ML19295F034

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Responds to Re NRC Review of Emergency Procedures at Operating Reactors as Part of Consideration of ATWS Problem.Ie Bulletin 80-17 Required BWR Licensees to Review Emergency Procedures Re Operator Shutdown Actions
ML19295F034
Person / Time
Issue date: 11/24/1980
From: Ahearne J
NRC COMMISSION (OCM)
To: Udall M
HOUSE OF REP., INTERIOR & INSULAR AFFAIRS
Shared Package
ML19295F035 List:
References
REF-SSINS-3351, REF-SSINS-6820 IEB-80-17, NUDOCS 8012110036
Download: ML19295F034 (2)


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November 24, 1980

.i CHAIRMAN 3

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The Honorable Morris K. Udall 7

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Dear Mr. Chairman:

I am pleased to respond to your letter of October 3,1980.

In that letter you expressed interest in the NRC's review of emergency procedures at operating reactors as a part of the Commission's consideration of the ATWS problem.

We are conducting a survey of all site-assigned inspectors to confirm that each licensee has developed adequate emergency operating procedures to address the ATWS event. We will inform you of the results.

At present we are considering rulemaking proposed by the staff to amend 10 CFR 50 on ATWS (SECY-80-409).

In considering the ATWS problem, we have concluded that some interim actions were necessary. An example of this is the requirement at all BWRs to install an automatic recirculation pump trip to aid in the mitigation of potential ATWS events by January 1981.

However, during the interim, operating BWRs and all applicants for operating licenses have been required to develop emergency procedures that would enhance operator ability to recognize an ATWS event, as well as train operators to take immediate action to terminate the transient and minimize consequences.

Further, emergency procedures for operating BWRs have been instituted in our response to the Browns Ferry Unit 3 partial scram event and are planned for operating PWRs in the TMI task action plan.

We have taken appropriate actions in areas where specific problems with the shutdown system have been identified. As mentioned above, an example is the Browns Ferry Unit No. 3 incident which occurred on June 28, 1980. Browns Ferry Unit No. 3 experienced a failure of some control rods to fully insert following a scram signal.

As you know, all rods were subsequently fully inserted.

Following the Browns Ferry incident, the Commission issued Bulletin IEB No. 80-17, along with three supplements, to all BWR licensees. This Bulletin required BWR licensees to perform certain tests at their plants as well as to conduct a review of their emergency operating procedures to assure that they include specific operator action for a safe shutdown for the event described in the Bulletin.

Our inspectors are currently verifying that the licensees have adequately complied with the Bulletin.

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The Honorable Morris K. Udall Procedures to cope with failure to automatically scram and to specify the reactor operator's authority and responsibility for shutting the reactor down when operating parameters exceed any reactor protection setpoint but a scram does not occur are specified in a more general way through normal procedure requirements. The requirement for a plant to have written procedures is given in its Technical Specifications, which is a part of the plant operating license.

The content and format of procedures acceptable to the NRC are identified in Regulatory Guide (RG) 1.33, " Quality Assurance Program Requirements (Operation)"

to which the licensee commits in the licensing process.

Included in RG 1.33 is a section entitled, " Procedures for Combating Emergencies and Other Signifi-cant Events." This section requires a licensee to develop procedures that address those actions required to be taken by plant operators during a partial or full scram failure. The procedures developed under these requirements apply both to PWRs and BWRs.

Emergency procedures are scheduled to be inspected by NRC during the preopera-tional testing phase of the plant. The inspection procedure calls for a review of all emergency procedures identified in RG 1.33.

Our review of these procedures includes looking at the technical adequacy as well as appropriate fo rma t.

Thus, a licensee is required to have procedures to provide operator actions on failure to automatically scram and NRC inspectors are required to determine that these procedures are developed and are technically adequate.

In addition to the actions described above, the Commission has approved for issuance to all applicants and licensees NUREG-0737, " Implementation of Post-Tfil Requirements." This NUREG provides clarification of requirements for emergency operating procedures to cope with ATWS events coupled with other postulated equipment failures.

We will continue to keep inspection of emergency procedures a high priority, and modify the inspection program as necessary to keep pace with current ATWS developments.

I trust that the abose has been responsive to your concerns.

Si

erely,

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i)JohnF.Ahearne cc:

Rep. Steven Symms