ML19210C040
| ML19210C040 | |
| Person / Time | |
|---|---|
| Site: | 05000516, 05000517 |
| Issue date: | 10/10/1979 |
| From: | Vassallo D Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19210C037 | List: |
| References | |
| NUDOCS 7911130178 | |
| Download: ML19210C040 (4) | |
Text
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UNITED STATES 3
g NUCLEAR REGULATORY COMMISSION y
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October 10, 1979 (T0 ALL LICENSEES OF PLANTS UNDER CONSTRUCTION)
Gentlemen:
SUBJECT:
FOLLOWUP ACTIONS RESULTINC MOM THE NRC STAFF REVIEWS REGARDING THE THREE MILE ISLAND UNIT 2 ACCIDENT Over the past seveial months following the Three Mile Island accident, the NRC staff has been conducting an intensive review of the design and operational aspects of nuclear power olants and the emergency procedures for coping with potential accidents. The purpose of these efforts was to identify measures that should be taken in the short-term to reduce the likelihood of such accidents and to improve the emergent.y preparedness in responding to such events. To carry out this review, efforts within NRR were established in four areas:
(a) licensee emergency preparedness, (b) operator licensing, (c) bulletins and orders followup (primarily in the areas of auxiliary feedwater systems M iability; loss of feedwater and small break loss-of-coolant accident analysis; emergency operating guidelines and procedures) and (d) Short-Term Lessons Learned.
The purpose of this letter is to provide for planning and guidance purposes the NRR staff position on the status and applicability of the results of these efforts to plaras under construction. The Comission may add to or modify these staff positions after reviewing them. Additional staff require-ments may be developed as NRR's Lessons Learned Task Force completes its long-term recommendations. Several other investigations, including the Presidential Comission and NRC's Special Inquiry Group, can be expected to lead to addi-tional requirements.
Lessons Learned Task Force Report The principal element of the staff activities listed above is contained in the report titled, "TMI-2 Lessons Learned Task Force Status Report and Shurt-Term Recomendations" (NUREG-0578), a copy of which was previously sent to you. The Task Force report contains a set of recommendations to be implemented in two stages over the next 16 months on operating plants and penriing operating license applications. The Task Force recomended 20 licensing requirements and three rulemaking matters in 12 broad areas.
The Advisory Comittee on Reactor Safeguards has completed its review of the Task Force report. The several public meetings of the ACRS subcommittee on TMI-2 and the public meeting of the full committee on August 9 provided 7911130 /7U
-2 October 10, 1979 an opportunity for the presentation and discussion of public coments on the report. The ACRS letter of August 13, 1979 to Chairman Hendrie states that the Comittee agrees with the intent and substance of all the Task Force recomendations, except four upor which the Comittee offered con-structive coments to achieve the same objectives articulated by the Task Force. A copy of the ACRS letter is provided as Enclosure 1.
After evaluating all coments received, we have concluded that the following actions are appropriate for plants under construction.
(a) The staff will be proposing a new rule on a Limiting Condition of Operation to require plant shutdown for certain htsaan or procedural errors, particularly those which are repetitive in nature. As such, no action is required on your part at this time.
(b) At the present time we are delaying effor's regarding proposed rule-making on both the inerting requirements for Mark I and II BWR con-tainments, and the requirement regarding hydrogen recombiner capability; accordingly, no action is required on your part at this time.
(c) The ACRS comments on the shift technical advisor have resulted in cur reassessment of the possible means of achieving the two functions which the Task Force intended to provide by this requirement. The two functions are accident assessment and operating experience assess-ment by people onsite with engineering competence and certain other characteristics. We have concluded that the shift technic:' advisor concept is the preforable short-term method of supplying these functions. We have also concluded that some flexibility in implementa-tion may yield the desired results if there is management innovation by individual licensees. We have prepared a statement of functional characteristics for the shift technical advisor that will be used by the staff in the review of any alternatives proposed by applic;nts for operating license. A copy is provided as Enclosure 2.
The Comission is considering whether or not additional qualifications should be required for this individual.
(d) Three additional instrtsnentation requirements for short-term acticn were developed during the ACRS review cf NUREG-0578. Thesa items relate to containment pressure, containment water level and contain-ment hydrogen monitors designed to follow the course of an accident.
Descriptions of these items are provided in Enclosure 3.
(e) An additional requirement following issuance of NUREG-0578, which conce ned a remotely operable high point vent for gas from the reactor coolant system, was developed. A description cf this requirement is provided in Enclosure 4.
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% October 10, 1979 (f) The Lessons Learned Task Force has compiled a set of errata and clarify-ing comments for NUREG-0578. It is provided as Enclosure 5.
Following our review of the proposed Task Force recomendations, ACRS review and coments received, we have concluded that all licensees of plants under construction should implement the actions contained in NUREG-0578, as modified and/or supplemented by items (a) through (f' above. Therefore, we suggest that you also consider these regt.irements '
eveloping your final plant design and procedures, and include a descriptiot ;f your actions in this regard in your application for an operating licer.se. An implementation schedule for operating plants and pending operating license applications is provided in Enclosure 6 for information. The implementation dates for the Cornission rulemaking actions and those deferred actions, identified above, will be established later.
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Other Review Areas outlines the requirements developed to date resulting from the staff's Emergency Preparedness Studies. Enclosure 8, which applies to oper-ating plants and pending operating license applications, provides the imple-mer.tation schedules for the emergency preparedness recomendations which, you will note, incluces three of the Lessons Learned topics. The staff position is that you should comply with each of the recommendations of.
Therefore, we suggest that you also consider these requirements in developing your final plant design and procedures, and incluce a description of your actions in this regard in your application for an operating license.
Further, the Comission has initiated a rulemaking procedure, now scheduled for completion in January 1980 in the area of Emsrgency Planning and Preparedness.
Additional requirements are to be expected when rulemaking is completed and some modifications to the emergency preparedness requirements contained in this letter may be necessary. outlines the staff recomendations concerning improvements in the area of operator training which are provided for your information.
These recomendations are undergoing Comission review and are expected to be adopted as requirements in the near future. Further Comission review in the dreas of operator training and qualification can be expected to result in substantial additional requirements.
A nurter of other related actions on your facility may have been initiated under the direction of the NRR Bulletins and Orders Task Group. Each licensee will receive additional guidance from this group, particularly related to auxiliary feedwater systems and small break LOCAs, in the near future. Your activities should continue in these areas, as all the mentioned activities are meant to complement one another.
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. October 10, 1979 The measures discussed above represent a set of requirements that the staff has concluded should be implemented at this time. As stated earlier, other requirements may follow in the future. The procedures for Commission review of TMI-related issues prior to the issucice of operating licenses have not yet been established. The Commission is considering several alternatives, and you will be notified when a decision is made in this matter.
If you have any questions regarding these actions, please contact the NRC Project Manager for your facility.
Sincerely,
~
Domenic B. Vassallo, Acting Director Division of Project Management
Enclosures:
1.
ACRS Ltr: Carbon to Hendrie dtd 8/13/79 2.
Alternatives to Shift Technical Advisor 3.
Irstrumentation to Monitor Containment Conditions 4.
Installation of Remotely Operated High Point Vents in the Reactor Coolant System 5.
NUREG-0578 Errata 6.
Implementation Schedule 7.
Requirements for Improving Emergency Preparedness 8.
Emergency Preparedness Improve-ments - Implementation Schedule 9.
Improvements in Operator Training 1319 282
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- 'o, UP'ITED STATES NUCLFAR REGULATORY CCMMISSION f.~ ~..C, ADVISCRY CCMMITTEE CN REACTOR SAFEGUAADS 2,, n..':
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August 13, 1979 Honorable Joseph M. "Hendrie Chairman U.S. Nuclear Regulatory Commission Washington, D.C.
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SECRT-TIRM FIC3dy.NOAT!CNS CF "MI-2 LIS5CNS Lt.h:.J TASK FCRCE
" ear Dr. Hendrie:
During its 232nd meeting, August 9-11, 1979, the,E viso:f C=mittee on Reactor Safeguards completed a review of the short-term recraendations of the ':MI-2 Lessons Lear 403 Task Force as reported in N'e'RIL-0578.
Sese recxcendations had been revied in part, by an AC?S Sebcoenittee at a meeting in Washington, D.C., on July 27, 1979. During its review the Comittee had the benefit of discussions with menbers of the Task Force.
C==ents from representatives of the nuclear industry *,.ere also considered.
In its review, tne Cxmittee has noted that de recxcendations in NUREG-0578 are those deemed by the Task Force to be required in de short term to provide subst1ntial additional protection for ce public health and safety.
Se Cecaittee has considered beta de recorcendations themselves and de schedules proposed for Seir implementation. Fegarding ee latter, the Committee believes that the orderly and effective implementation and de aopropriate level of review and approval by the NRC Staff will require a somewhat more flexible, and in scme cases more extended, schedule than is implied by NUREG-0578.
With regard to the requirements demselves, the Cx=ittee agrees with de intent and substance of all except Sc<,e discussed below.
2.1.5
? cst-Accident Hvdrocen4cntrol Systems a,.
Se Cxmittee agrees with de recxcendations relating to dedicated penetrations for external recx.biners or purge systems for operating plants that have such systems,
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2e majority of the Task Force has recxcended rule-making to require inerting of %R.trk I and !! reactors. A minority of de Task Force has recxmended rule-making to require Sat all ocerating light -ater j
reactors provide the :acability to use a hydrogen recr.biner.
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Honorable Joseph M. Hendrie Agust 13,1979
"'he Cxmittee believes that questions relattng to hydrogen generation during and following an accident, the rate and ameunt of generation, the need to control it. and the means of doing so, need to be reexanined. De Task Force has advised the Cermittee that it is considering this question furder in connection with its longer-term recxcendations dich are sched-uled to be completed by September,1979. Be ACRS believes that decisions cracerning possible additional measures to deal with hydrogen should be deferred pending early evaluation of the forther.ing longer-term Task Force recxcendations.
2.1.8 Instrur.entatien to Follcw the Course of an Accident With regard to instrunentation to follow the course of an accident, the ACRS believes that containment pressure, centai cent wter level, and on-line monitoring of hydrogen concentration in the contairrnent should also be considered for implementation tor all operring reactors on de same schedule as that recxcended by the fassons Learned Task Fo rce.
2.2.1.b Shif t Techn; cal Advisor te Committee agrees ex.pletely with the two closely related cbjectives of this recxcendation. 01e relate-to the presence in the control room dur-ing off-normal events of an indi fidual having technical and analytical capability and dedicated to concern for safety of the plant. Be other relates to de need for an on-site, and perhaps dedicated, engineering staff to review and evaluate safety-related aspects of plant design and operation.
3e a:hievement of these objectives will contribute significantly to 2e safe operation of a plant.
De Committee believes that there may be difficulty in finding a suf ficient nt.Ser of people with 2e required qualifications and interest in shift work to fill the Technical Advisor positions. 2e Orcittee derefore believes the solution proposed by the Staff should not be mandatory but that alternate solutions also should be considered.
2.2.3 Revised Limitino Conditiens for 0:eratien Se Craittee agrees with de findings of de Task Force dat dere are too many htinan or operational errors resulting in ce defeat of an entire safety system, that ce ntr.ber of such occ :rrences should be and' can be reduced, and that the ultimate responsibility for doing this must rest with the licensee.
Se Cxmittee, however, is net cervinced that the Task Force propesal is the best or only my to increase de licensee's awareness of the j'3)3 2bk
Henorable Joseph M. Hendrie August 13, 1979 need to improve operational reliability, and suggests that measures short of shutdown, such as a rule that recuires actions similar to those of a show-cause order, may be eg ally effective.
Sincerely, A
Max W. Carbon Gairman
References:
1.
NLREU-0578, "mI-2 Lessons Learned Task Force Status Report and Short-Term Rec:mendations," Cffice of Nuclear Reactor Regulation, U.S.
Nuclear Regulatory Coemission, July 1979.
2.
Iatter, D. Knuth, President, :OC, Inc., to Harold Denton, Director, Cffice of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commis-sion, August 8,1979,
Subject:
mI-2 Lessons Learned Task Force Report (NURin-0578).
3.
Letter, Stanley Ragone, President, Mrginia Electric and Powr Company, to Joseph M. Hendrie, Gairman, U.S. S -lear Regulatory Corcission, August 8,1979,
Subject:
Cassons Learne J Task Force on mI-2, NLRIG--3578.
4.
Iatter, Floyd W. Lewis, Chairman, Ad Hoc Nuclear Oversight Conmittee, to Harold R. Denton, Director, Cffice of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, August 1,1979,
Subject:
Iessons Imarned from NI-2.
5.
tatter, American Nuclear Society, ANS-3 Committee, to Joseph M. Hendrie, Gairman, U.S. Nuclear Regulatory Commission, August 2,1979,
Subject:
Iassons Learned Task Force Status Report NLREG-0578.
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.;i E:s?ATEs NLCLIAA 9E3ULATCRY CMM:SS:CN 4, k -d.
[r acvisoRY CO.".tMCEE ON REACTOR sAFEGUAROs r'f usmscT:s :. :. ::sss August 15, 1973 MEMCRANCUM :CR: Chai: nan Mendrie FRCM:
Raymer.d F. Frale
_xt:cutive Direc:ce, CRS
SUBJECT:
ADDITICNAL REFERENCES TO ACRS LE ER N SHCRT-TERM RECCMMENCAT!CNS CF TMI-2 LESSCNS LEARNE0 TASK FCRCE CATED AUGUST 13, 1979 The attached revised Page 3 of :ne subject letter snculd be substituted for the one which was originally sen: Oc you.
This ;: age inccc:: crates additional references 6, 7, and 3.
Attachment:
Revised Page 3 cc:
Comissioner Gilinsky Cormtissicner <ennedy Comissicner 3racfore Ocmissioner 2hearne 7
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