ML18047A497
| ML18047A497 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/02/1982 |
| From: | Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| TASK-***, TASK-RR NUDOCS 8208050072 | |
| Download: ML18047A497 (5) | |
Text
consumem Power company General Offices: 1945 Parnell Road, Jackson, Michigan 49201 * (517) 788-1217 August 2, 1982 Harold R Denton, Director Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
COMMENTS ON SYSTEMATIC EVALUATION PROGRAM Russell B. DeWitt Vice President Nuclear Operations The NRC staff in a letter dated July 14, 1982, requested comments on the Systematic Evaluation Program, Phase II, nearing completion for Palisades, and the proposal for Phase III which is now being discussed with the Commis-sioners.
We appreciate the opportunity to respond to that request.
A great deal of experience has been gained over the past five years by both the NRC and the participating utilities - experience.which should prove to be of great mutual value in the way the NRC and utilities manage future regulatory issues.
In concept the SEP was originally defined as a realistic assessment of the safety of eleven older plants.
The program was presented to the participating utilities and the Commissioners as an NRC effort which would have minimal impact on licensee resources. It also offered the promise of looking at a number of issues in the context of the overall plant to determine which backfits might of fer real improvements in safety regardless of current NRC design guidance.
In short, it sounded like a rational program to satisfy the NRC's charter for protecting the health and safety of the public as well as allow utilities to avoid piecemeal, single-issue NRC requirements for changes which did not necessarily make "safety sense" in the context of the entire plant.
Unfortunately, we can not say unequivocally that these objectives were met.
Two factors significantly influence that judgment.
First, the SEP turned into a much more massive effort than many people imagined at the start.
Instead of being a staff program, it became a licensee program directed by the staff.
To date nearly 45,000 manhours of Consumers Power Company technical effort and an additional $2.5 million of consultant work have been expended in support of about 11 NRC professional staff years and $710,000 of NRC contractor effort (as estimated by the staff in an ACRS Subcommittee Meeting on April 15, 1982).
The Palisades costs do not include~
modifications or costs of clerical support, etc.
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Harold R Denton, Director Palisades Plant August 2, 1982 2
Second, many of the issues were addressed piecemeal with final staff positions derived on individual issue bases.
Much of the effective integration was provided by Consumers Power Company. This did not severely impact the Palisades effort because few items of significance were identified, but this program weakness would have had a much greater impact on older Phase II plants.
The ability to integrate issues into the context of overall plant safety was primarily centered with the Site Resident Inspector, a few key individuals within the SEPB and RRAB and Consumers Power Company.
NRC contractors in general and many other technical organizations within the NRC were did not attempt to view their specialties in real terms of overall plant safety.
In general terms, we must conclude that the result of the SEP for Palisades did not justify its cost.
Few items were identified which could be considered of major importance.
Essentially all the corrective actions which will result are associated with mitigating extreme low probability events. It must also be kept in mind that the real cost of discovering these items has not only been the man hours and direct dollars expended but also the opportunity cost of having limited engineering resources assigned to the SEP rather than to other more immediate issues.
Severe competition for those limited resources resulted from other NRC mandated programs including fire protection, TMI actions, Security, EEQ, emergency planning and other generic issues as well as the daily administration, operation and maintenance of the plant.
The NRC did not appear to give due consideration to this fact.
In the following paragraphs a number of detailed comments are presented in two general categories. First additional comments are provided on the Phase II effort to reflect experience which is pertinent to any large program such as SEP.
Second, specific recommendations are provided which should be considered prior to initiating the proposed Phase III of SEP.
SEP Phase II Experience
- 1.
By their nature, SEP Topic reviews were very resource-intensive, time-consuming efforts.
Since the review criteria did not exist in many cases during plant design, little or no documentation existed to show that those criteria were met.
The reviews, therefore, tended to be open-ended and very difficult to scope and schedule accurately.
The.
level of effort to review alternative or equivalent features which met the review criteria could not be determined until the basic design comparison was complete.
In other words, the SEP reviews were much different from new 01 reviews and frequently much more difficult and time consuming.
The recent emphasis placed on schedules has severely strained Consumers Power Company resources as we have worked to maintain the level of quality we feel is mandatory for SEP type reviews.
- 2.
The probabilistic assessment of differences from review criteria performed for the Palisades Integrated Assessment was of little actual value because it was not based on a Palisades PRA.
No true value-oc0782-0025a142
Harold R Denton, Director Palisades Plant August 2, 1982 3
impact analyses were performed for the SEP findings.
This did not significantly affect the final result because Palisades compared well with current criteria.
PRA's and value-impact studies will need to be considered much more carefully for older SEP Phase II plants.
In general Consumers Power Company feels that plant specific PRA's can be of great value in the evaluation of SEP-type issues as well as current issues.
- 3.
As mentioned above, severe competition for resources occurred because of SEP and other NRG-mandated activities.
As stated by Dr F W Buckman, CP Co Executive Director of Nuclear Activities, at the April 15, 1982 meeting of the ACRS Subcommittee on the SEP, "I have 100 people working for me and effectively all of them - by all I mean 80 to 90% ~ at one time are working on regulatory issues, working on requirements.
We are almost out of the business of doing discretion-ary work."
... "I think its a very sad state.
But the fact is that we have become a requirements oriented industry, and we are managing and, to some extent, the NRC is managing industry resources to work on requirements, and there's not a great deal of effort being put into things that are in the form of product improvements, operating improvements, things of that nature."
SEP Phase II could be characterized as just one of several major programs within the entire spectrum of other demands imposed by the NRC on the nuclear industry.
Various NRC organizations have each appeared to pursue their own individual interests on their own schedules without regard to overall priorities. Little effort seemed to be given to assuring that resources were dedicated to the most important issues first.
The result has been inefficiency in resource utilization and extensions of schedules for important as well as lesser important issues both within SEP in our attempts to meet schedules as well as outside the SEP.
- 4.
Credit has been taken under SEP for a number of modifications imple-mented at Palisades. It is true that some of the modifications satisfied SEP topic concerns, but many of these were initiated by Consumers Power Company even before the relevant topic reviews were performed.
This group includes the upgrading of station battery capacity; upgrading emergency diesel generator indication and DC power status indication in the control room; and changes to various containment penetration configurations.
SEP can take credit for the upgrade in electrical equipment seismic anchorages and the seismic supports for the diesel generator fuel oil day tanks.
The remaining modifications generally can be categorized as improving the mitigation capability for low probability events.
It is pertinent that the modifications are not primarily oriented toward prevention.
Experience Applicable to Proposed SEP Phase III
- 1.
Since Palisades is the newest of the SEP Phase II plants, its experience should be viewed as a good indicator of the plants of its oc0782-0025a142
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Harold R Denton, Director Palisades Plant 4
August 2, 1982 vintage as well as newer plants.
The results have shown that Palisades compares well with current criteria or their equivalent.
Even the external events such as earthquakes, tornadoes and floods were addressed in the original plant design in a manner substantially equivalent to new plants.
The Palisades design should not be considered unique because it should reflect the state-of-the-art in design for the time as well as the NRC staff thinking of the late 1960's and early 1970's.
Designs of plants being licensed typically reflect NRC opinions and attitudes of the time whether or not those attitudes are codified in regulations or guidance documents.
On this basis it can be concluded that there is not a significant safety problem - certainly not one which would warrant a Phase II level of effort on later plants.
If any reviews might be warranted at all for a few additional plants, the appropriate areas could be limited to high energy line breaks inside containment (not applied to pre 1974 plants) and selected areas in which single failure criteria may not have been applied uniformly to design basis event analyses (although many of these areas have now been addressed generically under various IE Bulletins, TMI Action Plan, Etc.).
- 2.
The current Phase III proposal (as presented to AIF on July 27, 1982) should be viewed with caution.
The 64 topics (approximately) listed define essentially the same scope program as SEP Phase II.
Many simply appear to be generalized to make a smaller list.
Topics which generally required little effort have been deleted.
The resources necessary to address the proposed list are likely to be substantially the same as those expended for Palisades.
This level of effort simply does not appear to be warranted in light of the Palisades results.
- 3.
If Phase III is approved as proposed (coupled with the National Reliability Evaluation Program), the result will likely be an even greater burden on the participating plants than Phase II has been on Palisades.
Completing an effort of this scope in two years is likely to be unrealistic.
The current Consumers Power Company estimate to perform a plant-specific PRA for Palisades is $2.5 million over a period of 2-1/2 years, somewhat less than but comparable to the cost of Phase II for Palisades.
If the currently envisioned SEP/NREP program is implemented within the proposed mandatory two year period the result could be a technically inferior product which could not be defended.
Obtaining what we believe to be a very good quality product for Palisades has taken twice that time for a program which would appear to be half the scope.
If any approach makes sense in light of today's experience, it would seem to be to eliminate SEP Phase III entirely and implement an NREP of some form on a schedule which appro-priately acknowledges its priority within the entire context of safe plant operation.
- 4.
In general a program such as SEP and in particular Phase III with its emphasis on plant hardware would not make the best use of industry resources today.
Palisades and probably every other operating nuclear plant has been upgraded substantially over the years.
In terms of oc0782-0025a142
Harold R Denton, Director 5
Palisades Plant August 2, 1982 hardware the plants are probably safer now than ever before.
What has been underemphasized, however is operational safety.
We strongly believe that the currently envisioned SEP Phase III is premature.
SEP Phase II should be fully completed and the results analyzed critically before any decision is made on the value of Phase III.
These analyses must consider safety significance of the findings
- not just the numerical accounting of how many plants met or didn't meet current SRP criteria.
We believe it imperative that the proposed programs be critically reviewed by the Committee to Review Generic Requirements as well as the nuclear industry so that a realistic assessment is made of the program's value as well as its impact.
As conceived this program is yet another example of NRC diversion of limited industry resources toward concerns about improbable events rather than the daily business of safe plant operation.
In spite of the problems associated with the SEP to date, one positive aspect of the program must be mentioned.
From our perspective the SEP in some ways was a radical departure from a general regulatory tendency to apply staff requirements or guidance uniformly to all plants without regard to design differences.
The SEP philosophy required various NRC staff members to learn in some depth how Palisades really was designed and operated, and then to use that information to assess more realistically the safety significance of the various criteria to Palisades - not to some generalized conception of a "typical" plant.
With this came more efficient communications and a degree of cooperation which has not been typical in recent years.
The basic SEP philosophy should not be lost as Phase II is completed, but should be more generally applied throughout the NRC.
This philosophy coupled with more centralized NRC control and prioritization of issues as well as greater sensi-tivity to resource limitations could have a positive impact on both the efficiency and effectiveness with which future regulatory issues are addressed.
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l5 6v>>d:b Russell B DeWitt, Vice President Nuclear Operations CC Administrator, Region III, USNRC NRC Resident Inspector-Palisades Deputy Executive Director for Regional Operations and Generic Requirements oc0?82-0025a142