ML19305A498
| ML19305A498 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/20/1979 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Gilinsky V, Hendrie J, Kennedy R NRC COMMISSION (OCM) |
| Shared Package | |
| ML19305A499 | List: |
| References | |
| NUDOCS 7908220212 | |
| Download: ML19305A498 (4) | |
Text
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NUCLEAR REGULATORY COMMISSION C
WASHINGTON, D. C. : 0555 g-August 20, 1979 MEMORANDUM FOR: Chainnan Hendrie Comissioner Gilinsky Comissioner Kennedy Comissioner Bradford Comissioner Ahearne THRU:
Lee V. Possick
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Executi m Director for Operation FROM:
Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
RESUMPTION OF LICENSIf0 REVIEWS FOR NUCLEAR POWER PLANTS In May of this year I described a realignment of current and necr-term priority tasks within the Office of Nuclear Reactor Regulation (NRR) to deal with activities relating to the accident at Three Mile Island (see SE^Y-79-344).
One consequence of the realignment was a temporary delay in the ;rocessing of operating license and construction pennit applications for neclear plants pending completion of certain T;4I-2 related tasks.
TI:c short-tenn TMI-2 tasks are essentially complete, as summarized below, and based on the results of these effor ts I have decided to resume staff licensing activities on pending construction pennit and operating license applic '; ens.
It is my judgment that the TMI-2 related actions being taken by NRR on licensee emergency preparedness (see SECY-79-450), operator licensing (see SECY-79-33-E), bulletins and orders followup (primarily in the areas of auxiliary feedwater system reliability; loss of feedwater and small break loss-of-coolant accident analysis; emergency operating guidelines and procedures; and operator training), and short-term Lessons Learned, if accomplished generally on the schedule we have selected, are necessary and sufficient for the continued safe operation of operating plants and for the resumption of staff licensing activities on pending construction permit and operating license applications.
It is my intent to bring the staff's first completed review of a pending operating license application to the Comission for review prior to staff issuance of the license. The Lessons Learned Task Force and I also have considered whether the actions associated with these activities 'would foreclose other actions that subsequently may be shown to be necessary by the Lessons Learned Task Force, the Preside:it's Comission or the NRC Special Inquiry.
We have no indication that they will.
64S008 79082 207Q
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i The Comission The principal element of the composite of staff activities listed above is the completion of my review and the ACRS review of the first report of the TMI-2 Lessons Learned Task Force (NUREG-0578). The Task Force report contains a set of recomendations to be implemented in two stages over the next 16 months on operating plants, plants under construction, and pending construction permit applications. The Task Force recommended 20 licensing l equirements and three rulemaking matters in 12 broad areas (nine in the area of design and analysis and three in the area of operations).
All but one of the 23 recomendations had a majority concurrence by the The Task Force concluded that implementing its recommendations Task Force.
would provide substantial, additional protection which is required for the public health and safety.
The Advisnry Comittee on Reactor Safeguards has completed its review of the Task Force report. The several public meetings of the ACRS subcomittee on TMI-2 and the public meeting of the full comittee on August 9 provided an opportunity for the presentation and discussion of public comments The ACRS letter of August 13, 1979, to Chairman Hendrie on the report.
states that the Comittee agrees with the intent and substance of all the Task Force recomendations, except four upon which the Comittee offered constructive coments to achieve the same objectives articulated by the The Comittee also noted that effective implementation will Task Force.
require a more flexible, perhaps extended, schedule than proposed by the Task Force. A copy of the ACRS letter is provided as Enclosure 1.
The ACRS comments on NUREG-0578 concentrate to four of the Task Force recomendations. These are:
(a) the revisicu cf limiting conditions of operation to require plant shutdown for certain human or procedural errors; (b) the inerting of MKI and II BWR containments; (c) the provision of recombiner capability at operating plants that do not already have it; and (d) the addition of a shift technical advisor at each operating plant.
The first three of these matters require Comission rulemaking, and it is a straightforward matter for the staff to consider the coments in the I will assure that process of developing the required Comission papers.
is done.
It is my intent to ask the Office of Standards Development (SD) to proceed expeditiously with a Comission paper p)roposing a new rule on limiting conditions of operation (item a, above.
I will ask SD to include in the paper the alternative approach'recomended by the ACRS, and cae other approach that I think merits consideration. My alternative would amend the Task Force recommendation so as to differentiate between an isolated occurrence and a repetitive pattern.
For example, the forced shutdown aspect of the Task Force 'recomendation could be reserved for a repeat violation within a relatively short time period, such as two years.
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n-i The Comission In the case of the two hydrogen control matters (items b and c, above), I intend to follow the advice of the ACRS by asking SD to delay completion of the required staff papers for proposed rulemaking until after receipt and review of the final report of the Lessons Learned Task Force, now scheduled for completion in mid-September.
It is likely that the inerting and recombiner requirements recomended by the Task Force will be included in the eventual tolution to the hydrogen control problems encountered in the TMI-2 accident. However, in view of the short time until the availability of the overall hydrogen control recomendations by the Task Force, I agree with the ACRS that it is best to not dilute staff effor't in this area by prompt pursuit of the two short-term recommendations, one of which was a minority view of the Task Force for these same reasons.
The ACRS comments on the shift technical advisor (item d, above) have resulted in our 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 assessment by people onsite with engineering competence and certain other characteristics.
I agree with the Task Force that the shift technical advisnr concept is the preferable short-term method of supplying these functions. However, I have concluded that some flexibility in implementation may yield the desired results if there is management innovation by individual licensees. The Task Force has 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 licenseas.
It is provided here as Enclosure 2.
In addition to commenting on four of the Task Force recomendations, tne ACRS letter of August 13 recomends three additional instrumentation requirements for short-term action. These are containment pressure, containment water level and containment hydrogen monitors designed to follow the course of an accident.
I agree with these recomendations. The Task Force has prepared descriptions of these requirements in the same format as Appendix A of NUREG-0578. They are provided here in Enclosure 3.
I have also decided on one further licensing requirement for short-tern action. 'It is a requiremeat for remotely operable high' point venting of gas from the reactor coolant system. The Task Force has prepared a description of this requirement; it is provided here in Enclosure 4.
The Task Force had previously deferred this item for further study, but it is my judgment
-that design efforts by licensees can and should be initiated now.
Finally, the Task Force has compiled a set of errata and clarifying coments for NUREG-0578.
It is provided here as Enclosure 5.
S4SO.10 e
The Comission In sumary, the Task Force recommended prompt licensing action on 20 items (excluding the three rulemaking matters).
I have added the three additional requirements recommended by the ACRS in its August 13 letter and one more on the basis of my own review. This Office will issue letters to all operatino plant licensees and all construction permit and operating license applicants within the next two weeks requiring them to convrit within 30 days to meet the total of 24 licensing requirements on the implementation schedule provided here in Enclosure 6.
Another letter to be issued at approximately the same time, will state the requirements flowing from the work by the Bulletins and Orders Task Force on operating plants which also need to be picked up on the license applications.
Several licensees have advised that some of the hardware changes required in NUREG-0578 can be accomplished at much lower cost during springtime refueling outages in 1980.
For good cause shown, we intend to consider such flexibility in the implementation schedules. The end date for full implementation of all licensing requirements has not been changed from the January 1,1981, date recomended by the Task Force. The implementation dates for the Comission rulemaking actions will be established in the course of rulemaking.
Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosures:
- 2. Alternatives to Shift Technical Advisors
- 3. Instrumentation to Monitor Containment Conditions
- 4. Installation of Remotely Operated High Point Vents in the Reactor Coolant System
- 5. NUREG-0578 Errata
- 6. Implementation of Requirements for Operating Plants and Plants in OL Review cc: Mitchell Rogovin Saul Levine Oken g.,lu Robert Minogue Victor Stello William Dircks Carlton Kamerer ACRS
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