ML20032E833
| ML20032E833 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 11/19/1981 |
| From: | Goldberg S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Lazo R, Linenberger G, Schink D Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20032E834 | List: |
| References | |
| NUDOCS 8111230344 | |
| Download: ML20032E833 (2) | |
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November 19, 1981 Richard M. Lazo, Esq., Chairman Gustave A. Linenberger Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atonic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. David R. Schink N
Adninistrative Judge g
Department of Oceanography s
[T ' s Texas A & M University
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College Station, Texas 77840 NOV2 0193g h
I In the Matter of uu mry,D b PACIFIC GAS AND ELECTRIC COMPANY d
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Docket No. 50-133
Dear Administrative Judges:
In its Memorandum and Order of October 20, 1981, the Licensing Board directed the Staff to provide answers to eight questions within thirty days of the date of service of the Order. Order at 2-3.
This letter regarding question 1 and the accompanying affidavits of Vernon Rooney, Project Manager, Tolbert Young, Jr., Office of Inspection and Enforcement, and Ina Alterman and Jeffrey K. Kimball, Geosciences Branch, variously addressing the balance of the questions constitute the Staff response.
Question 1:
"What regulatory requirements apply to a plant in cold shutdown mode?"
The rcgulations, with few exceptions,E o not contain express refer-d enas which indicate their applicability to a plant in cold shutdown.
Generally, Part 50 contains the requirenents for normal operation and certain transient conditions.
In the absence of any express exclusion y
Appendix R focuses on the protection of structures, systems and components associated not only with achieving safe shutdown but also maintaining safe shutdown from the probability and effects of fires..
The tenn " safe shutdown" as used in Appendix R to 10 C.F.R. Part 50 applies to both hot and cold shutdown. Appendix R(I).
In addition, section 50.54(q), for example, requires a licensee " authorized to possess and/or operate a nuclear power reactor" to have emergency plans which meet the standards in @ 50.47(b) and the requirements in Appendix E to Part 50.
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2, in the regulations of cold shutdown and because it is one of the five modes of operation defined by the NRC and in a facility's license, the regulations that apply to a plant in normal operation will also apply to a plant in cold shutdown. Therefore, the provisions of 10 C.F.R. Parts 20, 30, 40, 50, 51, 55, 70, and 73, which are not expressly limited by their tenns, are applicable to plants in a cold shutdown operating mode, ilowever, with respect to a facility whose license is to be limited to shutdown condition, the various provisions applicable to normal operation, transients and accidents should be construed as relating to the shutdown condition (i.e., normal shutdown conditions, transients affecting the shutdown condition, accidents and abnonnal occurences as they affect the shutdown condition).
For example, those provisions requiring consideration of LOCA conditions would then consider the effect of loss of coolant under conditions of a cold depressurized primary system and a core with essentially no decay heat. Thus, in many cases very little, if anything, is needed to denonstrate canpliance.
against pipe whip (General Design Criterion 4)propriate protection For example, little would be needed to show ap when all fluids are cold and depressurized.
Rooney Affidavit.
The licensee must also comply with any conditions or requirements imposed by Order, its license and technical specifications. Humboldt Bay has not received Orders regarding the implementation of NUREG-0578 and NUREG-0737 standards and modifications.
Sincerely,
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( k,, f 0 Steven C. Goldberg Counsel for NRC Staff cc: v/ enclosure Service List l
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