ML19249B557
| ML19249B557 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/30/1979 |
| From: | Lewis F MIDDLE SOUTH SERVICES, INC. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7909040555 | |
| Download: ML19249B557 (3) | |
Text
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MID DL.E SO UTH UTILITIES,1N O/ BOX E1005/N EW C A LE ANS, LA 70181/ l504l 529-52SE FLOVO w LEwtS CM AlRM AN/ CHIE F E X ECUYlVE August 30, 1979 Mr. Harold R. Denton Director Office of Nuclear Regulatory Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr. Denton:
In my letter of August 1, I addressed the short-term recommendations of the TMI Lessons Learned Task Force for a limiting condition for operation of nuclear power plants based upon operational error.
At that time, I co=mitted the TMI Ad Hoc Nuclear Oversight Committee to provide you by September 1 a plan designed to meet operational reliability, while protecting from unnecessary plant shutdowns the customers served.
Current operations for nuclear power plants are governed by Technical Specifica-tions that require shutdown of a plant upon loss of a safety system, whether from operational errors or for other reasons such as equipment failure.
The Technical Specifications also prescribe reporting requirements for such situations.
It is felt that operation in accordance with Technical Specification reauirements as presently conceived should remain the criteria for plant operation with additional actions as discussed below.
The NRC Task Force's recommendations regarding shutdown of a plant upon loss of a safcty system, whether from operational errors or for other reasons such as equipment f ailure, are not practical or in the public interest.
In an effort to assure attention by senior utility management, they could penalize electrical users by requiring shutdown even if a safety function has been restored. Wricten alternative corrective actions as the NRC Task Force proposes may not be necessary.
The proposed public meeting is impractical, not because of di losure but because of notice requirements and other formalities including unnecessary loss of elec-trical production.
This is not : say, howcVer, that the licensee should not itself review each loss of safety function at each operating plant and also review them with the Regional compliance office.
We would propose additional actions as hereinafter set forth.
To assure that the Nuclear Regulatory Commission and corporate management are being made aware of any operating condition affecting a safety function's operability, plant manage-ment would, on complete loss of operability of a safety function due to operational (2O\\
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I Mr. Harold R. Denton Page 2 August 30, 1979 error, make an immediate report to their Regional Inspection and Enforcement (I&E) office. Concurrently, that corporate officer having responsibility for nuclear power generation would also be notified.
That corporate officer, or his superior, would then make a prompt (as defined in Regulatory Guide 1.16, paragraph C2.a.)
notification to the Regional I&E Director to confirm the reported event.
This notification would also include a discussion of the short-term corrective action being taken to assure the safe operation of the plant.
Upon a complete loss-of-safety f unction due to operational error, the licensee would be required to conduct an investigation as to the cause of the incident and institute corrective action. Within 14 days of the incident, if requested, a meeting with the NRC Regional I&E Staff would be convened where the corporate officer responsible for nuclear pcwer generation would provide both orally and in writing the results of it b vestigation.
The investigation would include as i
a requirement for review the deliberations of a special designated off-site safety review task force.
The designated task force would conduct an investigation of the incident, as well as the action taken by the plant management.
It would then make its recommendation to senior corporate management of any additional action that should be taken by the individual plant, or state that the action taken was of a nature to reduce the possibility of this type of incident happening again.
Also, adding further support to the independence of the investigation, the R2;i-dent Nuclear Rebulatory Inspector assigned to that particular plant (if one has been assigned) could audit and evaluate management's actten.
If the cause of the incident is attributed to one or more individuals, it could be cause for retraining or it may indicate need for disciplinary action by the licensee. Since there may be a uumber of uiverse causes for the incident, we would expect the remedial action would and should be different for each situation and the same prescribed action may not be followed.
In suc=ary, the following procedures are proposed for the complete loss of a safety funct.'on due to an operational error:
1.
Plant Manager or in his absence his designated representative, make an immediate report to their Regional Inspection and Enforce-ment Office.
2.
Plant Manager, or in his absence his designated representative, would i= mediately notify that corporate officer responsible for nuclear power generation of the event.
3.
Corporate of ficer responsible for nuclear power generation, or his superior, will confirm the event to the Regional I&E Director and describe short-term corrective action.
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I Mr. Harold R. Denton Page 3 August 30, 1979 4.
An off-site investiga:1ve task force would be designated and they would promptly review the event and propose corrective actions.
If the cause of the incident is attributed to one or uore individuals, it could be cause for retraining or
.t may indicate need for disciplinary action by the licensee.
5.
Within 14 days, if requested, the corporate office'.
,ponsible for nuclear power generation would meet with the W. sonal I&E Director to provide oral and written results of the investigation.
The acticr.s outlined are not meant tu preclude the liceasee's option to shutdown the plant or the NRC's option to rder the plant shutdown.
We believe the approach to loss of safety function described above satisfies the concerns identified in NUREG 057s, while not imposing an additional hardship upon the consumers of a particular utility of paying an unnecessary cost for replace-ment power while this type of investigation is being conducted.
Meubers of the TMI Ad Hoc Nuclear Oversight Committee would be pleased to meet with you or with members of the Office of Itcndards Development to discuss imple-menting details of our proposed alternativs Sincerely, h.
Floyd W. Lewis Chairman, TMI Ad Hoc Nuclear Oversight Committee FWL:js cc: Office of Standards Development r,^,.;.g)ssL}
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