ML19290E416
| ML19290E416 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/28/1980 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Magnuson W SENATE |
| Shared Package | |
| ML19290E417 | List: |
| References | |
| NUDOCS 8003110108 | |
| Download: ML19290E416 (3) | |
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UNITED STATES
[pnaso, NUCLEAR REGULATORY COMMtssION o
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me n t The Honorable Warren G. Magnuson United States Senate Washington, DC 20510
Dear Senator Magnuson:
Your letter of January 28, 1980 requested a response from the Nuclear Regulatory Comission to an inquiry from Mr. Steven B.
Rubin, dated January 12, 1980. The enclosure provides responses prepared by the NRC staff to the three questions in Mr. Rubin's letter that are within the purview of the NRC.
I am also returning the original of Mr. Rubin's letter as you requested.
I hope this information will be useful to you in responding to the constituent.
Sincerely, (Signed) E. Kevin Comoll William J. Dircks
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Acting Executive Director for Operations
Enclosures:
Ltr fm Rubin Responses t) 8 O-2?>/JU(
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NRC Responses to Questions Posed by Mr. Steven B. Rubin Question 2.
The US NRC is considering obtaining experimental infomation from new unlicensed power reactors.
(see copy of memo between ACRS and NRC attached.)
a.
Why haven't they obtained this necessary infomation before?
b.
Isn't it more expensive, to fix/ correct a power reactor after it has been started up? (it may be impossible to fix some components.)
Response
The ACRS coment to which Mr. Rubin refers relates to several situations in which construction of a nuclear power plant has been completed, but where the NRC has not yet reached a decision on the issuance of an operating license. In such cases, startup of the plant has been delayed until the Comission establishes what additional safety requirements must be implemented as a result of the lessons
' learned from the Three Mile Island accident, and on what time schedule. The ACRS letter note' that if such plants were allowed to load fuel and operate at power levels up to about 5% of full power, a number of tests could be performed that would provide useful information of safety significance, during the period that plant operation would otherwise be delayed pending a final Comission decision on issuance of a full-power license. Such information could not have been obtained before for these plants since a license is required to load fuel and operate at any power level.
Several utility applicants for operating licenses have proposed such an approach and the Commission staff is currently reviewing the proposals. The staff's criteria for judging the acceptability of conducting the proposed low power test programs, pending completion of the review for a full power license, are that:
(1) the tests provide meaningful information; (2) the tests provide an opportu-r nity for supplemental operator training, over and above the minimum requirements; (3) the tests not pose undue risk to the health and safety of the public; (4) the
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risk of plant damage should be low; and (5) performance of the test program should not result in post-test radiation levels in and around plant equipment that would preclude implementation of any new requirements that may be determined I
to be necessary prior to issuance of a full power license. Mr. Rubin's cuestion correctly infers that modifications or repairs to a nuclear power reactor can be more difficult and more expensive after the plant has operated at significant power levels, because of radiation levels. The fifth criterion above is intended 3
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to assure that the proposed low power testing does not result in such difficulties.
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Question 3.
I heard that Three Mile Island #2 which had the accident was
" grandfathered" into operation. That is new safety standards did
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not have to apply to it since it was "in-process". Is this true?
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Response
L The safety standards used by the NRC staff in judging the acceptability of nuclear I
power plant designs have evolved over the years and will continue to do so. As new or revised criteria are developed, it has been the staff practice to uniformly F
apply them to the review of applications for construction permits. In the case of plants already in operation or ender construction, decisions are made as to
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whether the new requirement is of sufficient importance to warrant imposition on such plants ("backfitting"). Where the decision is that backfitting is not required, some refer to the decision as "grandfathering." Since the staff's criteria are continually evolving in matters of a wide spectrum of importance, some, but by no means all, of the criteria that have changed since issuance of a construction permit are likely to be grandfathered on any given plant receiving an operating license.
Mr. Rubin's question most likely refers to the widely publicized "grandfathering" of Three Mile Island Unit 2 from a staff criterion for use of at least two diverse signals to automatically initiate isolation of certain piping penetrating the containment in the event of an accident. This criterion was stated in the staff's Standard Review Plan, issued in 1975 while the application for an operating p.
license for TMI-2 was under review. At the time the criterion was not judged to i;
be of sufficient importance to warrant backfitting to THI-2.
Subsequent to the TMI-2 accident, the NRC, the regulated industry, and many i
groups reviewing the accident have concluded that that judgment was poor. Diverse initiation of containment isolation is now required for all plants, including those in operation and under construction.
Question 4.
Will nearly completed and still unlicensed plants be grandfathered into operation?
Response
L No decision has been made by the Connission.to eliminate the concept of " grand-fathering;" that is, to require that plants nearly completed or in operation be required to conform to every new licensing criterion as it is developed. How-ever, the lessons we have learned from the TMI-2 accident have led to decisioas
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to implement several criteria previously applied only to new construction, and many new requirements thet have been developed as a result of TMI-2 are being applied to all plants.
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