. When the results of these efforts are in hand, decisions will have to be made about possible equipment or procedural backfitting.

These decisions should be made on the same integrated assessment basis as those reported in the draft report. These "further evaluation" topics will need to be resolved before any proceedings on the full term operating license.

A number of topics that had been listed among the 137 safety topics to

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be considered in the Systematic Evaluation Program reviews are currently being _treated generically as Unresolved Safety Issues or as Three Mile Island Action Plan items and are, therefore, not included in the Palisades-specific review work reported in NUREG-0820. Also, there are two topics being treated generically, and thus outside the SEP Program, under other programs. One of these is the fire protection of associated circuits, being treated under implementation of Appendix R, 10CFR50, and the other is failure of main feedwater isolation, being treated under IE Bulletin 80-04. Palisades-specific resolutions for each of these topics will be needed eventually. With regard to the full term operating license, those Palisades-specific resolutions will either have to be in hand before any proceeding oa the full term operating license, or the Commission will have to explicitly exclude them from such proceedings.

DISCUS_SION THE OVERALL PROGRAM The Systematic Evaluation Program as it now functions was established late 1977, soon after I joined the Commission. Earlier work by the staff, in 1976, had resulted in Commission approval of a program to evaluate operating power reactors with re_spect to then-current licensing criteria, and to docum~nt the results of those evaluations and the need for any plant changes. The staff was told to prepare a list of safety topics to be considered under the program and to report back to the Commissio~. The staff did this in late 1977 and proposed a specific group of eleven older operating plants to be reviewed in what was called Phase II of the program. The objectives of the program were, and are, to (1) assess the safety adequacy of operating plants, (2) establish documentation to show compatibility with current requirements

,i or justification for deviations, (3) make "integrated and balanced" decisions J

on backfitting, (4) give early identification and resolution of significant deficiencies, and (5) use resources efficiently and minimize impacts on staff and industry.

The need for some sort of safety review of the older plants in particular had been obvious for some time. The ACRS had been recommending a systematic review of operating plants for many years. There were always questions arising, particularly with Congressional staff and committees, about whether the older plants, designed and constructed to an earlier set of safety standards,. still met the Commission.' s current regulations. Along with the need for some assessment of the safety adequacy of the older operating. plants, it was also clear that

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.. it would be most useful to have current documentation which would show the compatibility of the design of those *plants with current criteria or the basis for permitting deviations to exsist.

The assessement of safety adequacy by the staff for the Palisades plant, as evidenced in the draft report NUREG-0820, is, in my view," a competent and sufficient job on the items covered thus far. There remain, of course, the Unresolved Safety Issue topics and the Three Mile Island Action Plan topics for Palisades, as well as the two other generic items being pursued outside the SEP. Assuming that these will be treated for Palisades in the same fashion as the topics that have been reviewed and reported upon thus far, the safety assessment work~has been a thorough and careful job that meets the Commission's intent in this area.

Not every item conceivably related to sa~ety at a nuclear plant is encom-passed in the SEP, of course. The original culling of more then 800 possible items for consideration down to the final Phase I list of 137 topics indicates that very clearly. But, in my view, all of the important safety matters are being covered under the SEP for these older plants,*and that is what the Coilllllission wanted.

The documentation of the assessment, which is main.ly in the safety evaluation report letters, one for each of the SEP topics dealt with in the Palisades review, seems to me to be sufficient for the purpose. NUREG-0820 summarizes the assessment, deals with each of the 31 safety topics on which there were deviations and for which questions of backfitting arose, and includes in its appendices the Sandia report on probabilistic risk assessments of some topics and an Oak Ridge report on the operating history at Palisades. I presume that a supplement or supplements to NUREG-0820 will be issued to cover the outcome *of the Unresolved Safety Issue and Three Mile Island Action Plan items and also the results of current analyses and evaluations being carried out by the licensee.

A major element in my own approval of the Systematic Evaluation Program in 1977 was the proposition that these plant revi~ws would be done on a integrated and balanced basis in. recognition of the fact that they were dealing with plants that had been operating more or less successfully for some time. I would not have agreed to an SEP in which the review was to be done as if it were a new license, item by item, with all of the i's dotted and t's crossed.

What was needed in my view, if the work was to be done at all, was an overall safety assessment of the plant as an entity, looking for places where safety upgrading was clearly needed. After reviewing the Palisades documents, I

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conclude that the SEP staff has done a good job in performing that sort of "integrated and balanced" assessment.

Of the other two program objectives, early identification of significant deficiencies and efficient utilization of resources for both staff and industry, I note that no urgent safety deficiencies were found at Palisades, so there was no need to exercise that objective. As for the last objective, I am inclined to think the utilization of resources has been done reasonably efficiently, although the job has taken a lot longer then originally projected. Three Mile Island bears a substantial responsibility for this, of course.

I conclude that the staff, in carrying out the Systematic Evaluation Program assessment of the Palisades Plant, has fulfilled the Commission's intent as reflected in the major program objectives laid down in the staff papers that are the basis for the SEP.

POL-FTL CONVERSION One o~ the Commission's aims in establishing the SEP was that the safety assessment work and its documentation would serve as a primary basis for the*

conversion of provisional operating licenses held by five of the plants in the Phase II program to full term operating licenses. I recall, in fact, that this was a major consideration for me in approving the program. Those provisional operating licenses, automatically renewed every 18 months, had long been an embarrassemnt. Conversion to full term operating licenses was going to be necessary at some point, and the sooner the better. The SEP effort offered precisely the kind of safety review that was needed for the conversion, that is, one which took an integrated view of the whole plant and its operations from a safety standpoint.

The material at hand from the Palisades SEP review will be the primary documentation of the staff work and the plant status in going forward with conversion of the Palisades Provisional Operation_License. The material developed thus far will serve the purpose, I think. This objective of the SEP, then, is also being achieved. There are various parts of the review that are still to come, of course. The results of licensee evaluations, analyses, and tests now being done will have to be considered and any possible backfitting matters settled and documented in a supplement to NUREG-0820. There are two matters being treated generically under other programs that are, nevertheless, listed among the Palisades SEP topics.

These are the fire protection of associated circuits and main feed Water isolation. I presume that both of these will.be resolved for Palisades

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specifically and the results of those resolutions included in the Palisades POL-FTL conversion documents. Then there .are the major outstanding items, the Unresolved Safety Issue topics and the Three Mile Island Action Plan topics that are being treated generically under those two programs and outside the SEP. These include important safety topics for Palisades.

The POL-FTL conversion proceedings for Palisades cannot go forward until the results of the USI and TMI resolutions for Palisades are docu-mented, unless the Commission specifically removes these matters from con-sideration in the POL-FTL conversion proceedings. This latter course is a possible one and would be justifiable on the basis that when the generic resolutions of the USI and TMI topics are achieved, the operating license (possibly a full-term licenoe by that time) for Palisades would be amended -

to include those resolutions.

Although it is a possible course and could be justified as noted, I am inclined against it if there is any hope of achieving Palisades-specific resolutions of the outstanding USI and TMI topics. The reason is that setting them aside for later treatment as license amendments exposes the process to a second possible hearing when the USI and TMI amendments to the license are imposed. I expect that on most occasions these days when the oppor~unity for a hearing is offered, there will be a hearing. So, it would be handy all around if the USI and TMI outstanding topics could be resolved for Palisades on a schedule that would allow their inclusion in the proceeding on the POL-FTL conversion.

THE STAFF SAFETY REVIEW The Palisades Plant was reviewed against the 137 SEP safety topics.

These are listed in Appendix A of the draft report. These 137 topics were sorted out in early 1977, following Commission approval of the initial SEP proposal and in preparation for the October 1977 paper to the Connnission.

In spite of their age, it strikes me that the 137 safety topics still form an appropriate list of areas for review of these older plants.

Of the 137 topics, 23 are not applicable to Palisades and were deleted from the review. In addition, 24 topics were deleted from the Palisades review because they are being covered generically under the Unresolved Safety Issues or the Three Mile Island Action Plan programs. The remaining 90 topics are reported upon in the draft report NUREG-0820.

The 137 SEP topics are heavily oriented toward design matters. Only

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three are specific to the operation of the plant per se. These are XIII-!,

Conduct of Operation~; XIII-2, Safeguards/Industrial Security; and XVII, Operational Quality Assurance Program. The first, Conduct of Operations, is a TM! issue and is not treated in the draft report. (There is, however, a report commissioned by the SEP from Oak Ridge National Laboratory on the Palisades operations: This is given in Appendix F of the draft report.)

The other two topics are covered in the Palisades review and both were found to be satisfactory.

The 90 topic reviews came out in one of three ways: (1) Palisades either is consistent with, or equivalent to current licensing criteria. 57 of the topic reviews came out th"is way. (2) Palisades is not consistent with current licensing criteria, but the licensee has implemented or commitEed to implement equipment or procedural changes ~hat make it consistent with or equivalent to current criteria. Two topics came out this way. (3)

Palisades is not consistent with current licensing criteria and the topic was turned*over to a staff team for a integrated assessment and possible backfitting recommendations. 31 of the topics fell into this category.

No urgent safety problems were identified of a nature that required immediate action. Current licensing criteria are taken from the current Standard Review Plan (July, 1981).

In 14 of the 31 topics for which backfitting was a possibility, a probabilistic risk assessment was found to be possible either on the whole topic or on some subsection of it. The risk assessment was done on a relative basis by Sandia Laboratories. Sandia compared the Palisades as-is system with a backfitted system to obtain a measure of the reduction in risk (primarily in the probability of occurrence) that might follow from backfitting. The Sandia report is included in NVREG-0820 as Appendix D.

Since there is no complete probabilistic risk assessment for Palisades, or even_for a Combustion Engineering plant, the Sandia work had to depend on an unpublished risk assessment for Calvert Cliffs as a baseline. The re-sulting assessments of safety importance and of benefit in risk reduction from backfitting are _necessarily rough but are still useful inputs to be

.considered in the overall assessment of the topic.

The results of the integrated assessment of the 31 safety topics in which Palisades had significant deviations from current licensing criteria may be tallied as follows. The 31 topics include a number of topics which have several sections that had to be treated essentially as separate reviews.

If one counts all of these separable issues, *the 31 topics become 58 subtopics

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or issues. Of the 58 issues considered:

- 2 are being treated generically outside the SEP, 23 were found to require no backfitting measures, and

- 33 were found to require some backfitting measures.

Of the 33 issues that were found to require some backfitting.measures:

- 7 required equipment changes or additions,

-I1 - 14 required procedural changes or additions, and 12 required further analysis, evaluation, or testing, which could lead in turn to requirements for equipment or procedural changes or additions.

Of the 21 equipment or procedural changes and additions, 12 led to new Technical Specifications being required.

In addition, during the review, the licensee made or committed to various equipment changes and modifications under 5 topics. These would have added to the 31 topics or the 58 issues if they had not been fixed during the review.

So, *the integrated assessment team has, thus far, required equipment changes or additions in only 7 out of 58 safety issues before it. In addition, in 14 cases, issues were settled by procedural changes or additions.

Nevertheless, it seems clear that the integrated assessment team has not come down blindly for backfitting no matter what the cost or safety benefit; The October, 1977 staff paper, which was the basis of Commission approval of Phase II of the SEP, noted that when deviations from current licensing criteria were identified there were a number of alteratives or combinations of the same that would be considered as a basis for acceptability.

These included acceptance of the deviation as not significantly decreasing the saf~ty level, use of non-safety grade systems to perform safety functions, administrative or procedural changes to enhance safety system reliability, augmented surveillance programs for the same purpose, and selected back-fitting. Deviations from current criteria were to be acceptable if the staff evaluation showed that the plant would respond satisfactorily to the various design basis events and the probability of those or the consequences were not significantly higher than for plants licensed in accordance with current criteria.

In reviewing the safety evaluations of the 31 topics where significant deviations have been identified, I conclude that the SEP staff has followed that direction faithfully. They have looked carefully at the risk reduction and safety benefit to be achieved by any changes and have utilized all of

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the available alternatives in arriving at these final judgements. I think the staff bases for requiring equipment changes or modifications in the few cases where that has been done, for requiring procedural changes in other areas, and for concluding that no backfitting is required in yet other areas are adequate and reasonable and are consistent with the Commission's directives of long ago. I am particularly pleased to see the staff willing to declare that there is no need for backfitting in those cases where it offers little or no reduction in risk and would have substantial impact on the plant if required. That has not always been a characteristic of staff reviews.

It is going on 5 years since the SEP Phase II came before the Commission for approval. I voted for it with a certain amount of trepidation. I had some concern then over the staff's ability to do a balanced assessment on an older operating plant and to come up with results that were meaningful from a safety standpoint and did not simply end up requiring total conformance with current criteria regardless of the safety benefits. That concern did not abate much in the years following and I used to confront the bright- .

eyed proposers of an SEP Phase III with the direction to go back and produce something from Phase II and then we would see. Now we have the first product from Phase II. I think it is a good job. My compliments to the staff.

sft11cerely,

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