ML20037D677
| ML20037D677 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 08/12/1981 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML20037D678 | List: |
| References | |
| LSO5-81-08-027, LSO5-81-8-27, NUDOCS 8108280151 | |
| Download: ML20037D677 (13) | |
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4 lir. Russell B. DeWitt g*
Vice President - Nuclear Operations Consumers Power Company A
AUG 181981 > y 1945 W. Parnall Road nnon Q Jackson, Michigan 49201
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Dear Mr. DeWitt:
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SUBJECT:
BIG ROCK POINT PROBABILISTIC RISK ASSESSMENT Throughout the past year we have been discussing the status and preliminary results of a Probabilistric Risk Assessment (PRA) for the Big Rock Point Plant. On March 31, 1981, you submitted the conplete1 study along with proposed recormendations for using the PRA to evaluate the current safety of the plant along with the safety significance of other staff concerns. The status reports and briefings that you have given to us have been very useful and reflect the confi-dence and conpany determination to develog a responsible and viable licensing program for Big Rock Point.
In your submittal you noted that the plant has a long history of safe operatinn, that the uniqueness of the plant design dictates that an alternative to generic licensing 1s essential and that nc acute fatalities were predicted to occur even for the most severe releases postulated.
The staff review of the complete Big Rock PRA is scheduled to be completed in about a year. We expect to have draf t.'esults by the end of this year. As a result, we have established the following position for certain near term issues. First, with regard to the Anticipated Transients Without Scram (ATWS) issue, you had requested that the staff rot require implementation of the automatic recircula-tion purp trip at Big Rock since it did not provide substantial additional protection.
Instead, you provided PRA-based information to show that'other modifications would be more effective at reducing the consequence of an ATMS event. By letter dated January 18, 1981, the Comission issued Amendment No. 38 to the Big Rock Point facility operating license which extended the implementation date for the installation of a recirculation pump trip until the completion of the HRC staff's review of those portions of the PRA that relate to ATWS. We expect to complete our revuw of this issue by about late sumer.
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Hr. Russell B. DeWitt August 12, 1981 Second, Attachment 6 of your March 31, 1981 letter requested a deferral of inplementation of an interlock on the recirculation punp loop. The position of HUREG-0737 Item II.K.3.19 is that at least two recirculation loops are to be open for flow so that level measurements in the downcomer region are representative of the level in the core region. You indicated that due to the fact that there is a steam drum at Big Rock, and other design differences, isolation of the recirculation loops will not isolate tne reactor or steam drun level instrumentation from the volumes for which they provide level monitoring. We have completed our review and conclude that such an interlock is not required on Big Rock Point because of such design differences.
Finally, you requested deferral of implementation of a number of other staff requirements as a result of your PRA conclusions. A list of these is pro-vided in Enclosure 1.
Your basis for this deferral is the PRA. We believe that an overall risk assessment is a valuable technique for providing in-sight into the identification of significant contributors to risk. We are reviewing your request to defer Items 1-5 and the control room habitability portion of Item 6 in conjunction with our review of the PRA.
In the interim, the schedule set forth in our letter of October 31, 1980, with respect to these items is tenporarily suspended. Should the completed staff review indicate that one or more of these items are required to substantially enhance plant safety at Big Rock, they will then be reg'; ired. The appropriate implementation will then be developed.
With respect to the remainder of Item 6, the permanent emergency response fac"ities are not required to be operational until October 1,1982. You were advised by the October 30, 1979 DOL letter to have an interim Technical Support Center (TSC) as described in NUREG-0578 (Section 2.2.2).
Further, in accordance with our February 18, 1981 letter that provided pages for NUREG-0737, Iten III.A.l.2, you were advised to submit conceptual designs for the total emergency response facilities as dentibed by NUREG-J695 by June 1,1981, for NRC review and preimplemenution approvul. As to your specific concerns regarding the onsite TSC, there is no need for a deferral at this time.
With respect to Item 7, and specifically to the meteorological system, Annex 1 to Appeadix 2 of NUREG-0654 gives a schedule for implementation of the meteorological elements of the emergency response plan.
In brief, you are required, nt this time, only to have a system equivalent to a backup system as described in the proposed Revi11on 1 to Regulatory Guide 1.23, and certain other capabilities. A primary system consisting of a full meteorological tower, data trans.nission, and a backup system is not scheduled for imple-mentation until July 1,1982. This implementation date is consistent with the projected completion of our review of the PRA; therefo e, no deferral is necessary.
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4 Mr. Russell B. DeWitt August 12, 1981 As to your request for a deferral of the prompt notification system, the HRC staff's evaluation of this site indicates that the installation of such a system would not involve a significant cost considering the benefits obtained.' Therefore, we do not believe that a deferral of this item is appropriate.
Your March 31, 1981 letter also indicated that you intend to use the PRA for "all current and future" safety issues. We acknowledge receipt of your June 19, 1981 letter regarding SEP Topic III-6, " Seismic Design",
and your June 22, 1981 letter regarding on-shift staffing. Our responses to these letters will be the subject of separate correspondence.
Should you have any questions regarding the staff position, please do not hesitate to contact the Project 11anager, Mr. Walter Paulson (extension 301/492-7214).
Sincerely, Wal%nd by H. R. Osnten Harold R. Denton, Director Office of Nuclear Reactor Regulation Enclosure As stated MErnst NRC PDR TMurley cc w/ enclosure:
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P Mr. Rassell B. DeWitt August 12, 1981 cc w/ enclosure:
Mr. Paul A. Perry, Secretary U. S. Environmental Protection Consumers Power Conpany Agency 212 West Michigan Avenue Federal Activities Branch Jackson, Michigan 49201 Region V Office ATTN: EIS COORDINATOR Judd L. Bacon, Esquire 230 South Dearborn Street
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Consumers Power Conpany Chicago, Illinois 60604 212 West Michigan Avenue Jackson, Michigan 49201 Herbert Grossman, Esq., Chairman Atomic Safety and Licensing Board Joseph Gallo, Esquire U. S. Nuclear Regulatory Comission Isham, Lincoln & Beale Washington, D. C.
20555 1120 Connecticut Avenue Room 325 Dr. Oscar H. Paris Wasningtra, D. C.
20036 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Comission Peter W. Steketee, Esquire Washington, D. C.
20555 505 Peoples Building Grand Rapids, Michigan 49503 Mr. Frederick J. Shon Atomic Satety and Licensing Board Alan S. Rosenthal, Esq., Chairman U. S. Nuclear Regulatory Comission Atomic Safety & Licensing Appeal Board Washington, D. C.
20555 U. S. Nuclear Regulatory Comission Washington, D. C.
20555 Big Rock Point Nuclear Power Plant ATTN: Mr. C. J. Hartman Mr. John O'Neill, II Plant Superintendent Route 2, Box 44 Charlevoix, Michigan 49720 Maple City, Michigan 49664 Christa-Maria Charlevoix Public Library Route 2, Box 108C 107 Clinton Street Charlevoi:t, Michigan 49720 Charlevoix, Michigan William J. Scanlon, Esquire Chairman 2034 Pauline Boulevard County Board of Supervisors Ann Arbor, Michigan 48103 Charlevoix County Charlevoix, Michigan 49720 Resident Inspector Big Rock Point Plant Office of the Governor (2) c/o U.S. NRC l
Room 1 - Capitol Building RR #3, Box 600 Lansing, Michigan 48913 Charlevoix, Michigan 49720 l
Herbert Semmel Mr. Jim E. Mills Council for Christa Maria, et al.
Route 2, Box 108C l
Urban Law Institute Charlevoix, Michigan 49720 3
Antioch School of Law i
263316th Street, NW Thomas S. Moore Washington, D. C.
20460 Atomic Safety & Licensing Appeal Board j
U. S. Nuclear Regulatory Comission 1
Washington, D. C.
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Mr. Russell B. DeWitt August 12, 1981 cc w/ enclosure:
Dr. John H. Buck Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555-Ms. JoAnn Bier 204 Clinton Street
,Charlevoix, Michigan 49720
.Mr. David P. Hoffman Nuclear Licensing Administrator Consumers Power Company 1945 W. Parnall Road
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ITEMS REQUESTED FOR DEFERRAL FROM CURRENT REQUIREMENTS, F
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Design Review of Plant Shielding and Submittal if deviation 1/01/81 Environmental Qualification of Equipment from position for Spaces / Systems which may be used in i Have design of modifications 1/01/81' Post-Accident Operations (NUREG-0737, Item II.B.2, Part 2, Plant Modifications) available Plant Modifications 1/01/82 (LLCat.8) 2.
Post Accident Sampling Capability Submittal if deviation 1/01/81.
(NUREG-0737. Item II.B.3) from position Plant Modifications -
1/01/82 (LL Cat. 8) 3.
Instrumentation for Detection of Licensee Stdmittal 1/01/81 Inadequate Core Cooling (NUREG-0737, Install level instruments 1/01/82 j
Item II.F.2)
(LL Cat. B) 4.
Isolation of Isolation Condensors on Licensee abmittal 7/01/81 i
High Radiation (NUREG-0737, Item Isolation Condensor 1/01/82 II.R.3.14)
Isolation Modification 5.
Interlock on Recirculation Pumps Licensee Submittal 7/01/81 I
Loops (NUREG-0737, Item II.K.3.19)
Modification 7/01/81 6.
Upgrade Emergency Support Facilities Interim TSC, CSC & E0F 1/01/80 (NUREG-0737, Item III.A.l.2 and NUREG-0696, specifically Technical Support Conceptual designs for 6/01/81 Center Requirements) and Control Room emergency response I
Habitability (NUREG-0737, Item III.D.3.4)
Upgraded facilities operational 10/01/82 Submit control room habitability 1/01/81 evaluation, propo, sed modifica-tions, schedule i
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Licensee submit. emergency pland
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Implement emergency plans 4/01/81*'
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7 Your March 31,1981 letter also indicated that you int, dato use the PRA for "ali current.and future" safety issues. We.bave only reached a conclusion on deferral on those items discussed abo (e that are included in the March 31, 1981 letter. We acknowledge recalpt of your June 19, 19 0
1981 letter regarding SEP Topic III-6, "Seismicf esign", and your June 22, 1981 letter regarding on-shift staffing. Our responses to these letters will be the subject of separate corresponde e.
Should you have any questions regarding. e staff position, please do not hesitate.to contact.the Project M ger, Mr. Walter Paulson (extension 301/492-7214).
Sincerely, Harold R. Denton, Director Office of fluclear Reactor Regulation
Enclosure:
ISTRIBUTION:
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Your March 31, 1981 letter also indicated that you intend to use le PRA for "all current and future" safety issues. We have only - ached a conclusion on deferral on those items discussed above that ar included in the March 31, 1981 letter. We acknowledge receipt of yg/r June 19, 1981 letter regarding SEP Topic III-6, " Seismic Design".
ur response to this letter will be the subject of separate correspo ence.
Should you have any questions regarding the staff pop tion, please do not hesitate to contact the Project Manager, Mr. W fter Paulson (exter.sion 301/492-7214).
Sincere I arold R. Denton, Director ffice of Huclear Reactor Regulation
Enclosure:
DISTRI UTI0a:
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Mr. R. B. DeWitt Your March 31, 1981 letter also indicated that you iritend to use the PRA for "all current and future" safety issues. Wejhave only reached a conclusion on deferral on those items discussed,above that are included in the March 31, 1981 letter. At this time, sh '1d you want consideration for other items, we would expect. hat you woul submit a specific request in a tinely manner.
Should you have any questions regarding the staff position, please do not hesitate to contact the staff.
Sincerely, Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
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downcomer region are representative of the level in the cor,e You indicated that due to the fact that there is a steam drum at Big Rock and other design differences that isolation of the, recirculation loops will not isolate the reactor or steam drum level 4nstrumentation from the volumes for which they provide level monitori,ng. We agree that such an interlock is r.at required because of design differences in Big Rock.
Finally, you requested deferral of implementation of a number of other staff positions as a result of the PRA concl isions. A list of these is provided in Enclosure 1.
Ths basis for tiiis deferral is the poten-tial low risk to the public health and safety from the Big Rock Point plant. Because of the relatively low powir level of Big Rock Point (70 Mee) cc:npared to other current opera (ing plants and the remote locat. ion with a low population in the vicinity of the facility, we conc 1r with a temporary deferral pending completion of cur review of the PRA. By that we mean that should the completed staff review indicate that a deferred item is reiuircd to substantially ehhance l
plant safety at Big Rock, it will be implemented. The appropriate
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implementation schedule will tnen be developed consistent with the significance of the issue.
Should you have any question regarding the staff position, please do not hesitate to contact the staff.
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Mr. Russell B. DeWitt Second, Attachment 6 of your March 31, 1981 letter requested a deferral
.of faplementation of an interlock on the recirculation pump loop. The position of NUREG-0757 Itr II.K.3.19 is that at least two recirculation loops are to be open for i sow-so that level measurements in the downcomer region are representative of the level in the core region. You indicated that due_to the fact that there is a steam drum at Big Rock, and other_ design differences, isolation of the recirculation loops will not isolate the reactor-or steam drum level instrumentation from the volumes for which they provide level monitoring. We have completed our review and conclude that such an interlock is not required on Big Rock Point because of such design differences.
. Finally, you requested deferral of implementation of a number of other staff requirements as a result of your PRA conclusions. A list of these is pro-vided in Enclosure 1.
Your basis for this deferral is the PRA. We believe that an overall risk assessment is a valuable technique for providing in-F sight into the identification of significant contributors to risk.,We are}
jt reviewing your request to defer Items 1-5 and the control ro m habitability.-
rtion _of em 6_ ingjunction with our review of the PRA. Should the j
cogleted sta F~rsi7tennaicate that onror more of ems are required tr substantially enhance plant safety at Big Rock, they will then be required.
[p The appropriate implementation schedule will then be developed.
,L With respect to the reinainder of Item 6, the permanent emergency response f acilities are not required to be operational until October 1,1982. You p#" _
~were'requiFed by the 0.tober 30,1979 D0L letter to have an interim Technical j
Support Center (TSC) as described in HUREG-0578 (Section 2.2.2).
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accordance ~with our. February 18, 1981 letter that provided pages for NUR2G-0737, i
Item III.A.1.2, you were(required to submit conceptual designs for the total emergency response facilifieri as described by NUREG-0696 by June 1,1981, 3
for NRC review and preimplementation approval. As to your specific concerns regarding the onsite TSC, there is no need for a deferral _ at this time.
With respect to Item 7, and specifically to the meteorological system, Arnex 1 to Argendix 2 of NUREG-0654 gives a schedule for implementation of the metTorological elements of the emergency response plan.
In brief, you are required, at this time, only t. have a system equivalent to a backup system as described in the proposed Revision 1 to Regulatory Guide 1.23, and certain other capabilities. A primary system consisting of a full meteorological
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Note to Walt Paulson BIG ROCK POINT PROBABILISTIC RISK ASSESSMENT l
As we discussed the changes which should be made are those indicated l
by Joe Scinto on the letter.
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Janice E. fiocre l
Counsel for NRC Staff l
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