ML20054M695

Forwards Request for Info Re Unresolved Safety Issues.Status of Unresolved Issues Encl.Response within 60 Days Requested

ML20054M695
Person / Time
Site:	Millstone
Issue date:	07/07/1982
From:	Lainas G Office of Nuclear Reactor Regulation
To:	Counsil W NORTHEAST NUCLEAR ENERGY CO.
References
ALAB-444, LSO5-82-07-013, LSO5-82-7-13, NUDOCS 8207140238
Download: ML20054M695 (9)

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July 7, 1982 Local PDR ORB Reading flSIC Docket !!o. 50-245 DCrutchfield LS05-82-07-013 HSmith JShea OELD OI&E Mr.11. G. Counsil, Vice President Iluclear Engineering and Operations ACRS (10)

SEPB flortheast fluclear Energy Company Post Office Box 270 Hartford, Connecticut 06101

SUBJECT:

UNRESOLVED SAFETY ISSUES STATUS FOR THE !!ILLSTONE flUCLEAR POWER STATIO!!, UrlIT l'0.1 The staff's safety evaluation report regarding the conversion of the Provisional Operating License for Millstone Unit No.1 to a full-tern operating license must address the status of unresolved safety issues (see discussion of ALAB-444 in Enclosure 1). To enable the staff to expeditiously review and evaluate the status of these itens at Millstone Unit Ho.1, 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 furnish the following information with regard to each of the identified unresolved safety issues within 60 days of the date of this letter:

(1) has the issue been resolved at Millstone Unit No. 1; (2) if 2, how has it been resolved; and (3) if full resolution has not occurred (including inplementation 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 gc/

affect feuer than ten respondents: therefore, 0",B clearnace is not required under P.L. 9G-511.

Sincerely, Original signed by Gus C. Lainas, Assistant Director 8207140238 820707 SaW 6mW DR ADOCK 05000245 Division of Licensing PDR cc.

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Mr. W. G. Counsil July 7, 1982 CC William H. Cuddy, Esqr ce State of Connecticut Day, Berry & Howard Office of Policy & Management Counselors at Law ATTN:

Under Secretary Energy One Constitution Plaza Division Hartford, Connecticut 06103.

80 Washington Street Hartford, Connecticut 06115 Ronald'C. Haynes, Regional Administrator Nuclear Regulatory Commission

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Region I Office 631 Park Avenue King of Prussia, Pennsylvania 19406 Northeast Nuclear Energy Company ATTN:

Superintendent Millstone Plant P. O. Box 128 Waterford, Connecticut 06385 Mr. Richard T. Laudenat Manager, Generation Facilities Licensing Northeast Utilities Service Company P. O. Box 270 Hartford, Connecticut 06101 Resident Inspector c/o U. S. NRC P. O. Box Drawer KK Niantic, Con'necticut 06357 First-Selectman of the' Town of Waterford Hall of Records 200 Boston Post Road Waterford, Connecticut 06385 John F. Opeka

- Systems Superintendent Northeast Utilities Service Company P. O. Box 270 Hartford, Connecticut 06101 U. S. Environmental Protection Agency Region'I Office ATTN:

Regional Radiation Representative JFK Federal Building Boston, Massachusetts 02203 e

ENCL.0.5URE 1

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STATUS OF UNRESOLVED SAFETY ISSUES AT MILLSTONE 1 The NRC staff evaluates the safety ' requirements used in its reviews against new information as it becomes available.

Information related to the safety of

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

Reactor Safeguards safety reviews; and vendor, architect / engineer.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,' tife~tieed Tof-immiadiate action.to ensure safe "

N-operation is assessed.

This~ assessment inEludes co,nsider'a' tion"of the. gener.ic' Z_ -

implications of the-1ssue.

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

In other cases, interim measures, such as modifications to operating procedures, may be sufficient to allow'fprTner study of the issue before

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

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s that-immediate li~ceMsihg 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

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long-term operation of plants already under construction or in operation.

These issues are sometimes called " generic safety issues" because they are related to a particular class or type cf nuclear facility rather than to a specific plant.

These issues have also been referred to as " unresolved safety issues" (NUREG-0410, "tiRC Program for the Resolution of Generic Issues Related to Nuclear Power Plants," dated Jan'ua?y 1,'1978). ~However, as discussbd above, such issues are considered on a generic basis only after the staff has made an l

initial determination that the safety significance of the issue does not 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 Decisid'n was issued on November 23, 1977

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(ALAB-444) in conn:ction with the Appeal Board's consideratien of f.he 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 responsibilities of a licensing board in the radi'ological health and safety sphere are not confined to the consideration and dispo-sition of those issues which may have been presented to it by a party or an "Intererted State" with, the required degree of specificity.

To

'he contrary, irrespective of what matters may or may not tave been

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properly paced in controversy, prior to authorizing the issuance of a constructica permit the board must make the finding, inter alia, that there is " reasonable assuranie* thait,. "t'Iie ~ proposed f acility can -

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br constructed and operated at, the prop,oserd. loc.ation.withou't 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 _ -

T staff revi.ew satisf.actorily has come to.gri,ps _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 identified in a~n 7SAR item, a Task Action Plan, an ACRS report or elsewhere hdwteen factored into thef staff's analysi.s 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-l vance to facilities of the type under review and potentially 'signifi-l cant public safety implications.

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This summary description shoul8 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 extent 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 cons'iderations 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 c-til after several years of reactor operation and, should it not be esolved by then, alternative means will be available to insure that

ainuea operation (if permitted at all) would not pose an undue

-isk to the public.

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This section is specifically included to respond to t'he decision of the Atomic-..

• m Safety and Licensing Appeal Board-as enunciated in ALAB-444, and as applied to

'f an operating license proceeding Virainli Ele *ctrTc and Power Comcany (North A'nna h-Nuclear Power Station Unit Nos T.and 2),' NLAB-491 8 NRC245 [1978).

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-In a related matter, as a result of Cong,ressional a'ction on the Nuclear

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Regulatory Commission budget for Fiscal Year 1978, the' Energy Re* organization Act of 1974. was amended (PL 95-209) on December 13, 1977 to include, among other things, a new Section 210 as follows:

UNRESOLVED SAFETY'IS' SUES PLAN SEC. '10.

The Commission shall develop a plan providing for specifi-2 cation and analysis of unresolved safety issues relating to nuclear reactors and shall take such actions as may be necessary to implement corrective measures with respect to such issues.

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

The Joint Explanatory Statement of the, House-Senate Conference Committee for I

the Fiscal Year 1978 Appropriations Bill (Bill S.1131) provided the following 1

l additional information;regarding the Committee's deliberations on this portion

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of the bili:

SECTION 3 - UNRESOLVED SAFETY ISSUES 1

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

The conferees agreed to a requirement that the plan l

be submitted to the Congress on or before January 1, 1978.

The conferees also expressed the intent that this plan should identify l

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and describe those safety issues', relating'to nuclear power reactors, which are unresolved on the date of enactment.

It should set forth:

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

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

n response to the reporting requirements of the new Section 210, the NRC staff submitted to Congress on January 1,1.978, a report, NUREG-0410, entitled "NRC Program for the Resolution of Generic Issues Related-to Nucl' ear' 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 ir of constderably broader scope ~ t.han the

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" Unresolved Safety Issues Plan" required by' Section 210.

In the letter trans -

mitting NUREG-0410 to the Congress oli December 30, 1977, NRC indicated that'-

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"the progress -ceports, which are requir'ed by Section 210 to be included in future NRC annual reports, may be more use'ful,to Congress if they foc0s on the sp e ific Section 210 safety items."

It is the NRC!s view that the intent of'5,ecTion 210 was to ensure that plans were developed and implemented on issugs. with poten'tially significant siublic safety implications ~ In 1978, the NRC YnMrtook a review of more than'130 generic issues addressed in the NRC program to d'etermine which issues fit this description and qualify as unresolved safety is' sues for reporting to the The NRC review included the development of proposali by the NRC Congress.

staff and review and final approval by the NRC Commissioners.

This review is desc,ribed in NUREG-0510, " Identification of Unresolved Safety Issues Relating to Nuclear Power Plants - A Report to Congress," January 1979.

The report p>uv' ides the following definition of an unresolved safety issue.

An Unresolved Safety Issue is a matter affecting a number of nuclear power plants that poses important questions concerning the adequacy of existing safety requirements for 'which a firal 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 potentially 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 NRC action on the affected plants.

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All of the issues addressed in the NRC program were systematically evaluated

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against this definition as described in. NUREG-0510.

The issues are listed

below.

Progress on these issues was first discussed *in the '19[8.NRC Annual : I - **

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Report.

The number (s) of th& gene 71c task (s) (e.g.., A-1).in the.NRC program

. addressing each issue is indicated in parenthe.ses 'following the ^itle.-

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UNRESOLVED SAFETY ISSUES (APPLICABLE TASK NOS.)

fl) Waterhammer. (A-1)

(2)

BWR MARK I Pressure Suppression Containments - (A-6, A-7, and A-39)

(3) Anticipatsd Transients Without Scram (A-9)

(4)

BWR Nozzle Cracking - (A-10)

(5) lieactor Vessel Materials Toughness (A-ll)

(6)

Systems Interaction in Nuclear Power Plants (A-17)

(7) Environmental Qualification of Safety-Related Electrical Equipment (A-24)

(8) Residual Heat Removal Requirements (A-31) l (9) Control of Heavy Loads Near Spent Fuel (A-36) l (10)

Seismic Design Criteria (A-40) l l

(11)

Pipe Cracks at Boiling Water Reactors (A-42)

.(12)

Containment Emergency Sump Reliability (A-43) l

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Station Blackout (A-44)

(14)

Shutdown Decay Heat Re= oval 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 o'f Hydrogen Burns on Safety Equipment (A-48)

The NRC staff has issues reports providing its proposed resolution ~of Eight of these issues.

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NRC ctcff'o prcpossd racolutien of Eight c:faty iccues_,

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

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

A-9 NUREG-0460, VOL. 4, " Anticipated Jransients-Without Scram

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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."

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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."

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

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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 staff's proposal for rulemaking on this i'ssue.

The Task Action Plan for Task A-43 was issued in January 1981, and the Task Action Plan for A-44 was issued in July 1980.

The information provided in NUREG-0694 meets most of the informa'tional requirements of ALAB-444. Each Task Action Plan provides a description of the problem; the staff's approaches to its resolution; a general. discussion of the bases on which continued plant lic-ensing or operation can proceed pending completion of the task; the technical organization involved in the task and estimates of the nrnpower required; a des-cription of the interactions with other NRC offices, the Advisory Committee on

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Reactor Safeguard and outside organizations; estimates of funding required for contractor-supplied technical assistance; pr'ospective dates for completing 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-r.er. ation status of each unresolved safety issue for which technical resolution is c.plete.

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