ML19347F411

Discusses Ucs 780502 Petition for Reconsideration of 771104 Petition for Emergency & Remedial Action.Requests Response to Encl Issues

ML19347F411
Person / Time
Issue date:	06/21/1978
From:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
To:	Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML19347F399	List: ML19347F398 ML19347F403 ML19347F407 ML19347F411 ML19347F414 ML19347F416 ML19347F417 ML19347F418 ML19347F419 ML19347F420 ML19347F421
References
FOIA-81-97 NUDOCS 8105190208
Download: ML19347F411 (7)

Text

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NGJLEAR REGULATORY COMMISSIOW _,

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"t.TI CFFICE OF THE 5;3 SECRETARY

.;;s. 4 lEMORANDUM FOR:

Lee V. Gossick, Executive Director for Operations 15 3 g.u.q

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S FROM:

Samuel J. Chilk, Secretar,

UflIONOFCONCERNEDSCIENT)ST)s(UCS) PETITIO E

SUBJECT:

RECONSIDERATION, MAY 2, 15;78 6.Z}

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On May 2,1978, UCS submitted a petition which requested that the.

Commission reconsider its April 13 decision on the earlier UCS Petition e:=::

for Emergency and Remedial Action (filed on November 4,1977).

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At the May 31 Co.uission meeting, the Commission decided as a matter of I.bf discretion, to consider the petitioner's request.

The Commission further "e

decided that an overall evaluation of the UCS petition by the staff was desirable.

In making the overall evaluation of this petition, the staff

• l should provide a response to the issues identified in Enclosures 1, 2 7

and 3 with an asterisk within one week.a A response to the other issues in these enclosures and the public comments received in response to the Commission's order should be provided by the staff within 60 days.b 'The staff should also use its discretion to address other issues as is necessary to provide a complete and objective assessment of the UCS contentions.

Although a number of the issues identified in the enclosures are addressed 12 ;

in the Commission's April 13 decision, for the purposes of this reassess-

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ment, the staff should provide its objective views independent of those f

prior Commission positions.

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Copies of the staff response should be placed in the Public Document h---(

Room simultaneously with transmittal to the Commission.

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Chairman 11endrie

=.x Commissioner Gilinsky a.(SECYSuspense: 7/5/78 )

Commissioner Kennedy

b. (SECY Suspense: 8/25/78) t-Commissioner Bradford

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Edson Case

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Saul Levine Ernst Volgenau d_,

Ken Pedersen t..c Ur-James Kelley UCS n

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Joseph Fouchard Carlton Kamerer 3 3.E lioward Shapar,

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Issues in the UCS Petition

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• 1.

UCS quoted the staff as stating that in at least some presently

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operating plants, a fire could have the same effe::t as the Brovas Ferry fire.

Identify those plants, if any, and the basis for

...c=j permitting such plants to continue operation..(pages 1, 21 m

,2.

Are Rere any. plants which cannot demonstrate environmental qualifica-p;;4 tion for electrical connectors, splices, penetrations and terminal blocts torq uith full documentation such that they meet the minimum requirements of kmq the Commission's regulations?

If there are, please e.xplain the legal ff.9]

and regulatory basis for permitting their operation. '(page 2)

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3.

Did the applicable environmental qualification regulations for all operating power plants specify actual testing prior to granting of an Z...W operating license? (page 2)

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4.

UCS asserts the Commission concluded that no violations of HRC regula-tions were presented in spite of the following facts:

1 Failure of the licensees to meet the commitments cade by

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a.

them in SER's and required by the regulations to environmentally Ml~

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qualify equipment.

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Failure to have performed tests to qualify equipment before operation.

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Installation of equipment which actually failed when testing was finally done.

Evaluate and comment on these asserted " facts." (pace 3)

"9 5.

Is there anything in the UCS attachment entitled " Chronology and i="

. Analysis of Staff Actions" that was not specifically brought to the

... 1.3f Commission's attention by the staff prior to the issuance of the 1225 April 13 Memorandum and Order? (page 4).

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6.

Review again-the UCS "Draf t Memorandum and Order" of January 9,1978, and respond to allegation that it was " virtually ignored."

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The Commission stated on pages 44 and 45 of its April 13, 1978

• El Memorandum and Order:.

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Except insofar as it has already been complic-d wi-h in f

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J particular cases, this portion of the petit'on is denied.

The licensing reviews perforced on construcm.. permit and operating license applications ensure that General Design r1 Criteria 3 and 4 of Appendix A of 10 CFP, Part 50,50.55a(h) 7Efi and the single failure criterion of Appendix A to 10 CFR Part 50 isms

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'* Response to the Commission in one week.

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The single failure criterion requirements of AppendiXA to 10 CFR Part 50 and 50.55a(h) applicable to fire protection and environmental qualification requirements do not establish L ;2..

a set of design basis events.

Rather. they establish standards

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for design and performance of electrica'l systems to ensure that 7,1?j such systems are capable of performing as required. The staff

_.;.5 reviews... show that plants d.eet the requirements and that m2&;

the Sandia tests do not bear upon consideration of single

~4"i failure requirements, but rather upon the basic question of

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conformance with overall design goals.'

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Is this the correct formulation for the use of the single failure "rf?

criterion in the licensing review process, or is it just a ". theoretical

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9 formulation" as asserted by UCS? Please elaborate. (page 5) l'd" i ""

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Do the staff and its staff's fire protection consultant (Gage-Babcock)

[I" agree that there are now many plants operating where a fire will damage all redundant cables needed for protection of the public, even Ts.~

considering the defense-in-depth protection, i.e., fire detection,

&f5; physical separation, flame retardancy, and-fire suppression?

Is there

["[l any evidence that GDC-3 is not being met? (page 5) gr..m

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9.

As to those plants shut down as a result of the investigations in

.?q response to the UCS petition, is there evidence that the licensing reviews failed to ensure that GDC-4 was met and/or that quality assuran:e requirements were inadequate to detect non-compliance with GDC-4?

(page 6)

(A response to this question cay be satisfied, in part, by the staff's response to Action Item 6(b) of the Commission's

c.

Memorandum and Order dated April 13,1978.)'

2=a 10.

Provide views on the UCS characterization of the single failure criterion j"

as stated on pages 7 through 12 of the UCS Petition for P.econsideration.

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• 11.

Discuss the allegation that "there is now reasonable assurance that

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most, if not all, plants in operation use equipment which will fail

..;_.m when exposed to design basis event conditions."

(page 9)

~ng:.1 12.

Does the staff consider fires as design basis accidents? The rationale

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for the staff. position should be prcvided. (page 9)

.. a 13.

Does the staff agree with the UCS statement that "the Sandia tests

t.,.a conclusively demonstrate that a fire in one set of cables will t_._ _

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damace the redundant set of cables"?

(page 10)

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n.; 7 7 Pesponse due to the Commission in one week.

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14 Evaluate and discuss the request to issue orders to all operating plants similar to the order issued to Indian Point 1, requiring

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'backfit of regulations for enviror.qental qualification, fire i......

protection and the single failure criterion. (pages 11-12)

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t, 1s. 'Please provide the rationale for not backfitting IEEE-323 (1974) to t:..m all operating plants.

Please provide the record of the Regulatory

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Requirements Review Committee's determination that this standard was

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not to be backfitted. (page 15) mu:_

16.

Does the staff agree with the UCS assertion that "... without the omr2.

activation of the UCS pet;ition, the staff would not have uncovered gjz;j;;g the disturbing facts which have since come to light"?

Please provide t r"~1 a listing of the staff actions completed or undersay in response to

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the Sandia test results, prior to the receipt of the UCS petition.

I"=F-(page 16) 17.

Please provide a full chronology and explanation of the D.C. Cook

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Unit 2 situation, specifically addressing the UCS statements on page 17 of the Petition for Reconsideration.

het is the staff view of the UCS contentions or, page 18 of the 35 18.

Petition for Reconsideration? Specifically address the assertion that the program description and other items cited by UCS as " evidence" C'

schich supports UCS' view that the Sandia Fire Tests results did not confirm prior staff assumptions regarding cable tray separation?

w-Provide prior documented support, if any, for the UCS or staff

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positions.

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General Issues from Apoendix 0, UCS Petition

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i 1.

Address all of UCS' contentions in each of the " Analysis of Staff i;..,

Action" sections.

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Review each of the " Chronology of Staff Action" secticns and E5:2d L~g. ;J determine whether it fairly represents the sequence of actions ik..d taken by the staff and licensees.

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Analyze the UCS-selected quotations from previous staff submissions EE and ' advise uhether these quotations are treated in an. appropriate

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Soecific Issues from A6cendix D, UCS'Pe ition Elli

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tiscuss the UCS assertioln that the staff completely reversed itself 5"'F'."

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cn the qualification of terminal blocks a't Connecticut Yankee.

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(Jan. 20, p. 2) m.....

2. :P.espond to UCS statements.on page 5 (Jan. 3) that the staff's aus 1Jinuary'27 submission to the Comission was _" untrue" as to its 5,c=mm premise of complete review of qualification data befofe Connecticut fl:n Yankee would be permitted.to resume operation.

If the plant risumed C

. operation before such a review was completed, explain why.

52 2,

taam 3.

Is -the UCS correc,t in stating that, regarding qualificatioh of emf connectors and penetrations at the Pilgrim plant, "neither of these J'^~"

promises (by. licensee and staff] were filfilled"? (Jan.14, p.16)

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Discuss the UCS assertion that the staff has attempted to " limit the k?' "

t;plicability of the Sandia test failures by alleging that 'a licensee's

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assurance that its connectors are qualified... is not identical to E

the assurance received from.the manufactureres of the connectors that 35 UJicensees specify detailed quality Tll.Zlj failed (in Sandialtests assurance requirements...'" (Dec. 22, p. 17)

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5.

Is the UCS correct in stating that " improper installation can render (t:..

presumably qualified equipment ~ incapable of surviving the accident i

environment"?

(Jan.13,p.19) What are the implications of this k;.:-..-

statement, i.e., how does the !!PC know whether installation is done i

so as to preserve the capability of electrical equipment to survive L

an accident environment? '

6.

Discuss the UCS conclusion on p. 21 that, in regard to testing of

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Pilgrim splices, "the staff had no basis for concluding that the test

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was ' conservative' compared to actual conditions in the plant." On

.gr r; this same issue, respond to the UCS statements on p. 22 that the

%T-staff is inclined "to excuse serious deficiencies by post hoc 3 ;"""~

rationalization", and that the testing of Pilgrim splices "did not II aa.,

determine their ability to survive a LOCA."

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Discuss the UCS assertion that the relevant Sandia tests demonstrate G.T.Z.."

th.*.t current. flame retardancy standards and physical separation qWE..

criteria are not sufficient to meet Commission regulations.

(Cable Fires Introduction, p. 25)

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Respond to the UCS assertion that the staff has attempted "to

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downplay the significance of the consultant's [ Gage-Babcock]

r disclosures".

(Feb. 10, p. 28) lias the UCS accurately summarized the meeting between the staff and fir. Cohn of Gage-Babcock? [Id. )

[.13 llow have the issues raised by the Gage-Babcock report been resolved?

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• 9.

Discuss in detail the Sandia tests of flame retahdant coatings, and Ik

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the UCS' treatment thereof.

(April 1.1, pp. 29-30) Are written

[L.T test reports available and have the results been reviewed? llave Egx Licensing Boards been notified of these esults? lias an IE

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Bulletin been sent'to licensees advisi.ig them of the results of M ~~.'...

these tests?

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Are any of the retardants tested in 'use in plants? What credit" has been given for overall fire protection in any plants in which C

fire retardant coatings are in use, considering the results of m

the Sandia tests?

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• Response due to the Commission in one week.

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