ML19261B267
| ML19261B267 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 01/26/1979 |
| From: | Silberg J SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| References | |
| NUDOCS 7902150163 | |
| Download: ML19261B267 (12) | |
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//' , i S NRC PUBLIC DOCUMENT Rgj j ;
UNITED STATES OF AMERICA [5 9 -4 NUCLEAR REGULATORY COMMISSION
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Before the Atomic Safety and Licensing Board cc e N
In the Matter of )
)
NORTHERN STATES POWER COMPANY ) Docket No. 50-263
)
(Monticello Nuclear Generating )
Plant, Unit No. 1) )
NORTHERN STATES POWER COMPANY'S RESPONSE TO LICENSING BOARD MEMORANDUM AND ORDER OF OCTOBER 13, 1978 In its Memorandum and Order dated October 13, 1978, the Atomic Safety and Licensing Board stated that, after its re-view of the record in this proceeding, there remained one item which might possibly be a major issue concerning the safety of the plant or its environmental impact. The item was Anticipated Transients Without Scram ("ATWS") . The Licensing Board noted t at it had reviewed the Staff's recent ATWS report, NUREG-0460, e- that that report left open certain questions on the resolu-tion of the ATWS issue. With that concern in mind, the Licensing Board asked the parties to addre,s the question of the issuance of a full-term license for Monticello "pending a resolution of
[the) ATWS question." In addition, the Licensing Board posed three specific questions:
- 1. Whether ATWS can be considered as a resolved safety issue?
- 2. Does the NRC Staff have a commitment for Northern States Power Company that modifica-tions will be made which will conform with NRC criteria when issued?
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- 3. Would Northern States Power Company comply without a Licensing Board order?
Northern States Power Company herein presents its response to the Licensing Board's questions. Based on those responses, we believe that the Licensing Board is authorized to, and should, enter an order dismissing this proceeding.
Subsequent to the Licensing Board's Order, important devel-opments have taken place concerning ATWS. Most of these are reflected in vol. 3 of NUREG-0460, which was issued by the Staff in December, 1978. Others are reflected in the Affidavit of Ashok Thadani, filed with the Licensing Board on January 18, 1979.
- 1. In NUREG-0460, vol. 3, p. 47, the Staff announced its plans for submitting a pro-posed regulation on ATWS in May, 1979. The Staff anticipates that all information neces-sary for issuing the rule in effective form should be available and analyzed by about November 1, 1979.
- 2. In NUREG-0460, vol. 3, p. 42-3, the Staff reaffirmed that the present likelihood of severe consequences arising from an ATWS event is acceptably small and presently there is no undue risk to the public from ATWS.
- 3. In the Thadani Affidavit, pp. 12-13, the Staff has identified emergency procedures
and operator training which will further reduce the risk from ATWS events pending the rulemaking proceeding.
- 4. In the Thadani Affidavit, p. 14, the Staff concludes, in light of the already installed recirculation pump trip and the emergency procedures and operation training identified in the preceding paragraph, that continued operation of the Monticello facility presents no undue risk to the health and safety of the public while the ATWS issue is under review by the Commission.
As set forth in the attached Affidavit of Dennis E. Gilberts, dated January 25, 1979, Northern States Power Company has already implemented many of the Staff's recommendations on emergency pro-cedures and operator training. The remainder will be accomp-lished within the next three months. With these actions, the uncontroverted conclusion is that reached in the Thadani Affi-davit, i.e. that continued operation presents no undue risk to the health and safety of the public while ATWS is under Com-mission review. Thus, for this interim period, there is no longer an unresolved safety question.
For the longer term, the key consideration is that the ATWS issue is being presented to the Commission for its resolu-tion through rulemaking. The results of that rulemaking will, of course, be binding on Northern States F .r Company and the
Company will abide by the provisions of those regulations. In view of the legal effect of the regulations and this commitment, we respectfully submit that no Licensing Board order is re-quired to assure that the Company will adhere to the applicable ATWS regulations.
Based upon these considerations, we believe that the Licensing Board should find the ATWS is no longer a major issue concerning the safety of the plant warranting further Licensing Board review. At this point, there are no extraordinary cir-cumstances requiring a determination that a serious safety matter exists. See 10 CFR S2.760a. Therefore, we respectfully request that the Licensing Board issue an order dismissing this proceeding.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By u r Ja ;E . pilberg )
18 M ptreet, North West Washington, D. C. 20036 (202)331-4100 Dated: January 26, 1979
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEEDRE THE ATOMIC SAFETY AND LICENSING BOARD IN the Matter of )
)
NORTHERN STATES POWER COMPANY )
) Docket No. 50-263 (Monticello Nuclear Generating )
P la nt , Unit 1) )
AFFIDAVIT OF DENNIS E GILBERTS ON ANTICIPATED TRANSIENTS WITHOUT SCRAM I, Dennis E Gilberts, being first duly sworn, do depose and state:
I am the General Manager of Power Production for Northern States Power Company. My statement of professional qualifications is attsched hereto. I am responsible for all Power Production operating activities and personnel of all NSP operating plants, including Monticello. This af fidavit addresses Northern States Power Company's position in regard to (1) operator training, and (2) development of ATWS emergency procedures as proposed by the NRC Staf f in the January 18, 1979 affidavit of Ashok C Thada ni .
ATWS MITIGATION Northern States Power Company has been a forerunner among electrical utilities in installing the ATWS recirculation pump trip (RPT) to mitigate the consequences of the postulated ATWS event. The "Monticello RPT" is
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one of two versions approved and recommended by the NRC. This modification was installed during the Monticello Fall 19 78 refueling outage. After satisfactory completion of preoperational tests, the system was placed in service prior to reactor startup on November 13, 1978.
OPERATOR TRAINING In accordance with the Technical Specifications, all Monticello operations personnel meet the requirements of ANSI 18.1-19 71, "S tanda rd for Selection and Training of Personnel for Nuclear Power Plants". The NSP corporate initial training program for operations personnel is a 2-year apprenticeship program consisting of 4000 hours0.0463 days <br />1.111 hours <br />0.00661 weeks <br />0.00152 months <br /> on tne job training and 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> of formal lecture. Senior operations persannel are selected for licensed operator training. The Hot License Certiff. cation Program proposed by NSP and approved by the NRC on September 15, 1977 describes the licensed operator training program. This program consists of formal lectures, system checkof fs to document on-the-job training, simulator training, and simulated NRC written and oral examinations. Upon satis-factory completion of this training, the Monticello Plant Manager may then recommend the license candidate for examination by NRC Operator Licensing Staf f members. A strong knowledge of plant systems and emergency procedures is required of all licensed operations personnel. The NRC License examination consists of written examination (s) (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for the reactor operator, 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> for the senior reactor operator) and oral examination (at leas t 3.5-4 hours) . This exacting process ensures that
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the Monticello licensed operator is competent to recognize emergency co nditions , to take the proper corrective action, and to protect the health and safety of the public.
Af ter satisfactorily passing the NRC examination, the licensed operator must satisfactorily participate in the NRC approved Monticello Licensed Operator Requalification Program. This program complies with 10CFR55 Appendix A. This continuing training program consists of formal lectures, simulator training, and annual written and oral examinations.
Conformance with regulations and quality of this program is monitored by NRC Inspection and Enforcement and Operator Licensing Branch personnel, respectively.
The NRC approved Monticello Licensed Operator Requalification Program requires that the plant licensed personnel receive lectures and seminars covering significant facility design and licensing changes.
Lectures and seminars covering the ATWS RPT system, procedure for an ATWS eve nt , and items described in section G2 of Mr Thadani's af fidavit have been scheduled for completion by April 17, 1979 as part of the current series of requalification training sessions.
PROCEDURES A temporary written description of the RPT system was provided for plant operators on November 10, 1978. A permanent procedure for the ATWS event was reviewed by the Operations Committee and approved by Plant Management on November 29, 1978. The procedt e describes the AIWS event; expected transien_ conditions; and provides instructions concerning - 1) means of recognizing that an ATWS has occurred, 2) alternate methods of
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scramming the reactor 3) initiation of suppression pool cooling, and 4) initiation of the standby liquid control system. A permanent RPT system description and normal system operating procedures were reviewed by the Operationa Committee and approved by Plant Management on January 23, 1979 Existing procedures and system descriptions address all items listed in Section G1 of Mr Thadani's affidavit except containment para-meters. These will be discussed in a future revision of the emergency procedures scheduled for approval no later than April 23, 1979 It should be recognized that the ATWS procedure is not fundamentally new information for plant operators. Alternate methods of scramming the reactor have always been routinely discussed in retraining. Previous procedures and training cover - 1) initiation of Standby Liquid Control when the reactor cannot be shutdown with control rods, 2) initiation of suppression pool cooling when there is continuous heat addition to the pool, and 3) monitoring of important control room indications following scram and other transients. .
SUMMARY
In summary, it is Northern States Power Company's position that the existing operator training cessions and ATWS system description and procedures (modified as described above) satisfactorily address those steps recommended by the NRC for reducing the risk from ATUS in Section G of the January 18, 1979 affidavit.
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I hereby certify that the foregoing information is true and correct to the best of my knowledge and belief.
M Dennis E Gilberts Subscribed and sworn to before me this 25th day of January, 1979 l b M/2/) Ad)t' )
Notary Public F My Commission Expires October 10, 1981 DENISE E. HALVdRSbN ! !
ff f-[Ek..a ll NOTARY PUBLIC - MINNESOTA ll ll HENNEPIN COUNTY l My Commission Empires Oct to.1981 ll,
DENNIS E. GILBERTS PROFESSIONAL QUALIFICATIONS I am the General Manager of Power Production at Northern States Power Company.
I am responsible for all Power Production Operating activities of all Northern States Power Company Operating Plants, including Monticello.
I received a Bachelor of Mechanical Engineering Degree from the University of Minnesota in 1954 and became a registered Professional Engineer in the State of Minnesota in 1960 (Registration Number 6478).
After graduation I was employed by Northern States Power Company as an Engineer at the Black Dog and later the Grand Forks steam electric generating plants. The years 1956 and 1957 were spent in the U. S. Army. After returning from service, I resumed working at the Grand Forks plant until mid-1959 when I was transferred to the General Office as a Supervisory Engineer.
From 1959 to 1971 I worked in this capacity providing technical supervision of the operation of a number of fossil fueled plants. From 1971 to 1973 I was General Superintendent of Fossil Plant Operations and in 1973 became General Manager of Power Production.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
NORTHERN STATES POWER COMPANY ) Docket No. 50-263
)
(Monticello Nuclear Generating )
Plant, Unit No. 1) )
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Northern States Pcwer Company's Response to Licensing Board Memorandum and Order of October 13, 1978" were served by deposit in the U. S. Mail, first class,. postage prepaid, this 26th day of January, 1979, to all those on the attached Service List.
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Iu / 'N' v Jay .' S lberg j Dated: January 2t, 1979
UNITED STATES OF AMERICA NUCLEAR REGUMTORY COMMISSION O'
Before the Atcmic Safety and Licensinc Board In the Matter of )
)
NORTHE3N STATES POWER COMPANY ) Docket No. 50-263
)
(Monticello Nuclear )
Generatine Plant, Unit 1) )
SERVICE LIST Fccert M. Larc, Esq. Dr. Walter H. Jcri n C1'a 4 -m Se4c- Fasead ihn.scr Aemic Safety & T 4mai g Scard Cak Ridge Naticml Timmt=rf U.S. N m2aa" Pegulat=rI C w i==i m Ec:c X Wach4 gt=n, D.C. 20555 Oak Ridge, Tenmssee 37830 I
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S w dal Assistant At*rney General Arm,c Safety & Licensing Ecard Mimaarta Follut:.cn Cent =cl Acency
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Waebimt=n, D.C. 20555 St The I.ewis, Esq.
Office of the Exec:Plve I.agal Direct =:-
U.S. M'claar Fag'il e ry O w 4asicn Washi:st=n, D.C. 20555 Docketing & Service Seca.ica I,n Office of the Secretar?
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