ML20055A296

Forwards Status Evaluation of Unresolved Safety Issues for SEP Integrated Assessment Program.Current Info Re Implementation of Hardware & Procedures Requested

ML20055A296
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	07/13/1982
From:	Lainas G Office of Nuclear Reactor Regulation
To:	Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8207160096
Download: ML20055A296 (10)

Text

-

o n

c;..

x Distribution Docket File

• July 13, 1982 Local PDR ORB Reading NRC PDR NSGC Docket No. 50-155 D. Critchfield H. Smith R. Emch Mr. David J. VandeWalle OELD Nuclear Licensing Administrator OI&E Consumers Powar Company ACRS (10) 1945 West Parnall Road SEgg Jackson, Michigan 49201

SUBJECT:

UNRESOLVED SAFETY ISSUES STATUS FOR THE BIG ROCK POINT PLANT The staff's safety evaluation report tegarding t he SEP Integrated Assessment Program (IAP) for the Big Rock Point 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 items at Big Rock Point, 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 550.54(f) of 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 Big Rock; (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 peration 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.L.96-511.

Sincerely, Original Signed By Cus C. Lainas, Assistant Director for Scfety Assessment Division of Licensing cc: See next page

[M[

8207160096 820713 g ggg gg (j DR ADOCK 05000 omct > -DLtenBas.,..

.DL

.AD. }...

..... ~. - -.

..... ~ ~ ~..

. ~ ~.. -..... -

.u-

>... RE,mc,h,f l, DC,,,,,,,g,, ie,1d,,G afnas,,,,

? O 82

..G t.Q.82....'\\. 4%2..

om>

....... -... ~ ~

sac ronu ais oow nscu cm OFFICIAL RECORD COPY usceo mi-mem

l

, July 13, 1982 Mr. David J. VandeWalle 4

cc Mr.. Paul A. Perry, Secretary U. S. Environmental Protection Co~nsumers Power Company Agency

~

212 West Michigan Avenue Federal Activities Branch Jackson, Michigan 49201 Region V Office ATTN:

Regional Radiation Representative Judd L. Bacon, Esquire 230 South Dearborn Street Consumers Power Company Chicago, Illinois 60604-212 West Michigan Avenue

" Jackson, Michigan 49201 Peter B. Bloch, Chairman Atomic Safety and Licensing Board Joseph Gallo, Esquire U. S. Nuclear Regulatory Commission Isham, Lincoln & Beale Washington, D. C.

20555 1120 Connecticut Avenue i

Room 325 Dr. Oscar H. Paris Washington, D. C.

20036 A,tomic Safety and Licensing Board U. S, Nuclear Regulatory Commission Peter W. Steketee, Esquire Washington, D. C.

20555 505 Peoples Building Grand Rapids, Michigan 49503 Mr. Frederick J. Shon Atomic Safety and Licensing Board

. Alan S. Rosenthal, Esq., Chairman U. S. NGclear Regulatory Commission

-~~

Atomic Safety & Licensing Appeal Board Washington, D. C.

20555 U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Aig Roek Point Nuclear Power Plant ATTN: ~gs.. C. J. Hartman

.r-Mr. John O'Neill, II FTant Superintendent Route 2, Box 44 Charlevoix, Michigan 49720 Maple City, Michigan 49664

_f Christa-Maria

~~' MF. Jim E. Mills-Routb 2, Box 108C i

Route.2, Box 108C Cha'rlevoix, Michigan -49720 Charlevoix, Michigan 49720 William J. Scanlon, Esquire 2034 Pauline Boulevard l

Chairman County Board of Supervisors Ann Arbor, Michigan 48103 Charlevoix County Charlevoix, Michigan 49720 Resident Inspector CE Big Rock Point Plant

~'

' 0'f f'ics lof the Governor (2) c/o U.S. NRC Room 1 - Capitol Building RR #3, Box 600

,. Lansing, Michigan 48913 Charlevoix, Michigan 49720

" Herbert Semmel Hurst & Hanson

'~

Counsel for Christa Maria, et al.

311 1/2 E. Mitchell Urban Law Institute Petoskey, Michigan 49770 Antioch School of Law 2633 16th Street, NW Washington, D. C.

20460

ENCL.0.SURE 1

~

{,,

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

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

e Reactor Safeguards safety reviews; and vendor, architect / engineer;.and

~

utility design reviews.

Each time a new concern or safety issue is identified 7

from one or more of these sources,tNe Meed Tor-irrifnediate ac: tion to ensure safe

• N-operation is assessed.

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

.~n -

-iniplications of the -issue.

~

o..

1 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'fsrTher study,of the issue before '

licensing decisions are made.- In mos4 cases,~the initial assessment ihdicates that immediate liceTisihg actions or chaMe~s in licensing criteria are hot necessary.

In any event, furth'er study may bii 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

".I.

~

~

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 issues" (NUREG-0410, "t4RC Program for the Resolution of Generic Issues Related to Nuclear Power Plants," dated Jan'uafy 1,~1978).

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

TheDecisionwasissuedonNovember23,197i 6

0. W : -..

{

~

N N:

U 7

(ALAB-444) in connection with the Appeal Board's considerction 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 responsibilities of a licensing board in the radi'ological health ar.d 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 " Interested State" with, the required degree of specificity.

To the contrary, irrespective of what matters may cr may nottave been

~-,

properly placed in controversy, prior to authorizing the issuance of a construction permit the board must make the finding, inter alia,

~~

~ ~, ~.

that there is " reasonable assuiance*'tha(."the proposed f acility can -

-1.

br constructed and operated at, the prop.ose-d, location.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 _

~

staff revi.ew satisf.Lctorily has come to. grips.>dth 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 abirto look to that document to ascertain the extent to which genevic unresolved safety problems.

which have been previously identified i~n an 7SAR item, a Task Action Plan, an ACRS report or elsewhere hdve' teen factored into the ~ 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 rete-vance to facilities of the type under review and potentially 'signifi-cant public safety implications.

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 Tor-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

~

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 considerations as whether:

2

(.

. (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

rtinuec coeration (if permitted at all) would not pose an undue

-isk to tne 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 appilied to

[-

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

}

Nuclear Powbr Station Unit Nos. T-and 2),' hlAB-491-8 NRC245 '('1978).

~

L_

in a related matter, as a result of CongressionaP a'ct[on on the Nuclear

~

7egulatory Commission budget for Fiscal Year 1978, the Energy Re~ organization' act 5f 1974. was amended (PL 95-209) on December 13, 1977 to include, among other things, a new Section 210 as follows:

UNRESOLVED SAEETT IS5UES PLAN

-w SEC. '10.

The Commission shall develop ( 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 the Fiscal Year 1978 Appropriations Bill (Bill S.1131) provided the following additional information regarding the Committee's deliberations on this portion of the bill:

SECTION 3 - UNRESOLVED SAFETY ISSUES 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 c'n or before January 1, 1978.

The conferees also expressed the intent that this plan should identify and describe those safety issues', relating'to nuclear power reactors, which are unresolved on the date of enactment.

It should set forth:

3

. -[

u.

g,-.. _

=

(1) Commission actions taken dir:ctly or indirectly to dsvelcp 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.

In response to the reporting requirements of the new Section 210, the NRC staff submitted to Congress on January 1, 1978, a report, NUREG-0410, entitTed "NRC Program for the Resolution of Generic Issues Related -to Nucibar' Power Plants,."-

describing the NRC generic issues-program.

The NRC program was already in

]

. place when PL 95-209 w'as enacted and is~of co_nstderably broader scope' than the Y-

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

initting NUREG-0410 to the Congress on December 30, 1977, NRC indicated that'-

~~

"the progress -ceports, which are requir'ed by Section 210 to be included in

~

future NRC annual reports, may be more useiul, to Congress if they focus on the specific Section 210 safety items."

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

~

were developed and implemented on issue (s..with poten'tially significant l ublic i

safety implications? In 1978, the NRC YnMrtook a. review of more than'130 generic issues a'ddressed in the.N' C pro' gram to d'etermine which issues fit this R

,e description and qualify as unresolved safety issues for reporting to the

~'

Congress.

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

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

The report pro'v' ides the following definition of an unresolved safety issue.

An Unresolved Safety Issue is a matter 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

[

~.'

Q

(

'~

public health and safety or (2) provide a potsntially significan2 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.

411 of the issues addr:ssed in the NRC program were systematically evaluated against this definition as described in. NUREG-0510.

The issues are listed bel ow.

Progress on these issues was first discussed *in the '197'8.NRC ~ Annual : I

~-

Report.

The number (s) of the generic task (s) (e.g., A-1).in..the.NRC pro' gram 4

m.

addressing each issue is indicated in parentheses 'following the title.

~

~

=

UNRESOLVED SAFETY ISSUES (APPLICABLE TASK NOS.)

~

fl) Waterhammer -- (A-1)

[

N/A (2) BWR MARK I Pressure Suppression Containments - (A-6, A-7, and A-39)

(3)

Anticipatsd Transients Without Scram (A-9)

(4)

BWR No=zle Cracking - (A-10)

(5) Reactor Vessel Materials Toughness (A-11)

(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)

(9)

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

(10)

Seisede Design Criteria (A-40)

(11)

Pipe Cracks at Boiling Water Reacters (A-42)

(12)

Containment Emergency Sump Reliability (A-43)

(13)

Station Blackout (A-44)

~

~

(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 o'f Hydrogen Burns on Safety Equipment (A-48)

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

~

~

-- ~~~

~

NRC ctnff'c propond resoluticn of Eight cafsty icau:=

~

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

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

A-9 NUREG-0460, V0'L. 4, " Anticipated Iransients-Without Scram 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 BTP 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 d649, " 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 staff's proposal for rulemaking on this issue. 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 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 Committee on

~

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.

~

6

(

(_

In. addition to the Task Action Plans, the staff issues the " Office of Nuclear

' Reactor Regulation Unresolved Safety Issues Summary, Aqua Book" (NUREG-0506) on a quarterly basis, which provides current schedule information for each of the unresolved safety issues.

It also includes information relative to the imple-T.er ation status of each ur. resolved safety issue for which technical resolution is compiete.

ee O

us'pMM#

G WW*

h M

y

=

g ep m

• = =

6 Y

..g.

• • w g'

gto*

e ee e

6 e

en 7

~__

. proposed site near Sedro Woolley in eastern Washington.

I The name of the project was changed to the Skagit/Hanford Nuclear Project (S/HNP), Units 1 and 2.

This Supplement No. 3 reports the results of the staff's review of Amendments 45,_EO, 21,23, 24 and 25 that incorporated changes to the Preliminary Safety Analysis Report (PSAR)

~

associated with the relocation.

Amendment 22 to the PSAR incorporated changes relatedtotheTMI-2frequirements which were addressed by the staff in Supplement No. 2 to the Safety Evaluation Report.

In Supplement No. 1 the staff reported that it had not completed its review of the geological and seismological aspects of the proposed Skagit Nuclea r Power Project,

~

Units 1 and 2.

Followino the change of location, the

~

staff discontinued its review of the geological and seismological aspects of the project for the original location.

A disagreement between the staff and the applicants was

$;tef d e s c r i b e d 'i n S e c t i o n 6=4@ of Supplement No. 1 to the Safety Evaluation Report.

The staff's position continues to be that it will recommend that the construction permits be conditioned to require the installation of a loose parts monitoring system, the details of which will be required to be submitted at the operating License stage of review.