ML20138D242

Forwards CY92 Rept on Changes to Operating Npps,Imposed by Commission or Staff,Per Directions Issued in House Appropriations Committee Rept 99-195

ML20138D242
Person / Time
Issue date:	02/03/1993
From:	Selin I, The Chairman NRC COMMISSION (OCM)
To:	Bevill T HOUSE OF REP., APPROPRIATIONS
References
NUDOCS 9302160264
Download: ML20138D242 (13)

Text

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8 UNITED STATES ic\)pq)/k

.x- c i NUCLEAR REGULATORY COMMISSION t - WASHINGTON D.C. 20SE February 3, 1993 CAR AN The Honorable Tom Bevill, Chairman Subcommittee on Energy and Water Development Committee on Appropriations-United States House of Representatives Washington, D.C. 20515 '

Dear Mr. Chairman:

In accordance with the directions issued in House Appropriations Committee Report 99-195, I am onclosing the Nuclear Regulatory Commission's report for calendar year 1992 on changes to operating nuclear power plants' that were imposed by the Commission or its staff. The report covers changes to the systems, structures, components, procedures, organization, or design of operating power plants.

Sincerely,.

'^'l Ivan Selin i

Enclosure:

.As stated cc: Rep. John T. Myers 120041 l

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9 Enclosure REPORT ON CHANGES THE NUCLEAR REGULATORY COMMISSION IMPOSED ON SYSTEMS. STRUCTURES. COMPONENT

S. PROCEDURE

S. ORGANIZATION.

OR DESIGN OF OPERATING NUCLEAR POWER PLANTS

1. PURPOSE The U.S. Nuclear Regulatory Commission (NRC) is submitting this report-to advise Congress of changes the NRC imposed on operating nuclear power plants during calendar year (CY) 1992.

2. BACKGROUND-The NRC staff reviewed bulletins, generic letters, final rules, regulatory guides, policy statements, the plant-specific backfit tracking system, and orders to determine which changes the NRC imposed in CY 1992 on systems, structures, components, pr_ocedures, organization, or design of operating nuclear power plants. The NRC imposed these changes by issuing documents a licensee is required to follow, such as regulations and orders, and documents that contain rac.ommendations for action, such as bulletins, regulator; guides, generic :etters, and policy statements. Licensees general:y choose to follor such recommendations. However, if such a rtcommendation is not followed and the_ NRC has evidence that the public health and safety uuld be' better-protected if it was followed, this agency would__need ta further establish the recommendation as an NRC requiree. cat haposed- on 1icensees.

3. BULLETINS During CY 1992, the staff issued one bulletin, a supplement to thatl bulletin, and a supplement to a previously issued-bulletin. These-documents were issued pursuant to Section 50.54(f) of Title 10 of. the C.oie g p_{ Federal Reaulations (10 CFR 50.54(f)), which implements the provisions of Section 182a of the Atomic Eneray Act of 1954, as_ amended.

These documents are summarized below.

In Bulletin 92-01, " Failure of Thermo-Lag 330 Fire-Barrier System to Maintain Cabling in' Wide Cable Trays and Small Conduits Free from Fire Damage," the NRC requested that licensees submit-to the NRC written notification of whether Thermo-Lag 330 fire barrier systems were installed in their_ facilities. For those licensees who had Thermo-Lag fire barrier material installed.in their-facilities, the NRC asked the licensee to (1) identify the locations in which the material was

' installed, (2) implement, in accordance with plant procedures, the appropriate compensatory measures, such as fire watches, and (3) submit-written notification to the NRC stating whether the above. compensatory actions had been implemented and describing measures being taken to restore the fire barriers to operability.

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Supplement l' to Bulletin' 92-01 expanded the_ scope of the bulletin to include nearly all sizes and shapes of-Thermo-Lag:330-1. fire barrier material.

The staff determined that the actions requested in Bulletin.92-01 -and .

its supplement were compliance backfits in:accordance with 10 CFR 50.109(a)(4) because-these actions were considered necessary to ensure compliance with existing requirements and did not-represent new staff positions Therefore, the staff did'not-estimate the cost..to' industry.

I The staff-issued Supplement 'l tol Bulletin 90-01, " Loss of Fill-Oll in--

Transmitters Manufactured by Rosemount,".to inform recipients of additional evaluations of Rosemount transmitters and to request;that:

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licensees take certain' actions to resolve the issue. The staff asked > '

licensees to identify any transmitters that could be affected and thatL are used in, or may be used in, safety-related systems. . Further, the.

staff requested that licensees expeditiously _ replace _ the transmitters = or- ~

institute. a rigorous program to monitor _ the performance of the

' transmitters to ensure their continued satisfactory performance. The~

staff' determined that the actions requested in' the supplement -

represented a new staff position and were,'in accordance with NRC ~

procedures,.a backfit to bring facilities,into' compliance with existing

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g requirements. Therefore, the staff performed an evaluation as required -

in 10 CFR 50.109(a)(6). The staff estimated that the industry would-need- to spend approximately 517 million to $34'million to replacez all transmitters that could be affected, or from $200,000 to $2 million to -

implement rigorous monitoring-programs. -

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4. GENERIC LETTERS During-CY'1992,'the staff issued:14.new generic letters.and supplementsi - ,

to generic letters issued .in- previous _ years..- In one generic letter, the -

staff encouraged licensees to participate.in a voluntary pilot program-to assess the advantages and disadvantages of compiling the current- '

. licensing basis. Although no response'was required, the: staff estimated that 10 person-hours would:be needed for each voluntary response. -In '

f' nine of these documents, the staff provided useful?information or:

E clarified previous generic letters without imposing-new requirements or increasing the burden on licensees. In three other generic letters and

.one supplement to a previously issued generic letter, the staff:

requested that licensees submit information pursuant to 10 CFR 50.54(f). ~

The three generic letters and the supplement-are summarized below.

In GL 92-01, Revision 1, " Reactor Vessel Structural Integrity," the staff requested information in order to assess each licensee's-1 compliance with requirements and. commitments for- reactor vessel-integrity as: delineated in 10 CFR 50.60(a) and '10 CFR' 50.61. - Section a 50.60(a) .of 10 CFR requires that licensees for light water nuclear power E reactors meet fracture toughness requirements and have a material L

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surveillance program for the reactor _ coolant pressure boundary.

Section 50.61 of 10 CFR contains fracture toughness requirements for protecting pressurized water reactors against pressurized thermal shock events. The generic letter was not considered a backfit since no new staff positions were established. Because the information was requested -

in order to verify compliance with existing requirements,. the staff did not estimate the cost for complying with this generic letter.

In GL 92-04, " Resolution of the Issues Related to Reactor Vessel Water level Instrumentation in BWRs," the staff requested information about:

the adequacy of and the corrective actions for boiling water reactor (BWR) water level instrumentation concerning the effects of noncondensable gases on system operation. As discussed in NRC Information Notice 92-54, " Level Instrumentation -Inaccuracies Caused by' Rapid Depressurization," the staff expressed concern that noncondensable.

gases may become dissolved in the reference leg of- BWR water level-instrumentation and, during a rapid depressurization event, lead to a false high level indication. In the generic letter, the staff provided its evaluation of analyses and design-basis' scenarios prepared by the BWR Owners Group and its consultant, General Electric. The staff concluded that interim plant operation was acceptable but requested licensees to address the effects of inaccurate vessel level indications that may result from a rapid depressurization. The licensees were to-address (1) the effect on automatic safety system response during licensing-basis transients and accidents,- (2) the effect on the operator's short- and long-term actions during licensing-basi; transients and accidents, and (3) the effect on the operator's ~ actions prescribed in emergency operating procedures or other affected .

procedures. The staff asked each licensee to notify the NRC of short-term actions taken to address the issue and submit plans and schedule for long-term corrective actions.. Because the staff determined that the actions requested constituted a backfit to-ensure facilities are in compliance with existing requirements, it did not estimate the cost of implementing the generic letter. However, the staff estimated that-licensees would need to spend 200 person-hours to prepare each response.

In GL 92-08, "Thermo-Lag 330-1 Fire Barriers," _ the staff requested detailed information regarding the use and qualification of Thermo-Lag 330-1 fire barrier systems to verify compliance with NRC requirements.

The staff asked each addressee to report whether Thermo-Lag 330-1 fire barriers are relied upon to meet the requirements of 10 CFR 50.48 (fire protection), to achieve physical independence of electrical systems, to meet a condition of the plant's_ licensing' basis, or to satisfy a-licensing commitment. If the barriers are relied upon to meet any of these conditions, the staff asked licensees to state whether (1) the-barriers are qualified by appropriate tests, (2) the as-installed configurations are qualified under the tests and any deviations from tested configurations have been properly evaluated, and (3) the as-built configurations are consistent with those used during ampacity derating tests and the test results are correct and apply to the plant design.

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If the licensee responded negatively to any.of these requests, the staff requested it to (1), describe the corrective actions needed and submit a schedule of their implementation, (2) describe compensatory measures taken to meet technical specifications and administrative controls, and (3) notify the NRC when such actions were complete. The information requested was necessary to verify licensees' compliance'with their current licensing bases. Therefore, in accordance with 10 CFR-50.109(a)(4), the staff determined that the request was a backfit to-ensure facilities are in compliance with existing requirements and did not estimate the cost to industry of any procedural. or-hardware changes-that may result from taking.the actions requested in the generic letter.

The staff estimated that each licensee would need to spend 300 person-hours to prepare each response.

In Supplement 1 to GL 87-02, " Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46," the staff transmitted Supplemental Safety .

Evaluation Report 2 (SSER 2). The SSER documented the staff's evaluation of Generic Implementation Procedure (GIP), Revision 2, which' was a generic schedule submitted by. the Seismic- Qualification Users Group (SQUG) for taking actions to resolve USI A-46. In the stpplement, the staff asked licensees to submit (1) a statement committir , totuse the SQUG commitments and the implementation guidance in the GIP for resolving USI A-46 or give an acceptable alternativ9 response to GL 87-02, (2) a plant-specific schedule for implementing the.GIF guidance and a report summarizing the results of the USI A-46 review, and (3) detailed information on the procedures and criteria.used to generate the in-structure response spectra for USI A-46. The staff concluded that the request was a backfit under 10 CFR 50.109(a)(4). :Therefore, the staff performed a backfit analysis and determined the backfit was-justified by the benefits to be derived from implementing the program.

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The staff also. determined that no new. costs were added to the program that had not been previously addressed in GL 87-0?'and reviewed by the Committee to Review Generic Requirements.

5. FINAL RULES In CY 1992, the NRC published 28 rules in final form, some of which reduced regulatory burden. Nine resulted in changes to systems, structures, components, procedures, organization, or design of operating nuclear power plants. The rules are summarized below.

On January 31,1992,. the NRC amended its regulations to require a reinvestigation program for NRC licensee personnel' with "Q" or "L" access authorizations and to amend the fee schedule to recover investigative costs. This rulemaking applies only to a very few operating nuclear power plants with very few personnel whose access authorizations were granted 5 or more years ago. The NRC determined that the backfit rule of 10 CFR 50.109(a)(1) applied because the

5 rulemaking is within the criteria, but a backfit analysis was not required because this final rule qualifies for exemption under 10 CFR 50.109(a)(4)(iii). The estimated costs of the reinvestigations range from $45 to $3,000.

On August 6,1992, the NRC published an amendment to its regulations to incorporate by reference the 1986 Addenda, 1987 Addenda, 1988 Addenda, and 1989 Edition of Section III, Olvision 1, of the American Society of Mechanical Engineers Boiler and Pressure Ves:el Code (ASME Code), and the 1986 Addenda, 1987 Addenda, 1988 Addenda, and 1989 Edition of Section XI, Division 1, of the ASME Code. The staff estimated 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br /> for each response as the public reporting burden for this collection of information. The ASME Code addenda and editions incorporated by reference contain updated rules for constructing components of light-water-cooled nuclear power plants and for conducting in-service inspection and testing of those components. The final rule imposes an augmented examination of reactor vessel shell welds and separates the requirements for in-service testing from those for in-service inspection by placing the requirements for in-service testing in a separate paragraph. The incorporation by reference into the regulations of later editions and addenda of Section 111 and Section XI of the ASME Code is not a backfit because Section III requirements apply only to new construction and because Section XI requirements are an integral part 'of the longstanding requirement to update in-service inspection and testing programs to reflect the requirements of the latest edition and addenda.

The Connission completed a backfit analysis in accordance with 10 CFR 50.109(a)(3) and concluded that imposing augmented reactor vessel examination will result in a substantial increase in the protection of the public health and safety and thus justifies the direct and indirect costs of implementation. The estimated cost of the augmented examination for each plant depends on the type of reactor, the reactor vessel examinations previously scheduled for the inspection interval,

• the time remaining in that inspection interval, and the indirect costs associated with the examination. Taking all these variables into account, the estimated total incremental cost for the industry to conduct the augmented examination of the reactor vessel shell welds is approximately $77.95 million.

On August 31, 1992, the NRC amended its regulations to reduce the regulatory burden on licensees. Six of the eight amendments affect nuclear power plant licensees. The NRC estimated that this collection of information would reduce the public reporting burden by an average of 208 hours0.00241 days <br />0.0578 hours <br />3.439153e-4 weeks <br />7.9144e-5 months <br /> for each response for operating power reactors. The NRC determined that the backfit rule does _not apply to this final rule and, therefore, a backfit analysis was not required. The amendments are summarized below.

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1. . The NRC reduced the requirements from semi-annual to annual for-submitting reports 'on the quantity of principal nuclide released to unrestricted areas in -liquid and gaseous effluents (10 CFR 50.36a).

The NRC estimated that this action,-assuming an' average remaining plant life of 26 years, would save the licensees $16.8 million and would save the NRC $360,000.

2. The NRC revised the acceptance criteria for evaluations of emergency core cooling systems and combustible gas control applicable to zircaloy-clad fuel to include ZIRLO-clad fuel l (10 CFR 50.44, 50.46, and Appendix K to Part 50). The NRC estimated that eliminating the need to process recurring exemptions to the regulations would save licensees $2 million and would save the NRC

$50,000. This estimate is based on six plants each year requesting.

to use ZIRLO-clad fuel over the next 8 years.

3. Tis NRC added an option from the current requirements for annuall; updating the Final Safety Analysis Report (FSAR). .

i Licensees may choose to_ submit the required information once each refueling outage if the interval between ' updates does'not exceed 24 months. The NRC estimated that, assuming an average remaining 1 plant life of 26 years, this action would save licensees $11.1 million and-would save the NRC $910,000.

4. The Commis:: ion revised the requirements for the annual submittal of reports for facility changes under 10 CFR 50.59 to conform'with  !

the proposed change for updating the FSAR as described above.

Instead of submitting the information annually, the licensee may submit the information once each refueling cycle if the interval- ,

between reports does not exceed 24 months. The'NRC estimated-that, '

assuming an average remaining plant' life of 26 years, this action - ,

would save licensees $1.5 million and would save the NRC $400,000.

5. The Commission addressed the elimination of unnecessary event j reports in a separate rulemaking discussed below. j

6. The NRC addressed the receipt back of processed low-level waste in a separate rulemaking discussed below.

On September 10, 1992, the NRC amended its regulations to make minor modifications to the current reporting requirements for events at nuclear power reactors. The final rule applies to all nuclear power reactor licensees and deletes reporting requirements for three categories of events that have been determined to be of little or no safety significance. The final rule reduces the industry's . reporting - ',

burden and the NRC's response burden for reviewing and assessing events.

The NRC estimated that the thanges to the existing rules will reduce the number of licensee event reports each year by about 150, which is about 5-10 percent of the current annual average. The NRC expects a similar reduction in the number of prompt event notifications. The resulting reduction in burden is estimated to average 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> for each licensee

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7 response. These changes neither impose additional reporting requirements nor require modifications to the facilities or their licenses. Therefore, this final rule did not constitute a backfit, and a backfit analysis was not required.

On October 21, 1992, the NRC published an amendment to its regulations governing the condition of licenses for production and utilization facilities to allow a reactor licensee to receive back byproduct and special nuclear material produced during reactor operations after that' material has been sent off-site for processing, such as compaction or incineration. The NRC took this action to give licensees adequate short-term on-site storage capacity for low-level waste until permanent disposal is available. The Commission does. not look favorably on long-term storage at the reactor site. The Commission has determined that-the backfit rule does not apply to this final rule, and therefore, a backfit analysis was not required. The final "egulation will not impose any additional cost or burden on a licensee or other individuals.

On November 25, 1992, the NRC amended its information collection requirements for fitness-for-duty programs, which require the reporting of test results by process stage and management actions on appeals and their resolutions. The NRC estimated that this rule will reduce the-public reporting burden to each affected licensee by an average of 17.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> for each response.

On December 7, 1992, the NRC amended its regulations to permit on-site incineration of contaminated waste oils generated at licensed nuclear power plants without amending existing operating licenses. This action will ensure that the limited capacity of low-level waste disposal-facilities is used more efficiently while maintaining releases from operating nuclear power plants at levels which are as low as reasonably '

achievable and V11 provide a more cost- and risk-effective means of disposing of waste oil. The Commission hat determined that the backfit rule does not apply to this final rule, and therefore, a. backfit analysis was not required.

On December 8, 1992, the NRC amended its regulations, effective ,

immediately, to correct errors in the text-of the revised standards for protection against radiation, to conform portions of the regulatory text to the Commission's decision to defer mandatory implementation of the revised standards until 1994, and to reflect the recent' 0MB approval of the use of HRC Forms 4 and 5. The-NRC has determined that the backfit rule,10 CFR 50.109, does not apply to this final rule, and therefore, that a backfit analysis is not required for this final. rule.

On December 29, 1992, the NRC amended its regulations, effective March 1,1993, to provide for the exclusion of counsel from a subpoenaed interview when that counsel represents multiple ~ interests in the investigation and there is concrete evidence that the counsel's presence .

at the interview would obstruct and impede the investigation. These amendments are designed to ensure the integrity and efficacy of the investigative and inspection process. These amendments provide a

8 standard and procedures for making and effectuating the decision.to exclude counsel. The NRC has-determined that the backfit rule, 10 CFR-50.109, does not apply to these amendments and that a backfit analysis -

is not required.

6. REGULATORY GUIDES The NRC does not issue regulatory guides to impose changes on licensees.

The guides are intended to present and explain methods which the NRC would find acceptable to meet regulatory requirements or comitments.

In CY 1992, the NRC -issued 10 regulatory guides, 9 of which applied to commercial nuclear power plants.

In Regulatory Guide (RG) 1.101, Revision 3, " Emergency Planning and Preparedness for Nuclear Power Reactors," the NRC issued guidance on acceptable methods for complying with the Commission's regulations for emergency response plans and preparedness at nuclear power reactors, In RG 1.84, Revision 28, " Design' and Fabrication Code Case Acceptability, ASME Section III,- Division 1," and RG 1.85, Revision 28,

" Materials Code Case Acceptability, ASME Section III, Division 1," the NRC listed those code cases that are generally acceptable to the NRC staff for implementation in the licensing of light-water-cooled nuclear power plants. In RG 1.147, Revision 9, " Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1," the NRC listed those code cases that are generally acceptable to the NRC staff for implementation in the in-service inspection of light-water-cooled nuclear power plants.

The staff periodically revises these three guides'to update ^the listings of acceptable code cases and to include the results-of public coment and the staff's additional review.

In RG 8.25, Revision 1, " Air Sampling in the Workplace," the NRC gives guidance on air sampling in restricted areas (as defined -in 10 CFR-Part 20) of the workplace. In this-guide, the term " air sampling" includes the collection of samples for later analysis as well as real-time monitoring in which samples are analyzed as they are collected.

The guide does not cover environmental or effluent sampling or the analysis of samples.

In RG 8.34, " Monitoring Criteria and Methods to Calculate Occupational Radiation Doses," the NRC issued criteria acceptable to the staff that licensees may use to determine when monitoring is required. The guide also describes methods acceptable to the NRC staff for calculating j occupational radiation doses when the intake is known, i

! In RG 8.35, " Planned Spec', .1 Exposures," the NRC issued guidance on the L conditions and prerequisites for permitting planned special exposures

! allowed by the revision to 10 CFR Part 20, " Standards for Protection Against Radiation," on the asLciated specific monitoring and reporting requirements, and gave examples of acceptable means of satisfying these requirements.

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In RG 8.36, " Radiation Dose to the Embryo / Fetus." the NRC issued '

guidance on methods acceptable to the NRC staff for calculating radiation dose to an embryo / fetus.

In RG 8.7, kevision 1, " instructions for Recording and Renorting-Occupational Radiation Exposure Data," the NRC describes an acceptable program for the preparation, retention, and reporting of records of occupational radiation exposures. The guide also includes copies of NRC Forms 4 and 5 and giver detailed instructions on completing them. 3

7. POLICY STATEMENTS In CY 1992, .ne NRC issued seven policy statements. None of the policy -

statements required licensees to make changes to the systems, structures, components,. or the design of operating nuclear power' plants or the procedures and organization required to operate them. However, one policy statement encouraged licensus to take action. The policy statement on " Availability and Adequacy of Design Bases Information at Nuclear Power Plants," issued on August 10, 1992, described the Commission's expectations and future actions with regard to the availability of design information. The Commission stated that all power reactor licensees should assess the accessibility and adequacy of their design-bases documentation and should use the findings of that assessment to form the basis for a licensee's decision en whether a design reconstitution program'is necessary and the attributes to be included in the program.

PLANT-SPECIFIC BACXFIT TRACKING SYSTEM During CY 1992, the NRC imposed one plant-specific backfit. A plant-specific backfit is a modification or addition the NRC requires or recommends to systems, structures, components, or design of a specific a single facility or the procedures required to design, construct, or .,

operate that facility. Supplement I to NUREG-0737 specifies thtt facilities shall have as a goal emergency activation times of generally 60 minutes for their Technical Support Center (TSC) and Emergency Operations Facility (EOF). The Joseph M. Farley Nuclear Plant, Units 1 and 2, had an emergency plan that allowed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to staff the TSC and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to staff the EOF. After meeting with the licensee several times, the licensee, on August 31, 1992, submitted its commitment to revise the emergency plan and resolve the staff's concerns. Therefore, the staff did not complete the backfit analysis an6 a cost estimate is .

i not available.

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9. ORDERS In CY 1992, the NRC issued three orders. Two were 1 sued to Northeast Nuclear Energy Company and approved the transfer of ownership interests in Hillstone Nuclear Power Station, Unit 3. In t.pril 1992, the NRC issued an order approving the transfer of control of 0.217 percent of the Hillstone Unit No. 3 ownership from Fitchtmrg Gas and Electric Light Company to UNITIL Corporation, a holding company. The merger of--

Fitchburg and UNITIL was completed on' April 28. 1992. In May 1992, the

- NRC issued an order approving the transfer of r 2-8475 percent ownership in Hillstone Unit No. 3 from Public Service Couany of New Hampshire (PSNH), an independent company, to PSNH, whol y owned subsidiary of Northeast Utilities (NU). The merger Set:,een PJNH and NU was completed-on June 5, 1992.

In May 1992, the NRC approved the transfer of ownership and of management authority of Seabrook Station from PShH to two wholly-owned subsidiaries of NU. The NRC issued a license amendment for each transfer and an order approving the transfers.

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