ML20054M204

Forwards Guidelines for Info Needed to Update Unresolved Safety Issues for Facility.Info Required within 60 Days

ML20054M204
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	07/07/1982
From:	Lainas G Office of Nuclear Reactor Regulation
To:	Counsil W CONNECTICUT YANKEE ATOMIC POWER CO.
References
NUDOCS 8207120094
Download: ML20054M204 (9)

Text

.ur Distribution Jult 7, 1982 Docket File Local PDR NRC PDR NSIC ORB reading Docket No. 50-213 D. Crutchfield H. Smith C. Tropf Mr. W. C. Counsil, Vice President OELD Nuclear Engineering and Operations OI&E Connecticut Yankee Atomic Power Coc:pany ACRS (10)

Post Office Box 270 SEPB flartford, Connecticut 06101

SUBJECT:

UNRESOLVED SAFETY ISSUES STATUS FOR THE HADDAM NECK PLANT The staff's safety evaluation report regarding the SEP Integrated Assessment Program (IAP) for Haddam Neck Plant must address the status of unresolved safety issues (see discussion of ALAB-444 in ).

To enable the staff to egeditiously review and evaluate the status of these items at Haddam Neck, we will need up-to-date information of the type described in the enclosure to this letter for the unresolved safety issues listed in Enclosure 1.

Accordingly, pursuant to 850,54(f) of 10 CFR 50, you are requested to fu hish the following information with regard to each of the r

identified unresolved safety issues within 60 days of the date of this letter:

(1) has the issue been resolved at Haddam Neck; (2) if so, how has it been resolved; and (3) if full resolution has not occurred (including implementation of necessary hardware, procedures, etc.) what interim measures have been taken to assure that continued operation would not pose an undue risk to the public.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.LL.96-511.

Sincerely, Original signed by Cus C. Lainas, Assistant Director for Safety Assessment Division of Licensing

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• • July 7, 1982 Mr. W. G. Counsil CC Day, Berry & Howard Counselors at Law One Constitution Plaza Hartford, Connecticut 06103 Superintendent Haddam Neck Plant RFD #1 Post Office Box 127E East Hampton, Connecticut 06424

. Mr. Richard R. Laudenat Manager, Generation Facilities Licensing Northeast Utilities Service Company P. O. Box 270 Hartford, Connecticut 06101 Board of Selectmen Town Hall Haddam, Connecticut 06103 State of Connecticut 0Ffice of Policy and Management ATTN: Under Secretary Energy Division 80 Washington Street Hartford, Connecticut 06115 U. S. Environmental Protection Agency Region I Office ATTN:

Regional Radiation Representative JFK Federal Building Boston, Massachusetts 02203 Resident Inspector Haddam Neck Nuclear Power Station

.c/o'U. S..NRC East Haddam Post Office East Haddam, Connecticut 06423 Ronald C. Haynes, Regional Administrator Nuclear Regulatory Commission, Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 l

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' 'g S' ATUS OF UNRESOLVED SAFETY ISSUES AT HADDAM tlECK T

The NRC staff evaluates the safety reouirements used in its reviews against new information as it becomes available.

Information related to the saf.ety of nuclear ccwer plan s comes frca a variety of scurces including. experience frcm c; era.ing reactors; resaarcn resuits; NRC staff anc' Adviscry Ch.mittee en P.aac cr Safeguards sr.fety reviews; and vendor, archigct/ engineer, and

.- e utility design reviews.

Each time a new concern or safety issue'is identifi'ed from one or more of tt)gse sources, the need for immediate action tr ansure safe cperation is assessed.

This assessment includes consiceration of the generic.

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implications of the issue.

In some cases, immediate action is taken to ensure safety.

In other cas'es, interim measures, such as modifications to operating.

procedur'es, may be sufficient to allow further study of the issue before licensing decisions are'made.

In most cases', fthe initial as'sessment ' indicates -

that immediate licensing actions or changes' in licensing criteria are not In any event, further study may be deemed apprbpriate to make necessary.

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judgments as to whether existing NRC staff requirements should be modified-to

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address the issue for new plants or if backfitting is appropriate 'for the' long-term operation of plants alresdy under construction or in operation.

These..ssues are so,metimes called " generic safety issues" because they-are < g..

related to a particular class or type of nuclear facility rather than to

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-specific plant'.' These issues have also been referred t,o as ".unr.esolved safety issues"- (NUREG-0410, "NRC Program for the Resolution of Generic Issues Related to Nuclear Pcwer Plants," datec January 1, 1978).

However, as discussed above, sucn issues are consicerec on a generic basis only after the staff has made an initiai cetermination that the safety significance of the issue does not c

l prchibit continued cperati.on or rec.uire licensinc actions while the. longer-s,-.

term generic rev;ew is under way.

A Decision by the Atomic Safety and Licansing Appeal Scard of the Nuclear Regulatory Ccmmission actresses these' l

ionger-term generic stucies.

The Decision was issued on November 23, 1977

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(Al,AS-44) in conntetion-with the Appeal Board's consideration of the Gulf ~

States Utility Company application for the P.i.ver Bend Station, Units 1 and 2.

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In the view of the Appeal Board (pp. 25-29),

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The responsibilities of a licensing board in the radiological health a c safety s:nere are not confined to the consideration and dispo'-

s i;icr. Of nes e i s s ues which 22. have teen presanted to it by a party or an " Interested State" with the requir# c'egree of specificity.- To the centrary, irrespective of What matters may or..may not have b'een' preperly piaced in centroversy, prior to authorizing the issnance of a cons ruc-icn permit the board must make the finding, _ inter alia, that there is " reasonable assurance" that ".the proposed f acility can be constructed and operated at the proposed location without undue risk to the health and safety of the public:"

Of' necessity, this :10 CFR 50.35.(a) determination vill Entail an inquiry into whether th'e

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staff revi'ew satisf actorily has come to orips with any unresolved

. generic safety problems which might have an impact'upon op'eiati6n~ of

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the nuclear facility under consideratioh.

Th SER is, of course, the principal document before the licensing board which reflects the co,ntent and outcome of the staff's safety

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review.

The board should therefore be able to look to that document to ascertain the extent to which generic unresolved safety problems which have been previously identified in an FSAR item, a Task Action Plan, an ACRS report or elsewhere have been factored into the.':taff's' analysis for the particular reactor--and.with what result.

To this end, in our view, each SER should contain a summary description of those generic' problems under continuing study which have both?rele

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vance to facilities of the type under review and potentially-signifi -

cant public safety implications.

This summary description should

• include iri, formation of the kind now contained in most Task Action Plans.

More specifically, there' should be 'an indication of the investigative program which has been or'wil.1

.c be. undertaken wiE regard to the problem, the program's anticipated time span, whether (and if so, what) interim measures have been devised for dealing with the problem pending the completion of the I

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' nvestigation, and what alternative course ~of action mi' ht' b'e'~ avail-i g

able.should the prog.r.am not produce the envisaged result.

In short, the board (and the public as well) should be in a positi'on to ascertain frcm tne SER itself--without the need to resort to extrinsic documents--the staff's perception of the nature and extent of the relatienship between each significant unresolved generic safetv questien and the. eventual cperation of the reactor under scrutiny.

Once 'agaIn,' tMs assessment might well have a direct beeri-nc u;cn the.abiiity of the licensing bcard to mcke the safef.y

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findin;s recuired of it on the construction permit level even though

.he ceneric answer to the question remains in the offing.

Among other thines, the furnished information would likely shed light on sucn alternatively important considerations as whether:

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(1) the problem has already been r: solv;d for the reactor under -

study; (2) there is a reas.onable basis for, concluding that a

. satisfactory solution will be obtained before the reactor is put in operation; or (3) the proble=.would have no safety implications until after several years of reactor cperation and, should it not be resolved by then, alternative means will be available to insure that c:..tinued cperatier. (if permined at all) would net-pose an undub 3

n :ne pu:lic.

This section is specifically included ::: respond to the decision of the Atomic fj 1

Safety and Licensing Appeal Ecard as enunciated in ALAB-tt-4, and as applied to an operating license pf'oceeding Vircinia Electric and Power Comcany '(North Anna Nuclear Power Station Unit Nos. I and 2), ALAB-491, 8 NRC 2.45 (1978)

In a. related matter, as a result of C-ongressional action on the Nuc-lear-Regulatory Commi'ssion budget for Fiscal Ye'ar,1978,' the Energy Reorganization Act of-1974 was amended (?L 95-209) on December 13, 1977 to include, among other things, a new Section 210 as follows:

UNRESOLVED SAFETY ISSUES PLAN

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SEC. 210.

The Commission shall develop a' plan providing for specifi-cation and analysis of unresolved safety issues relating to nuclear' reactors and shall take such actions as may'be necessary t'o implement corrective measures with respect to such issues.

Such plan shall be submitted to the' Congress on or before January 1,1978, and progi ess reports shall be included, in the annual report of the. Commission thereafter.

i l-The Joint Explanatory Statement of the House-Senate Conference Committee.for h-the Fiscal Yeaf'1978 Appropriations Bill (Bill-5.1131) provided 4-he following l

. additional information.r,egarding the Committee's, deliberations on this portion l

of the bili:

SECTION 3 - UNRESOLVED SAFETY ISSUES l,.

The House amencment requirec development of a plan to resolve ceneric

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safety issues. "Thi conferees agreed to a recuirement thi.t the p'lan be se::mitted to the Congress on or before January 1,1978.

The conferees also expressed the intent that this pian should identify ano describe those safety issues, relating. to nuclear power reactors, l

ynich are unresolved on the date of enactment.

It should set forth:

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(1) Commissicn tctions taken directly cr indirectly to develop and implement corr;ctive measures; (2) futher actions planned concerning such measures; and (3) timetables and tost estimates of such ' actions.

The Commission should indicate the priority it has assigned to'each issue, and the basis on which p.riorities have been assigned.

In res:cnse to tne repcr.ing recuirements of the new Seciion 210, the NRC staff sucmi tec to Congress on January 1,1978, a report, NUREG-0410, entitled "NRC

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Progra-for the Resolution of Gene'ic Issues Related.to Nuclear-Power PYants.,"

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describing the NRC generic issues program.

The NRC program was already in

' place when PL S5-209 was enacted and is of considerably broader scope than the

" Unresolved Safety Issues Plan" required by Section 210.

In the letter trans.

mitting NUREG-0410 to the Cong'ress on December 3'0, 1977, NRC indicated' th'at -'.

"the progress reports, which are requ-ired by Section 210 to..be. included..in

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fubre NRC annual reports, may be more useful to Congress if,they focus on,the

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specific Section 210 safety items."

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It is the NRC's view that the intent of Section 210 was to, ensure that plans

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were developed and implemented on issues with potentially significant public

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safety implications.

In 1978, the NRC. undertook a review of more than 130 generic issues addressed in the'N' C prdgram to 'd'etermine which is' sues ~ fit this R

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description and qualify as unresolved safety issues for repoi-ting to' the

' Congress.

The NRC review included the development of prope'sals' by the NRC staff and review and.. final approval.by the NRC Commissioners.

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This revied is described in NUREG-0510, " Identification of Unresol'ved Safetyv- '.

Issues Relating to Nuclear Power Plants - A Report to Congress," January 1979.

L-The ' report provi' des the fo.11owing definition of an unres,olved,sagty issue.

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An Unresolved Safety Issue is a matter affecting a number of nuclear

ower plan.s that poses important questions concerning the adequacy I

of existinc safety requirements for which a final resolution has not vet been ceveloped and that involves conditions not likely to be acceptable over the lifetime of the plants it affects.

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m Further,- the report inc.icates that in applying this definition, matters that pose "important cuestions concerning the adequacy of existing safety require-ments" were judged to be those for which resolution is necessary to (1) com-p'ensate for a possible major reduction in the degree of protection 'of the 1

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public health and safe'ty or (2) provid2 a poteritially signific' ant decrease 'in r=

the risk to the public health and safety.

Quite simply, an unresolved safety issue is potentially significant frem a public~ safety standpoint, and its resolution.is likely to result in NRC action on the affected plants.

e issues addressed in the EC Orogram were systb.aticilly evaluated

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-f :s agains this definition as described in NUREC--05i0.

The issues are listed b el ow.

Progress on these issues was first discussed-in the 'I'978 NRC Annual:

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The number (s) of the ceneric task (s) (e.g., A-1) in the NRC program addressing each issue Fs indicated in parenthes.es following the title ~.

UNRESOLVED SAFETY' IS' SUES fAPPLICABLE TAS'K N05.)

(1)

Waterhammer

-(A-1)

(2) Asymetric Elowdown Loads on the Reactor Coolant System (A-2)

Pressur' zed Water Reactor ' Steam Generator Tube Integrity (A-3! A-4, A-5) i (3)

(4) Anticipated Transients Without Scram (A-9)

(5)

Reactor Vessel Materials Toughness (A-ll.)

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(5)

Fracture Toughness of Steam Generator and Reactor Coolant Pump Supports Ail 2)

(7)

Systems. Interaction in Nuclear Power Plants (A-17)

-(8)

Environmental Qualification of Safety-Relate'd Electrical E(uipment (A-24),

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(g)

Reactor Vessel PVessure Transippt Protect. ion (A-26)

(10). Residual Seat Removal Requ.irements (A-31)-

(il)

Control of ' Heavy Loads Near Spent Fuel (A-35)

(12)

Sei,smic Desi gn.'Ciiteria (A-40). -

(13)' Containmerrt Emergency Sump Reliability (A-43) e-(14)

Station Blackout (A-44)

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' (15)' Shutdown Decay Heai' Removal Recuirements (A-45)

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(15)

Seismic Qualification of Ecuipment in Operatiric Plants (A-46)

(17)

Safety Implications of Control Systems (A 47) h.

.. (1S)

, Hydrogen Contrel Measures and Effects of Hydrogen Burns on Safety Ecuipment (A-48)

(19)

Fressuri ed Thermal. Shock (PTS) ( A-49)

The NRC staff has issued reports providing its proposed resolution of six of these issuds.

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v NRC' staff's proposed resolution of six. safety issu::s :

Task number NUREG report number and'titl'e A.2 NUREG-0690, " Asymmetric Blowdown Loads on PWR Pr.imary Systems" A_g NUREG- 0 50, Vci. 4, " Anticipated Transients Without Scram

1. cr !.icht Water Reactors" A-2; NUREG-05ES, " interim Staff Pesition on Environmental c

Qualification of Safety-Related Electrical Equipment"

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A-25 NUREG-0224, " Reactor Vessei,. Pressure Transient Protection,,

for Press.ur.ized Wa_ter Reactors" and NUREG-0800, BTP.RSB.

5-2 SRP 5.47 and BTP 5-1, " Residual Heat Removal Systems" A-31

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incorporate requirement's of USI A-31 A-35 NUREG-0612,, " Control of Heavy Loads at Nuclear Power Plants With the exception of Tasks A-9, A-43, A-44, A-47, A '48 and A-49, Task. Action Plans for th'e generic tasks above are included in NUREG-0649, " Task Action Plans for,

ee Onresolved Safety Issues Related to Nuclea'r Power Plants."

A' technical res.oluti.o..n for Task' A-9 has been proposedsby the NRC staff in Volume 4'of'NUREG-0450, issued <

. for cornent.

This served as a basi.s for the.,s, taff's proposal for rulemakinion ' M this. issue.

Th'e Task Action Plan for Task A-43 was issued in January 1981, and the Task Action Plan gr A-44 was issued in July 1980.

Draft NUREG'-0577.which,..

represe'nts staff resolution of USI A 12 was issued for comment in November 1979.

The,' Draft NUREG contained the Task Action Plan for A-12.

The, info,rmation provided in NUR'E'G-0594 meets most of the informational requirements of ALAB-444.

Each Task Action Plan provides a d esiription of the.

problem; the staff's approaches to its resolution; a general discussion of the bases on which continued plant licensing or operation can proceed pending completion of the task; the technical organita ion invoived in the task and estimates of the manpower required; a' deftr%tfon of the interactior,s with other NRC offices, the

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Advisory' Committee on P,eactor Safeguards and outside organizations; es'timates. of

. funding required for contractor-supplied technical assistance; prospective dates

' for compigting the task; and a description of potential problems tha,t could alter the planne'd. approach on sched'le.

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In addition to tha Task Action' Plans, the staff issuas the " Office of'Hucl' ear Reactor Regulation Unresolved Safety Issues Su::inary, Aqua Book" (NUREG-0505) on a quarterly basis, which provides current schedule information for each.of the unresolved safety' issues.

It also includes information relative to the imple-

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.sniatien status cf each unresolvsf safety issue for which technical esol ution is :c ;ie:e.

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