ML20054M670

Requests Current Info Re Unresolved Safety Issue Status. Items Per ALAB-444 Will Enable NRC to Expeditiously Review & Evaluate Issues Re Conversion of Provisional to full-term OL

ML20054M670
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	07/06/1982
From:	Lainas G Office of Nuclear Reactor Regulation
To:	Linder F DAIRYLAND POWER COOPERATIVE
References
ALAB-444, LSO5-82-07-007, LSO5-82-7-7, NUDOCS 8207140180
Download: ML20054M670 (9)

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e DISTRIBUTI0ri July 6, 1982 Docket NRC PDR Local PDR Docket !M. 50-409 ORB Reading hutchfield LS05-82-07-007 HSmith DDudley Mr. Frank Linder OELD OI&E General Manager ACRS (10)

Dairyland Power Cooperative 2615 East Avenue South SEPB La Crosse, Wisconsin 54601

SUBJECT:

Uf; RESOLVED SAFETY ISSUES STATUS FOR Tile LA CROSSE BOILING UATER REACTOR (LACBUR)

The. staff's safety evaluation report regarding the conversion of the Provisional Operating License for LACBWR to a full-tem operating license must address the status of unresolved safety issues (sco discussion of ALAB-444 in Enclosure 1). To enable the staff to expeditiously review and evaluate the status of these itens at LACBUR, we will need up-to-dato information of the type described in the enclosure to this letter for.the unresolved safety issues listed in Encloosrc 1.

Accordingly, pursuant to $50.54(f) of 10 CFR 50, you are requested to furnish the following infomation with regard to each of the identified unresolved safety issues within 60 days of the date of this lotter:

(1) has the issue been resolved at LACDUR; (2) if so, how has it been resolved; and-5p/

(3) if full resolution has not occurred (including inplementation

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of necessary hardware. procedures, etc.) what interin measures I

have been taken to assure that continued operation would not pose an undue risk to the public.

The reporting and/or recordkeeping requircaents contained in this letter affect fewer then ten respondents; therefore, 0:!B cicarance is not required under P.L.96-511.

Sincerely, Original signed by Gus C. Lainas. Assist at Director 8207140100 020706 for Safety Assessacr.t DR ADOCK 05000 Division of Licensing p

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Mr. Frank Linder

~. July 6, 1982

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Frit'z Schubert, Esquire U. S. Environmental Protection Staff Attorney Agency Dairyland Power Cooperative Federal Activities Branch

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2615 East Avenue South Region V Office La Crosse, Wisconsin 54601 ATTN:

Regional Radiation Representative 230 South Dearborn Street O. S. Heistand, Jr., Esquire Chicago, Illinois 60604 Morgan, Lewis & Bockius 1800 M Street, N. W.

Mr. John H. Buck Washi'ngton, D. C.

20036 Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Mr. R. E. Shimshak Washington, D. C.

20555 La Crosse Boiling Water React'or Dairyland Power Cooperative Mr. Ralph S. Decker P. O. Box 275 Route 4, Box 190D Genoa, Wisconsin 54632 Cambridge, Maryland 21613 Mr. George R. Nygaard Charles Bechhoefer, Esq., Chairman Coulee Region Energy Coalition Atomic Safety and Licensing Board 2307 East Avenue

.U. S. Nuclear Regulatory Commission La Crosse, Wisconsin 54601 Washington, D. C.

20555 Dr. Lawrsnce R. Quarles Dr. George C. Anderson Kendal at Longwood, Apt. 51 Department of Oceanography

, Kenneth Square, Pennsylvania 19348 University of Washington-Seattle, Washington 98195

,U. S. Nuclear Regulatory Commission Resident Inspectors Office James G. Keppler, Regional Administrator Rural Route #1, Box 276 Nucle ~ar Regulatory Commission, Region III Genoa, Wisconsin 54632 799 Roosevelt Road Glen Ellyn, Illinois 60137 l

Town Chairman Thomas S. Moore

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l Town'of Genoa Atomic Safety and Lic.ensing Appeal Board Route 1 U. S. Nuclear Regulatory Commission Genoa, Wisconsin 54632 Washington, D. C.

20555 Chairman, Public Service Commission of Wisconsin Hill Farms State Office Building

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Madison, Wisconsin 53702 Alan S. Rosenthal, Esq., Chairman Atomic Safety and Licensing Appeal Board l

U. S. Nuclear Regulatory Commission l

Washington, D. C.

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STATUS OF UNRESOLVED SAFETY ISSUES AT LACBWR The NRC staff evaluates the safety requirements used in its reviews against new information as it becomes available.

Information related to the safety of nuclear power plants comes from a variety of sources including experience from operating reactors; research resu.lts; NRC staff and Advisory Committee-on --

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Reactor Safeguards safety reviews; and vendor, architect /engineeri.and utility design reviews.

Each time a new concern or safety issue is identified'

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from one or more of these sources,ttfe tieed Tof-im?nediate action to ensure safe

• N-operation is assessed.

This' assessment inhludes consider ~a' tion"of the. gener.,ic

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- implicat. ions of the issue.

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

.In other cases, interim measures, such as modifications to operating

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procedures, may be sufficient to. allow'fprther study of the is. sue before -

licensing decisions are'made.- In most casus', 'the initial' assessment 'ihdicates

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s that immediate li'celisihg actions or chaNe~s in licensing criteria are hot necessary.

In any event, further study may be deemed appropriate to make judgments as to whether existing NRC staff requirements should be modified to address the issue for new plants or if backfitting is appropriate for the long-term operation of plants already under construction or in operation.

These issues are sometimes called " generic safety issues" because they are 7-

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

These issues have also been referred to as " unresolved safety i~ssues" (NUREG-0410, "NRC Program for the Resolution of Generic Issues Related to Nuclear Power Plants," dated Jan'ua?y 1, ~1978).

However, as discussed above, such issues are considered on a generic basis only after the staff has made an

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initial determination that the safety significance of the issue does not

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prohibit continued operation or require licensing actions while the lo'nger-term generic review is under way.

A Decision by the Atomic Safety.and Licensing Appeal Board of the Nuclear Regulatory Commission addresses' these longer-term generic studies.

The Decision was issued on November 23,197i h

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(ALAB-444) in conntetion with the Appsal Board's consideration of the Gulf States Utility Company application for the River Bend Station, Units 1 and 2.

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

The responsitJ1ities of a licensing board in the radi~ological health and safety sphere are not confined to the consideration and dispo-sition of ti,ase issues wnich may have been presented to it by a party

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or an " Interested State" with, the required degree of specificity.

To

'he contrary, irrespective of what matters may o,r may rrot tave been

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properly placed in controversy, prior to authorizing the issdance of a construction permit the board must make the finding,- inter alia, T. "

that there is " reasonable assuiance tha(."the proposed facility can Y

br constructed and operated at, the pr.op.osed, loc.ation.without undue risk to the health and safety of.the public."

Of necessity, this 10 CFR 50.35 (a) determinatioh will entail an inquiry into whether the _

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staff revi.ew satisf.actorily has come to. grips _with any unresolved generic safety problems which might have an impact' upon operation of the nuclear facility under consideration.>

The SER is, of course, the principal document before the licensing board which reflects the content and outcome of the staff's safety review.

The board should therefore be abiv-to look to that document to ascertain the extent to which genevic unresolved safety problems.

which have been previously identif-ied i~n an TSAR item, a Task Action Plan, an ACRS report or elsewhere hdWteen factored into thel staff's analysi.s for the particular reactor--and with what result.

To this end, in our view, each SER should contain afsummary description of those generic problems under continuing study which have both rele -

vance to facilities of the type under review and potentitlly 'signifi-cant public safety implications.

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This summary description should include information 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.will be undertaken with regard to the problem, the program's anticipated time span, whether (and if so, shat) interim measures have been devised for dealing with the problem pending the completion of the investigation, and what alternative course of action might be avail-able should the program not produce the envisaged result.

In short, the board (and the public as well) should be in a position

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to ascertain from the SER itself--without the need to resort to extrinsic documents--the staff's perception of the nature and e.xtent of the relationship between each significant unresolved generic safety question and the eventual operation of the reactor under.

scrutiny.

Once again, this assessment might well have a direct bearing upon the ability of the licensing board to make the safety findings required of it on the construction permit. level even though the generic answer to the question remains in the offing.

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

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(1) the problem has already been resolved for the reactor under study; (2) there is a reasonable basis for concluding that a satisfactory solution will be obtained before the reactor is put in operation; or (3) the problem would have no safety implications until after several years of reactor operation and, should it not be esolved by then, alternative means will be available to insure that

.tinued operation (if permitted at all) would not pose an undue risk to the public.

This section is specifically included to respond to the decision of the Atomic Safety and Licensing Appeal Board as enunciated in ALAB-444, and as applied to

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an operating license proceeding Vircinli Ele *ctrTc and Po'wer Comoany (North A'nna

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Nuclear Powbr Station Unit Nos. Land 2), ALAB-491-8 NRC 245 (1978).

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-In a related matter, as a result of Cong,re,ssional action on the Nuclear Regulatory Commission budget for Fiscal Year 1978, the Energy Re~ organization '

Act bf 1974. was amended (PL 95-209) on December 13, 1977 to include, among other things, a new Section 210 as follows:

UNRESOLVED SAFETT 153U1"5 PLAN s~

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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 i

reactors and shall take such actions as may be necessary to implement l

corrective measures with respect to such issues.

Such plan shall be submitted to the Congress on cr before January 1, 1978, and progress l

reports shall be included in the annual report of the Commission l

thereafter.

The Joint Expla.natory Statement of the, House-Senate Conference Committee for the Fiscal Year 1978 Appropriations Bill (Bill 5.1131) provided the. following additional information.regarding the Committee's deliberations on this portion

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of the bill:

SECTION 3 - UNRESOLVED SAFETY ISSUES l

The House amendment required development of a plan to resolve generic safety issues.

The conferees agreed to a requirement that the plan be submitted to the Congress o'n or before January 1, 1978.

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conferees also expressed the intent that this plan should identify

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and. describe those safety issues', relating ~to nuclear power reactors, i

which are unresolved on the date of enactment.

It should set forth:

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(1) Commission actions taken dir:ctly or indircctly to develop and implement corrective measures; (2) futher actions planned concerning such measures; and (3) timetables and cost estiutes of such actions.

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

M response to the reporting requirements of the new Section 210, the NRC staff submitted to Congress on January 1, 1978, a report, NUREG-0410,-entith d "NRC Program for the Resolution of Generic Issues Pelated -to Nucitar' Power Plants,."

describing the NRC generic issues-program.

The NRC program was already-in

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, place when PL 95-209 w'as enacted and W of cd_nstderably broader scope than the

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" Unresolved Safety Issues Plan" required.by Section 210. 'In the letter trans -

tnitting NUREG-0410 to the Congress oi) December 30, 1977, NRC indicated thati "the progress -ceports, -which are requir'ed by Section 210 to be included in future NRC annual reports, may be more useful, to Congress if they focus on.the specific Section 210 safety items."

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lt is the NRC's view that the intent of' S,ecTion 210 was to ensura that plans were developed and implemented on issuqs. with petentially significan+. public safety implications?

In 1978, the NRC TnMrtook a. review of more than'130 generic issues addressed in the N'RC pr6 gram to d'etermine which issues fit this description and qualify as unresolved safety is' sues for reporting to the Congress.

The NRC review included the development of proposals by the NRC staff and review and final approval by the NRC Commissioners.

This review is described in NUREG-0510, " Identification of Unresolved Safety c.

Issues Relating to Nuclear Power Plants - A Report to Congress," January l'979.

The' report provides the following definition of an unresolved safety issue.

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An Unresolved Safety Issue is a m'atter af fecting a number of nuclear power plants that poses important questions concerning the adequacy of existing safety requirements for 'which a final resolution has not yet been developed and that involves conditions not likely to be acceptable over the lifetime of the plants it affects.

Further, the report indicates that in applying this definition, matters that pose "iaportant questions concerning the adequacy of dxisting safety require-ments" were judged to be those for which resolution is necessary to (1) com-pensate for a possible major reduction in the degree of protection of the 4

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public health and safety or (2) provide a potCntially significant decrease in the risk to the public health and safety.

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

All of the issues addressed in the fiRC program were systematically evaluated against this definition as describ,ed in fiUREG-0510.

The issues are listed below.

Progress on these issues was first discussed *in the '197'8 f4RC Annual :T Report.

The number (s) of th6 generic task (s) (e.g., A-1).in the.!1RC pro' gram a

addres. sing each issue is indicated in parentheses 'following the title.-

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UNRESOLVED SAFETY ISSUES (APPLICABLE TASK NOS.)

{1) Waterhammer

.(A-1) ft/A (2) ^BWR MARX I Pressure Suppression Containments - (A-6, A-7, and A-39)

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

BWR Nozzle Cracking - (A-10) i (5) Reactor Vessel Materials Toughness (A-11)

(6)

Systems ' Interaction in Nuclear Power Plants (A-17) l (7) Environmental Qualification of Safety-Related Electrical Equipment (A-24)

(8) Residual Heat Removal Requirements (A-31)

(9) Control of Heavy Loads Near Spent Fuel (A-36)

(10)

Seismic Design Criteria (A-40) 1 l

(11)

Pipe Cracks at Boiling Water Reactors (A-42)

(12)

Containment Emergency Sump Reliability (A-43)

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(13)

Station Blackout (A-44) l (14)

Shutdown Decay Heat Removal Requirements (A-45)

(15)

Seismic Qualifications of Equipment.in Operating Plants (A-46 (16)

Safety Implications of Control Systems (A-47)

(17)

Hydrogen Control Measures and Effects of Hydrogen Burns on Safety Equipment (A-48)

The NRC staff has issues reports providing its proposed resolution of Eight of l

these issues.

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4 NRC cttff'o prcporrd racolution cf Eight cafcty incue]

Task number NUREG report number and title A-6 NUREG-0408, " MARK I Containment Short Term Program."

A-7 NUREG-0661, " MARK 1 Containment Long Term Program."

A-9 NUREG-0460, V0'L. 4, " Anticipated Iransients-Without Scram l

for Light Water Reactors" A-10 NUREG-0619, "BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking."

A-24 NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment."

A-31 SRP 5.47 and BIP 5-1, " Residual Heat Removal Systems" incorporate requirements, of USI A-31 A-36 NUREG-0612," Control of Heavy Loads at Nuclear Power Plants A-42 NUREG-0313,REV.1, "BWR Coolant Pressure Boundry Piping.i' With the exception of Tasks A-9, A-43, A-44, A-47, and A-48, Task Action Plans for the generic tasks above are included in NUREG-0649, " Task Action Plans for Unresolved Safety Issues Related to Nuclear Power Plants." A technical resolution for Task A-9 has been proposed by the NRC staff in Volume 4 of NUREG-0460, issues for comment. This served as a basis for the st'aff's proposal for rulemaking on this issue. The Task Action Plan for Task A-43 was issued in January 198,1, and the Task Action Plan for A-44 was issued in July 1980.

The information provided in NUREG-0694 meets most of the informational requirements of ALAB-444. Each Task Action Plan provides a description of the problem; the staff's approaches to its r.esolution; a general discussion of the bases on which continued plant lic-ensing or operation can proceed pending co=pletion of the task; the technical organization involved in the task and estimates of the manpower required; a des-cription of the interactions with other NRC offices, the Advisory Co==ittee'on Reactor Safeguard and outside organizations; estimates of funding required for contractor-supplied technical assistance; pr'ospective dates for co pleting,the task; and a description of potential problems that could alter the planned approach on schedule.

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In addition to the Task Action Plans, the staff issues the " Office of Nuclear Reactor Regulation Unresolved Safety Issues Sumary, Aqua Book" (NUREG-0606) on a quarterly basis, which provides current schedule information for each of the unresolved safety issues.

It also includes information relative to the imple-

.sr,tation status of each unresolved safety issue for which technical resolution is complete.

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