ML20002C291
| ML20002C291 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 12/18/1980 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20002C289 | List: |
| References | |
| NUDOCS 8101090940 | |
| Download: ML20002C291 (6) | |
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'O-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Harold R. Denton, Director In the Matter of
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CONSUMERS POWER COMPANY Docket No. 50-155 (BigRockPointPlant)
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DIRECTOR'S DECISION UNDER 10 C.F.R. 2.206 By petition dated April 1,1980, Christa-Maria, on behalf of Concerned Citizens for the Charlevoix Area, requested that the Big Rock Point Plant be shutdown immediately because it does not meet minimal Nuclear Regulatory Comission (NRC) requirements relating to containment integrity. This petition has been considered under the provisions of 10 C.F.R. 2.206 of the Commission's regulations. Notice of receipt of the petition was published in the Federal Register July 7,1980(45FR45748).
The basis of Christa-Maria's petition is the contention that the steel containment at the Big Rock Point Plant is insufficient to contain radiation in the event of an accident. Petitioner asserts that continued operation of the Big Rock Point Plant with an unshielded steel containment is in direct violation of NRC requirements. Upon consideration of the information set forth in Christa-Maria's petition, it has been determined that Christa-Maria has not presented any new information or reasons which consistute a basis for shutting down the Big Rock Point Plant.
DISCUSSION Christa-Maria asserts that the unshielded steel containment at the Big Rock Point Plant is insufficient to contain radiation and that this is in direct violation of " requirement 2.213" of NUREG 0578, "TMI-2 Lessons Learned Task C10109 094D l
Force Status Report and Short-Term Recommendations," which states that nuclear power plants must shut down imediately in the event of a complete loss of safety function.
It is assumed that the reference to " requirement 2.213" of NUREG 0578 in Christa-Maria's petition is a typographical error and that the reference was intended to be to Section 2.2.3.
In that section, the NRC Lessons Learned Task Force had originally proposed that the Technical Specifications for each reactor should provide that the reactor be placed in a hot shutdown condition within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and a cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time that the reactor is found to be or has been in operation with a complete loss of safety function.
However, based on further review, the NRC staff determined that rather than implement the original proposal at this time a termd new rulemaking should be undertaken which would require plant shutdown for various human and procedural l
errors. Accordingly, the NRC's September 13, 1979 letter to all licensees indicated that no further action on Section 2.2.3 would be required by the licensees pending the actions of the rulemaking process.
Consequently, the
" requirement" which Christa-Maria asserts the Big Rock facility is violating is not currently a requirement for NRC licensees.
The issue of adequate shielding from post-accident radiation fields is still under active review. One of the lessons learned from the TMI-2 accident is that radiation fields resulting from contained radiation sources after an accident may make it difficult to effectively perform accident recovery operations or may impair safety equipment. As a result, by letter of October 30,1979, we asked nuclear power plant licensees to perform a design review of plant shielding by January 1, 1980 and to implement needed changes by January 1,1981. The NRC design criteria assume a very severe accident with a very large radiation source term and assume
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that stringent limits on radiation exposure to personnel would be met.
Consumers Power Company submitted the design review by letter of December 27, 1979 and identified areas of the plant which would need additional shielding protection if NRC design criteria were to be met.
By letters dated February 22, April 2, May 6, August 25, and September 2, 1980, Consumers Power Company had requested a delay in implementation of additional shielding protection requirements until the completion of an ongoing risk assessment of the plant, estimated to be April 1981. The requested delay was effectively mooted by the publication of NUREG-0737, " Clarification of TMI Action Plan Requirements" which modifies the implementation date I,
for necessary changes to January 1,1982.
As required by the staff, the licensee has completed a review of vital areas in which personnel occupancy may be limited by radiation during post-accident operations.
Our ' safety evaluation of the imple-mentation of " Category A" Lessons Learned requirements was issued on May 2,1980 and stated that the control room, the interim Technical Support Center and the Operational Support Center are sufficiently shielded that they would remain accessible for continuous occupancy.
The vital' areas in which personnel occupancy may be limited are the backup emergency diesel, backup cooling water supply hose to,the core spray heat exchanger and the emergency diesel general fuel supply.
The l
licensee initiated work to implement changes for these three items, and two of them, the relocation of the backup emergency diesel and the modification to the emergency diesel general fuel supply, should be l
completed shortly. With respect to the third item, the licensee began
-4 implementation of the modifications but has recently informed us that preliminary results from the probabilistic risk assessment being con-ducted for the Big Rock Point plant could affect the need for the modification to the backup cooling water supply hose to core spray heat exhanger. Accordingly, they indicated that work on this third item has been stopped. Because of the delay in the implementation of additional shielding requirements until January 1,1982, as discussed above, the licensee had additional time to further assess this modification.
Because of the conservatism of the design requirements against which the shielding acceptability must be evaluated, it is our judgment that a deferral of implenentation until 1982 will not result in exposure of plant personnel to significant risk from a loss-of-coolant accident or a greater risk to the public than previously evaluated, if such an accident should occur.
CONCLUSION Based on the foregoing discussion and the provisions of 10 C.F.R. 2.206, I have determined that there is no adequate basis for shutting down the Big Rock Point Plant. The request by the Concerned Citizens of Charlevoix Area is, therefore, denied.
A copy of this Decision will be placed in the Commission's Public Document Room at 1717 H Street, N. W., Washington, D.C.
20555 and the Local Public Document Room for the Big Rock Point Plant, located at the Charlevoix Public Library,107 Clinton Street, Charlevoix, I
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5-Michigan 49720. A copy of this Decision will also be filed with the Secretary of the Commission for review by the Commission in a'cAordance with 10 CFR 2.206(c) of the Commission's regulations.
In accordance with 10 CFR 2'.'206(c) of the Commission's regulations, this Decision will constitute the final action of the Commission twenty (20) days after the date of issuance, unless the Commission, on its own motion, institutes a review of this Decision within that time.
c: -a sted by it II. Deatca i
Harold R. Denton, Director Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland this e
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