ML19351F108
| ML19351F108 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/11/1980 |
| From: | Bickwit L NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| Shared Package | |
| ML19351F105 | List: |
| References | |
| REF-10CFR9.7, TASK-PS, TASK-SE SECY-A-80-179D, NUDOCS 8012290507 | |
| Download: ML19351F108 (21) | |
Text
m um7EO Starts
/m NUCLEA2 cEGULATO.7Y COMMfS:ll:N V
ADJUDICATORY ITEM POLICY SESSION December 11, 1980 SECY-A-80-1790 For:
The Comissioners Frem:
Leo' nard Bickwit, Jr.
General Counsel
Subject:
REDRAFT OF INDIAN POINT ORDER Discussion:
At the Comission meeting of November 26, 1980, the Comission resolved some outstanding issues with respect to the drafting of the Indian Point order.
The attached redraft is marked up to indicate areas on which agreement was reached in the November 26 meeting, as well as areas which the Comissioners planned to discuss further.
For purposes of clarity, this draft does not specially indicate areas where differences among Ccmissioners were resolved at meetings earlier than November 26.
The major changes contained in this draft are:
-- a renumbering of questions 1-4 In this draft, questions 1-4 correspond to questions 4, 3,1, and 2 in the previous version; l
-- the deletion of question 7;
-- the replacement of the word " care" with the word "wish" in question 8; and l
-- a rephrasing of what is question 4 in this draft.
l The Comission recognized that further consideration of the one-hearing as against the two-hearing approach might affect the text of the order, on pages 6 and 7, as well as the footnote on page 7.
That question is being addressed in a paper being sent to the Comissioners i
l separately.
l Comissioner Bradford has suggested that in lieu of the l
planned footnote describing differences between Units 2 and 3, for inclusion at the bottom of page 5, an acpendix be added, 8032290g 7 adapted from the recent letter to E.L. Jordan (Attachment B).
SECY NOTE:
This paper, which will be discussed at an open Contac..
Comission meeting on Monday, December 15, 1980, is identical to l
Peter Crane, CGC advance copies which were distributed to Comission offices on 634-146o December 11, 1980.
With respect to the question posed by Chairman Ahearne -- whether the use of the word "pemitting" in Paragraph 9A on page 5 would create additional procedural requirements, in light of the recent Sholly decision. Our view is that no such problem would be presented, even if the Comission determined that Unit 2 could resume operation only after formal Comission approval. The Comission would not, as in Sholly, be allowing the licensee to do something that its license did not already permit it to do.
Rather, the Comission would be permitting the licensee to use a license it had already obtained.
Finally, we would stress that a careful reading of the transcript does not invariably make clear what the Comissioners have and have not agreed to.
This redraft represents our best effort at presenting what the Comissioners seemed to have decided on, either as a resolution of disputed issues or as a tentative basis for compromise and further discussion.
,/::
Leonard Bickwit, Jr.
General Counsel Attachments:
A'.
Redrafted Order B.
Letter to E.L. Jordan (excerpt) l DISTRIBUTION:
l Comissioners Comission Staff Offices Secretariat
ATTA(.HMEA)T A
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 63h C0!'.MISSIONERS:
John F. Ahearne, Chaiman Victor Gilinsky Joseph M. Hendrie Peter A. Bradford
)
CONSOLIDATED EDIS0N COMPANY
)
0F NEW YORK (Indian Point,
)
Unit No. 2)
)
)
Docket Nos. 50-274 POWER AUTHORITY OF THE STATE
)
50-286 0F NEW YORK (Indian Point,
)
Unit No. 3)
)
)
t'EMORANDUM AND ORDER Backaround*
On May 30, 1980, the Commission issued an order establishing a
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four-pronged approach for resolving the issues raised by the Union of Concerned Scientists' petition regarding the Indian Point nuclear facilities, and by the decision of the Director, Office of Nuclear Reactor Regulation (NRR), granting in part and denying in part that petition.
The order announced the Commission's intention to hold a discretionary adjudication l
The Commission has received a motion from the Union of Concerned Scientists, dated June 23, 1980, requesting the disqualification of Commissioner Hendrie from participation in _ this matter.
In its l
Diablo Canyon decision (In the Matter of Pacific Gas and Electric, l
11 NRC 411 (1980), the Commission, with Commissioner Bradford dissenting, stated that requests for the disqualification of a Co.missioner would not be entertained by the Commission as a whole but would be referred to the Commissioner whose disqualification was requested.
By memorandum of April 23, 1980, Commissioner l
Hendrie has denied the request for his disqualification.
i i
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for the resolution of safety issues concerning the plants; initiated an informal proceeding for the purpose of defining the questions to be answered in that adjudication, as well as the criteria to be applied; announced the Commission's plan to address the generic question of the operation of nuclear reactors in areas of high pcpulation density through a generic proceeding, to be decided at a later date; and directed the Commission's General Counsel and Director, Office of Policy Evaluation, to establish a Task Force to address the question of the status of the reactors during the pendency of the planned adjudication.
In this order, we will deal with the issue of interim operation of the Indian Point units during the adjudicatory hearing and will take the steps necessary to initiate that adjudicatory hearing.
Interim Operation The Commission must decide whether the Indian Point Units 2 and 3 h
should continue to operate on an interim basis during the time it takes to complete the adjudicatory hearing we order today.
A decision on interim operation is not a decision about the long-tem safety of the Indian Point plants.
In his decision on February 11, 1980, the Director of Nuclear Reactor Regulation found that the interim risk of the continued operation
[b of the Indian Point units did not warrant their shutdown while the matter was being further considered.
Additionally, the Task Force, fomed to conduct a separate investigation of comparative risks of interim operation, completed.i_ts_ wor.k in. June.
The conclusion of the Task Force was that the overall risk of the Indian Point reactors is
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about the same as the typical reactor on a typical site.
The Task Force 2
found that although the Indian Point site was, considerably more risky
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than the average nuclear power plant site because of the density of the surrounding population, the design features of the plants reduced the accident risk from Indian Point by a comparable factor.
The report acknowledged, however, that the degree of uncertainty for the design comparison was much greater than for the site comparison.
Based upon this report, as well as the Director's previous decision, we concluded on July 15 that the risk posed by the operation of the Indian Point facilities did not warrant the suspension of the operating license _s during the adjudicatory proceedings. The Task Force findings and the Director's findings are not the final judgcent on the safety of Indian Point Units 2 and 3.
That final judgment may only be made after all parties have had the opportunity to examine in detail the Task Force report and other evidence presented by the NRC staff and present additional evidence of their own.
In the event that the Licensing Board conducting the adjudication determines that new evidence warrants interim relief, it may at any time recodmend a course of action to the Commission. The Task Force Report itself will be distributed free upon a w-itten request l
l to the NRC.
l In making this decision, we considered the positions taken by the I
many commenters.
Certain of those positions warrant specific discussion.
l l
UCS has alleged that there are specific safety defects in the Indian Point units which raise questions about whether or not the units l
c mP y with NRC regulations. The Director responded to these allegations 45 in his February 11, 1980 Order and UCS responded in turn in the submittal i
of March 10, 1980. We believe these specific allegations raise issues 3
I:3 which are best resolved in the forthcoming adjudicatory proceedings.
We have not made a judgment about these allegations and rely in the interim upon the judgment of the Director of t;RR. However, we do note that the Task Force report found no significant difference in risk between the Indian Point 2 and 3 designs.
It also found that the technical fixes ordered in the Director's decision would be clearly beneficial in reducing risk, but questioned whether the factor of improvement was significant in light of the uncertainties in estimating overall risk.
If the Board at any time during the proceeding believes that any of these issues are serious enough to warrant immediate action, it should make an appropriate recommendation to the Commission.
Several ccmmenters contended that the Commission should not pemit continued operation because of the lack of an emergency plan for the 4
surrounding area.
While a successful plan for evacuation at Indian Point would probably reduce overall risk, the fact is that most operating reactor sites do not yet have an approved plan and Indian Point is not different in this regard, flew York PIRG requested that we make no decision on interim operation until Senate confirmation of a new chaiman.
He cannot delay Com:nission business pending a confimation process which is beyond our control.
g Furthemore, such delay would not make a significant difference in this case since the decision on interim operation was unanimous.
tiew York PIRG also requested that the Commission examine a copy of the FEMA review on the status of state and local emergency planning ordered by the President.
We have examined this report and it does not change the opinion on emergency planning we expressed above.
4
We note that the Governor of New York has strongly urged that the plants remain in operation pending the outcome of the proceeding.
Both UCS and New York PIRG sought to address the Commission orally gq on the subject of interim operation.
By a vote of 2-2, that request was denied.
The recent leaks of large amounts of water into the containment and reactor vessel cavity at Indian Point Unit 2 are still being reviewed by Y@b the Commission's Office of Inspection and Enforcement.
On November 14, 1980, the Commission received a briefing on the status of the investigation at Indian Point Unit 2, and on the implications of the problem for Unit 3.
Unit 2 is currently shut down, and nust remain so for technical reasons for a period of nonths.
With respect to Unit 2, prior to pemitting resumption of operations, the Commission will determine whether its NOTE:
(AfETitEK. TH decision of July 15, 1980, to permit continued operation remains valid.
g ugg, With respect to Unit 3, we decided to stand by our earlier determination MITTlW SHooto GE to allow operation during the pendency of the adjudication.
Our judgment g
is based upon the information received in the November 14 briefing from ROMws Ut0 tlESow&D the Director of the Office of Inspection and Enforcement, who advised that the containment fan cooler units at Unit 3 are in markedly better condition than those which have been the source of problems at Unit 2, and that Unit 3 has additional safety features not present in Unit 2 in i
this regard.E Our judgment also reflects the fact that the two units are owned and operated by separate entities.
1 Adjudicatory Proceedina The Commission has received a motion for reconsideration of that
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portion of the Commission's order dated May 30, 1980 which directs that I-./
Note:
Commissioner Bradford suggests that relevant portions of a letter to E.L. Jordan, dated November 13, 1980, be incorporated into an appendix.
See attachment B.
4
an adjudicatory hearing be held on the long-term safety of the Indian Point units.
The basis for the petition is the Task Force's conclusions that Indian Point poses the same overall societal risk and less of an individual risk than a typical reactor on a typical site.
The licensees also contend that the population density is not materially dissimilar frcm numerous other sites not subject to adjudicatory hearings.
We deny the motion for reconsideration.
The licensees would have us treat the Task Force report as the final word on the risks of the Indian Point site, instead of a document designed to aid the Commission
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in its decision on interim operation.
As we stated previously in this order, the Task Force report, compiled in a short time period and not disclosing its detailed nethodology and underlying data, will be tested in an adjudicatory setting where parties may present additional or rebuttal evidence.
Furthermore, the Task Force report, even if perfectly ~
accurate, does not answer all of the questions the Commission wishes explored by the Licensing Board in a full proceeding.
In short, we will not turn a decision on interim operation into a final decision on the long-term acceptability on the Indian Point site.
Licensees also contend that the Indian Point demography is not different from other sites.
In fact, according to the Task Force report, j
Indian Point has the highest population within 10, 30 and 50 miles of any nuclear power plant site in the United States. At 50 miles, its population is more than double any other plant site.
The Conmission directs that the discretionary proceeding will be i
conducted in the vicinity of Indian Point by an Atomic Safety and Licensing I
Board, using the full procedural format of a trial-type adjudication, l
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including discovery and cross-examination.M The purpose of the proceeding will be to take evidence and nake recommended findings and conclusions on disputed issues material to the question whether the Indian Point Units 2 and 3 plants should be shut down or other action h
taken. The record of the proceeding, together with recommendations, will then be forwarded to the Commission for the final agency action on l
tne merits o'f the proceeding.
In view of the complexity of this proceeding, and in order that the Commission may make its decision within a reasonable period of time, we stress that the Board should focus clearly upon the questions asked by the Commission.
J y
Because of the investigative nature of this proceeding, further guidance is necessary with respect to certain pioc dural matters.
I Because the proceeding, although adjudicatory in fom, is not nandated by the Atomic Energy Act, it is not an "on the record" proceeding within the meaning of the Atomic Energy Act.
Although nomal ex carte constraints will apply to communications to the Licensing Board, the Commission will not be limited in its ability to obtain information with respect to Indian Point from any source. Because the Commission itself is designating by this Order the issues it wishes to be addressed in the adjudication, it is particularly important that the Licensing Board have discretion to fomulate contentions and subissues, upon the advice of the parties, so as to effectuate that purpose.
In admitting and fomulating contentions and subissues, therefore, the Licensing Board will not be bound by the provisions I
of 10 CFR Part 2.
The Licensing Board may also, without regard to the provisions of 10 CFR Part 2 establish whatever order of presentation I
it deems best suited to the proceeding's investigative purposes.
Except as orovided above or elsewhere in this Order,10 CFR Part 2 will control.
If the Board concludes that further relaxation of the rules is necessary for the efficient conduct of the hearino, l
we expect it to request such authorization from the Comnission.
The Commission exoects the Licensino Board to use its authority under Part 2 to assure the relevance and efficiency of discovery and cross-examination...The Licensing Board shall not reach an initial decision, but as noted in the Order, shall instead fomulate recommendations on
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the questions posed by the Commission.
No party will have the " burden of persuasion" as the term is normally used in adjudicatory proceedings; if evidence on a particular matter is in equipoise, the Board's recom-mendation may be expected to reflect that fact.
The staff will be a party to the proceeding, and the licensees will be admitted as parties upon request filed within 30 days of Federal Register notice of the appointment of a Licensing Board.
All others wishing to intervene
'shall file petitions for intervention within 30 days of Federal Register
' notice of the appointment of a Licensing Board. The arpointment of the l
Licensing Board will be announced by subsequent order of the Commission.
l
<=.
[ NOTE:
THE FOLLOWING FOUR PARAGRAPHS ARE ALTERNATIVE APPROACHES TO THE SAtiE ISSUE.]
[JA/JH: The primary bases for the Commission's decision will be whether the risks, to individuals living in the vicinity of the Indian
[ll Point site, including those resulting from the difficulty in evacuating, are significantly greater than the risks to individuals living in the vicinities of other operating nuclear power reactors in the U.S. and whether the societal risks from the Indian Point station are significantly above the range of societal risks from other operating units station.
The Commission intends to compare Indian Point to the range of risk from other nuclear power plants.]
[VG,PB: The Commission is primarily concerned about the extent to which the large population around Indian Point affects the risks posed by Indian Point as compared to the risks posed by other plants.
In
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particular, the Commission is concerned about:
(1) the risks to individuals resulting from the difficul' of evacuating the vicinity of Indian Point; and (2) the total r persons and property posed by the Indian Point plants.
The Comn.
.an intends to compare the risks posed 1
by the Indian Point plants to the risks posed by other nuclear power pl an ts. ]
l 7he Conmission's primary concern is the extent to which the population
/6 b around Indian Point affects the risk posed by Indian Point as compared to the range of risk posed by other nuclear plants.
In particular, the CT Commission is concerned with the total risk to persons and property i
t.b l posed by the Indian Point plants as well as the risk to individuals resulting from the difficulty of evacuating the vicinity of Indian i
8
Point. The Comission intends to compare the risks posed by the Indian Point plant to the range of risk posed by other nuclear plants.]
[ NOTE: THE FOLLOWING REDRAFT OF OPE'S PARAGRAPH 18A WAS PROPOSED BY CHAIRMAN AHEARNE AS A POSSIBLE BASIS FOR COMPROMISE.]
[The Comission's primary concern is the extent to which the population around Indian Point affects the risk posed by Indian Point as compared to the range of risk posed by other nuclear plants.
In particular, the Commission is concerned with the total risk to persons and property posed by the Indian Point plants as well as the risk to individuals resulting from the difficulty of evacuating the vicinity of Indian Point.
The Comission intends to compare Indian Point to the range of risk from other nuclear power plants, since the primary bases for the Comission's decision will be whether the individual and societal risks associated with Indian Point are significantly above the range of risks from other operating stations.]
i
g l
..!EE,
)
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The Commission is also interested in the current state of emergency planning in the vicinity of the Indian Point site and in future improvements gh in that planning as well as in resolving the specific contentions in the UCS Petition to the effect that some of our regulations are not met in one or both units.
Risks from nuclear power reactors are defined by the probabilities and consequences associated with potential accidents.
In directing a comparison of the risks of the Indian Point units with those from a representative group of other operating units, the Commission is fully aware of the uncertainties that attend such quantitative risk assessment calculations (reference NUREG-CR-0400, the Lewis Report, and the Commission policy statement on it.)
Nevertheless, risi assessment methods offer the best means available for objective and quantitative conparision of the kind needed here.
Further, some of the uncertainty that is associated with risk assessment est.imates of the absolute values of accident probabilities and consequences does not apply to comparisons such as those sought here.
Several measures of risk are useful for the comparisons the Commission seeks.
For individual risks, these include the probabilities of early gM effects--fatalities and injuries that could occur soon after an accident--
and of long-term effects--cancers and genetic effects that could occur more than a year after an accident, all as a function of distance from the reactor.
For societal risks the useful measures include early effects, long-
,g tern effects, and property damage and costs in terms of interdiction, decontamination, and crop and milk losses and the possibility that some c.,
areas affected by an accident might be uninhabitable for long periods.
Societal risk measures should include the distributions of probabilities and consequences as well as the expected risks or mean annual values of the consequences. Risk measures of these kinds for the Indian Point J
units and for a representative group of other operating nuclear power
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plants were presented in the report of the Commission's Task Force on Interim Operation of the Indian Point, NUREG-0715, and were found useful by the Commission in its consideration of the interim operation matter.
l In developing the record of the proceeding, the Board should address a series of questions as follows:
l
[ NOTE: AS IS CLEAR FROM ddCY-A-80-179C, COMMISSIONERS GILINSKY AND BRADFORD, ON THE ONE HAND, AND CHAIRMAN AHEARNE AND COMMISSIONER HENDRIE, ON THE OTHER, HAVE FAVORED DIFFERENT APPROACHES TO THE INITIAL QUESTIONS TO THE BOARD. THOUGH TH'E'TRANSCRIPTO'F'TH5' NOVEMBER 2'6ME5TINGISFARFRdMCLEAR0NTHElbINT,IT
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APPEARED THAT THERE WAS GkNERAL ACCEPTANCE OF ATTEMPTING TO USE THE QUESTIONS 1 THROUGH 4, RENUMBERED AND SLIGHTLY ALTERED, AS A BASIS FOR POSSIBLE COMPROMISE.]
1.
What risk may be posed by serious accidents at Indian Point 2 and 3, including accidents not considered in the plants' design basis, pending and after any improvements described in (2) and (4) below?
2.
What improvements in the level of safety will result from measures required or referenced in the Director's Order to the licensee, dated February 11, 1980?
(A contention by a party that one or more specific safety measures, in I
addition to those identified or referenced by the Director, should be required as a condition of operating the facility or facilities, would be within the scope of this inquiry.)
3.
What is the current status and degree of conformance with NRC? FEMA guidelines of state and local emergency planning within a 10-mile radius of the site and, ot the extent that it is relevant to risks posed by the two plants, beyond a 10-mile radius?
In this context, an effort should be made to establish what the minimum number of hours warning for an effective evacuation of a 10-mile quadrant at Indian Point would be.
[JA:
The FEMA position should be taken as a rebuttable presumption for this estimate.]
4.
What improvements in the level of emergency planning can be expected in the near future, and on what time schedule, and are there other specific offsite emergency procedures that are feasible and ~should be taken to protect the public?
5.
Based on the foregoing, how do the risks posed by Indian Point Units 2 and 3 compare with the range of risks posed by other nuclear power plants licensed to operate by th'e Comission? (The Board should limit its inquiry to generic examination of the range of risks and not go into any site-specific examination other than for Indian Point itself, except to the extent raised by the Task Force.
6.
What would be the energy, environmental, economic or other consequences of a shutdown of Indian Point Unit 2 and/or Unit 3?
[ QUESTION 7 FROM THE PREVIOUS DRAFT HAS BEEN DELETED, AND WHAT WAS QUESTION 8 IN THAT DPAFT HAS BEEN RENUMBERED AS QUESTION 7.]
7.
Does the Governor of the State of New York wish to express an official position with regard to the long-tenn operation of the units?
U
It is so ORDERED.
For the Commission SAMUEL J. CHILK Secretary of the Commission Dated at Washington, D.C.
This day of
,1980.
U
ATTACHMENT B I
E. L. Jordan 2
GSO 504 3
No safety-related electrical equipment is located where it would have been wetted during this event.
c.
Potential Consecuences
.2 Since containment design pressure is g/EYter than normal service water -
pressure inside the containment fan coolers, any holes in the service water system in the containment (such as those which caused this event) would present a potential post-LOCA release path from containment.
so, any such leakage could cause boron dilution in the recirculation wa er (long-term cooling) inventory inside containment following a LOCn' This would contribute to a recriticality (restart) event.
In add ' tion, leakage from the fan coolers could cause the necessity for isolition of one or more coolers, shich would degrade the post-LOCA ability to cool the containment.
II.
Cause of Event The most s,ignifican of the multiple' causes of the event were-1.
The history of ser ice water leakage from the containment fan coolers, culminating in the leaks which caused this eve '(
.N 2.
The failure of both vap containment su pumps, one due to tripped circuit breakers and the ther due t stuck float (the rod connecting the float to the sump star r ley was caught in.the grating on top of the sump.)
3.
The lack of any external / o co tainment). direct indication that the sump pumps were not ra ting.
4.
The failure of operators to obse ve dec/ eased flow to the waste holdup tanks HUT)(due to failure of he sump pumps).
This effect was maske y the fact that other water lows into the WHUTS (laboratory drain w er,etc).
5.
T failure of the operators to act upon the ump level instrument olumns which were indicating water in the sum'ps(the indicated level was within the normal range but it was not normal for the indicated l
level to exist constantly for several days as was the case during this event).
III.
Corrective Action A.
Short Term The above-described event occurred at Indian Point Unit 2 (IP-2).
However, since Indian Point Unit 3 (IP-3).is a nearly identical design,
i E. L. Jordan 3
NOV 13 ISSO and since IP-3 was shutdown for maintenance and inspection at the time of the IP-2 incident, it is necessary to determine if features exist at IP-3 which would preclude "IP-2" type events.
Those features are discussed below.
1.
The maintenance history on the containment fan coolers is signi-ficantly better at IP-3 compared to IP-2; therefore, major leakage inside containment is much less likely to occur. Although the better condition is probably largely because IP-3 fan coolers are newer, at the-present time the fact is they are in significantly better conditi.on and are expected to remain so during the upcoming cycl e.
At IP-3, there have been no leaks in the piping associated with the fan coolers (such as the main contributing leak to the IP-2 event in a 10" service water return pipe).
IP-3 has replaced five motor cooler anits in their history after experiencing leakages up to approximately 2 gpm maximum from those units.
Al,so, there are no "episeal" or " adams clamp" patches on the IP-3 coolers (there are numerous patches of both types on IP-2, some of which have had to be r.e-repaired).
IP-3 has used "hard" solder (90/5/5) to build up a patch over several small leaks. Those patches, while.not considered permanent, have proven more satisfactory than the IP-2 method.
Finally, the fan-cooler service water isolation valves at IP-3 have all been rebuilt even though no recent problems have been experienced, and each fan cooler unit has passed the Technical Specification required 0.36 gpm/ cooler leak rate tes.t (this includes all valves, coils, pipes, etc., not just the isolation valves).
2.
There are more indications in the control room of the sump levels in containment than there were at IP-2.
The sump pump on/off leveks of the vapor containment (VC) sump a.
are adjusted so that five level lights (three on one column and two on another column) will turn on before water spills onto the 46' elevation floor (as opposed to four at IP-2).
Since two are normally on even after the sump pumps have pumped the sump at each plant (the lowest 2 lights) that means 3 additional lights will come on at IP-3 as opposed to 2 at IP-2, before water spills onto the 46' elevation floor.
b.
A new capacitive detector device will detect approximately 1" of water on the 46' floor, with an audible control room alarm.
l
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E. L. Jordan 4
g g 1980 c.
At IP-3, the recirculation sump is normally kept dry so that increasing levels in containment will also be detected by the two additional level indicating columns in that sump before water could flow into the reactor cavity (at IP-2, the recir-culation sump is kept full of borated water, thereby negating usefulness of these indicators).
One of the two level indicating columns in each sump must be operable by Technical Specifications for continued plant operation..
3.
Several features are present in the reactor cavity to prevent and detect collection of water there.
Two new pumps.have been installed which will not operate a.
in such a way as to be subject to trips on thermal overload, as'might have been the case with the previous pumps.
The pumps have been installed with a " siphon breaker" (3/4" vacuum relief line in the discharge loop above the 46' floor, where it will discharge into the VC sump).
b.
A column has bcen installed in the cavity that will activate two independent audible alarms in the control room when approxi-mately 1" and approximately 3" of water respectively are in the bottom of the cavity.
A s'e^ arch has been conducted for other siphon ' paths' into the
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c.
reactor cavity, resulting in sealing of one conduit connection i
on the 46' floor which upresented a potential siphon path.
l d.
Tko unlabeled lights inside containment that were incorrectly assumed to indicate cavity pump operation (when on) at IP-2 have been properly labeled at IP-3 (they d_o indicate cavity pump operation at IP-3, unlike IP-2 where they indicate moisture in the cavity).
The 46' floor has been " surveyed" using a water-filled tygon e.
hose, with the result that water depth on the 46' floor at the i
sump before water would flow into the cavity would be approximately l
5-1/2" (compared to variously reported 2" to 4" at IP-2 due to i
a reverse slope in the IP-2 46' floor).
4.
In addition to Technical Specification requirements already mentioned (0.36 gom leakage / fan cooler, one float column operable / sump) l several plant requirements, some with calibration procedures, exist for equipment important for detection / prevention of "IP-2" type events.
'E. L. Jordan 5
3 BO a.
Level switches and the capacitive level indicator must be calibrated by procedure each refueling outage.
b.
Dew point detectors and weir level (containment fan cooler condensate and/or leakage flow detector) must be calibrated every two years.
c.
Plant procedures require each shift recording and supervisory review of trends on the rotometer flow meter / totalizer installed
Changes in that flow would signal leaks in containment (by an increase) or the possibility of pump failure (by a decrease).
1 I
B.
Long Term With the above noted exceptions, many of the preventative and mitigative features described above are not defined as " safety-related" and/or they do not have formal operability requirements.
However, IP-3 personnel have been " tuned" to look for this type of event by IE Information Notice 80-37 concerning the IP-2 event, and by extensive discussion with NRC personnel. We are convinced that in the near term, a flooding event at IP-3 is unlikely, and that if it did happen it would be promptly detected and corrected long before consequences become,as severe as they did at IP-2.
The NRC is considering the desirability of requiring upgrading of certain equipment to safety-related status and/or imposition of operability requirements and implementation of fonnal operating and/or emergency 0
procedures, etc. for plants having non-closed cooling systems in con-tainment.
In the near future.a-Bulletin will be issued. dealing with those issues.
l l
IV.
E We believe adequ features exist as described above so that in the near term, occurrence of a P-2 type flooding event with lack of-early detection l
1s precluded.
V.
Recommendation We recommend th +.. er the Resident Inspe
- rs have verified existence l
of the e ient/ Technical Specifications / Proc res described above, that 1
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