ML20148S762
| ML20148S762 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/30/1997 |
| From: | Mckee P NRC (Affiliation Not Assigned) |
| To: | Lochbaum D UNION OF CONCERNED SCIENTISTS |
| References | |
| 50-245-97-01, 50-245-97-1, 50-336-97-01, 50-336-97-1, 50-423-97-01, 50-423-97-1, GL-31-18, NUDOCS 9707080301 | |
| Download: ML20148S762 (6) | |
See also: IR 05000245/1997001
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NUCLEAR REGULATORY OOMMISSION
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WASHINGTON, D.C. 20f36-0001
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June 30, 1997
..
David A. Lochbaum
1616 P Stre n NW., Suite 310
,
Washington, DC 20036-1495
Dear Mr. Lochbaum:
I am responding to your letter of May 9,1997, to Samuel J. Collins, Director,
Office of Nuclear Reactor Regulation, in which you requested that the U.S.
Nuclear Regulatory Commission (NRC) determine whether the Millstone Unit 1
licensee (Northeast Nuclear Energy Company) complied with 10 CFR 50.59 when
debris was left in the' spent fuel pool; and whether the Millstone Unit 1
licensee is currently conducting activities in the spent fuel pool in
accordance with General Design Criterion (GDC) 61 " Fuel Storage Handling and
Radioactivity Control." You based your questions on information you read in
NRC Combined Inspection Report 50-245/97-01, 50-336/97-01, 50-423/97-01 dated
April 11, 1997.
After discovering the debris in the spent fuel pool, the licensee performed an
operability determination (as recommended by the NRC staff in Generic Letter (GL) 91-18, "Information to Licensees Regarding Two NRC Inspection Manual
Sections on Resolution of Degraded and Nonconforming Conditions and
Operability"). Although not a regulatory requirement, the NRC staff's
GL 91-18 guidance provides an acceptable method for licensees to disposition
design basis discrepancies.
If an initial operability evaluation determines
,
that the subject system remains operable, facility operation may continue.
The licensee must then decide whether to restore the system to the condition
described in the design basis documents or operate in a manner different than
1
as described in the design basis documents.
If the licensee chooses the
former, the restoration must take place in a time frame commensurate with
,
safety.
If, instead, the licensee chooses the latter action, or not to
restore, then an evaluation must be performed, pursuant to 10 CFR 50.59, to
ensure an unreviewed safety question (USQ) is not involved.
In the case of Millstone Unit 1, the licensee's analyses determined that the
applicable spent fuel pool safety functions remained operable.
Since the
licensee determined the debris in the spent fuel pool would not be immediately
removed, a USQ analysis pursuant to 10 CFR 50.59 was performed.
The licensee
concluded there were no USQs due to the debris in the spent fuel pool. The
licensee's conclusion was based, in part, on a report supporting a 1988 spent
fuel pool rerack license amendment request that showed that an 80 percent
blockage of convection flow area would result in a maximum local temperature
increase of 11' F and that a substantial margin against local boiling existed.
Based on viewing a videotape of the debris, the licensee concluded that none
of the debris found in the spent fuel pool would result in a blockage of flow
area that is close to 80 percent of the total flow area.
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9707080301 970630
ADOCK 05000245
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NPaC FELE EBTEP COPY
-
David A. Lochbaum
-2-
Regarding the issue of compliance with GDC 61, the GDC (i.e.,10 CFR Part 50,
- Appehdix A) set forth general requirements for design of nuclear power
reactors.
Specifically, the GDC establish the principal design criteria for
establishing "the necessary design, fabrication, construction, testing, and
performance requirements for structures, systems, and components important to
safety." The specific design information used to meet the GDC then becomes
part of the plant's design basis as defined in 10 CFR 50.2.
Thus, licensees
indirectly ensure compliance with the GDC by operating their plant in
conformance with their design bases assumptions.
Additionally, licensees are
required to comply with Criterion XVI of Appendix B, to 10 CFR Part 50,
" Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing
Plants." This criterion states, in part, that "[m]easures shall be
established to assure that conditions adverse to quality, such as failures,
malfunctions, deficiencies, deviations, defective material and equipment, and
nonconformances are promptly identified and corrected." As previously noted,
the licensee did perform a GL 91-18 operability determination as recommended
by the staff and a USQ evaluation pursuant to 10 CFR 50.59. The licensee
concluded that its systems remained operable and the de facto change (i.e.,
the debris in the spent fuel pool) did not involve a USQ; therefore, they were
within their design bases.
The NRC staff has reviewed the licensee's analyses and spent fuel pool
videotape and concluded that there were no immediate safety concerns due to
the debris in the spent fuel pool. However, the staff considers the
acceptability of the degraded conditions in the spent fuel pool to be
unresolved pending completion of further NRC and licensee review of the issue.
Once these reviews have been completed, the staff will consider enforcement
action as appropriate. The staff's final resolution of this issue will be
included in a subsequent inspection report.
I trust this reply responds to your concerns.
If you have any further
questions on this matter please contact me at (301) 415-2240.
Sincerely,
Phillip F. McKee
Deputy Director for Licensing
Special Projects Office
Office of Nuclear Reactor Regulation
Docket No. 50-245
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David A. Lochbaum
-2-
June 30, 1997
i
Regarding the issue of ccmpliance with GDC 61, the GDC (i.e., 10 CFR Part 50,
!
, Appendix A) set forth general requirements for design of nuclear power
reactors.
Specifically, the GDC establish the principal design criteria for
!
establishing "the necessary design, fabrication, construction, testing, and
,
performance requirements for structures, systems, and components important to
!
safety." The specific design information used to meet the GDC then becomes
part of the plant's design basis as defined in 10 CFR 50.2.
Thus, licensees
!
indirectly ensure compliance with the GDC by operating their plant in
j
conformance with their design basis assumptions. Additionally, licensees are
required to comply with Criterion XVI of Appendix B, to 10 CFR Part 50,
!
" Quality Assurance Criteria for Nuclear. Power Plants and Fuel Reprocessing
j
Pl ants . " This criterion states, in part, that "[m]easures shall be
!
established to assure that conditions adverse to quality, such as failures,
{
malfunctions, deficiencies, deviations, defective material and equipment, and
-
i
nonconformances are promptly identified and corrected." Further, licensees
l
are required to comply with 10 CFR 50.72, "Immediate Notification Requirements
for Operating Nuclear Power Reactors," and 10 CFR 50.73, " Licensee Event
l'
Report System," which require certain actions if the licensee discovers a
i
condition that is outside the design basis of the plant. As previously noted,
!
the licensee did perform a GL 91-18 operability determination as recommended
by the staff and a USQ evaluation pursuant to 10 CFR 50.59. The licensee
i
concluded that its systems remained operable and the de facto change (i.e.,
!
the debris in the spent fuel pool) did not involve a USQ.
.
,
The NRC staff reviewed the licensee's analyses and spent fuel pool videotape
!
and concluded that there were no immediate safety concerns due to the debris
in the spent fuel pool. However, as noted in the inspection report, the staff
considers the acceptability of the degraded conditions in the spent fuel pool
i
to be unresolved pending completion of further NRC and licensee review of the
issue. Once its review has been completed, the staff will consider
enforcement action as appropriate. The staff's final resolution of this issue
j
will be included in a subsequent inspection report.
<
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j
I trust this reply responds to your concerns.
If you have any further
i
questions on this matter please contact me at (301) 415-2240.
,
Sincerely,
,
j
Original signed by:
1
Phillip F. McKee
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Deputy Director-for Licensing
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Special Projects Office
Office of. Nuclear Reactor Regulation
!
Docket No. 50-245
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DISTRIBUTION: See next page
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0FFICIAL RECORD COPY
Ta seceive a copy of thle sleeunient,insposte in the ben: *C* = Copy without ettechment/ enclosure
- E' = Copy with ettechment/ enclosure
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David A. Lochbaum
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Regarding the issue of compliance with GDC 61, the GDC (i.e., 10 CFR Part 50,
,
.
- Appendix A) set forth general requirements for design of nuclear power
reactors. Specifically, the GDC establish the principal design criteria for
establishing "the necessary design, fabrication, construction, testing, and
performance requirements for structurer, systems, and components important to
safety." The specific design information used to meet the GDC then becomes
part of the plant's design basis as defined in 10 CFR 50.2.
Thus, licensees
indirectly ensure compliance with the GDC by operating their plant in
1
conformance with their design basis assumptions. Additionally, licensees are
,
required _to comply with Criterion XVI of Appendix B, to 10 CFR Part 50,
-
!
" Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing
{
Plants." This criterion states, in part, that "[m]easures shall be
established to assure that conditions adverse to quality, such as failures,
'
malfunctions, de'ficiencies, deviations, defective material and equipment, and
nonconformances are promptly identified and corrected." Further, licensees
^
i
are required to comply with 10 CFR 50.72, "Immediate Notification Requirements
j
for Operating Nuclear Power Reactors," and 10 CFR 50.73, " Licensee. Event
,
Report System," which require certain actions if the licensee discovers a
t
condition that is outside the design basis of the plant. As previously noted,
)
'
the licensee did perform a GL 91-18 operability determination as recommended
by the staff and a USQ evaluation pursuant to 10 CFR 50.59.
The licensee
i
concluded that its systems remained operable and the de facto change (i.e.,
the debris in the spent fuel pool) did not involve a USQ.
.
The NRC staff reviewed the licensee's analyses and spent fuel pool videotape
1
)
and concluded that there were no immediate safety concerns due to the debris
4
in the spent fuel pool.
However, as noted in the inspection report, the staff
considers the -acceptability of the degraded conditions in the spent fuel pool
to be unresolved pending completion of further NRC and licensee review of the
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!.
issue. Once its review has been completed, the staff will consider
1
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enforcement action as appropriate.
The staff's final resolution of this issue
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will be included in a subsequent inspection report.
,
,
1
I trust this reply responds to your concerns.
If you have any further
!
questions on this matter please contact me at (301) 415-2240.
'
,
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Sincerely,
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Phillip f. McKee
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Deputy Director for. Licensing
Special Projects Office-
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FROM:
ORIGINAL DUE DT: 06/10/97
TICKET NO: 0970072
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NRR RCVD DATE: 05/13/97
-D. A. LOCHBAUM, UCS
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TO:
S. J. COLLINS
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APPARENT UNREVIEWED SAFETY QUESTION INVOLVING
COLLINS
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SPENT FUEL POOL STORAGE AT MILLSTONE UNIT 1
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UNION
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CONCERNED
SCIENTISTS
May 9,1997
Mr. Samuel J. Collins, Director
Office of Nuclear Reactor Regulation
United States Nuclear Regulatory Commission
Washington, DC 20555 0001
SUBJECT:
APPARENT UNREVIEWED SAFETY QUESTION INVOLVING SPENT FUEL
POOL STORAGE AT MILLSTONE UNIT 1
i
Dear Mr. Collins:
Section UI 02.1 in NRC Combined Inspection Report 50-245/97-01, 50-336-97-01, 50-423/97-01
dated April 11,1997, details a number discrepant conditions within tbc spent fuel pool at Millstone
Unit 1. According to this inspection report, foreign material exclusion problems allowed the
accumulation of a large amount of debris within the spent fuel pool. The debris was described as
" rope, cable, boron tubes, a broom head, filter hoses, nuts, and unidentifable objects." In addition, this
inspection report stated that "14 fuel bundles are elevated (from their seated position in the spent fuel
storage racks] due to unknown reasons, although it is suspected that debris is in the fuel rack
preventing proper seating."
Section 15.7.4," Radiological Consequences of Fuel Handling Accidents," of the NRC's Standard
Review Plan (NUREG-0800) and NRC Bulletin 96-02, " Movement of Heavy Loads Over Spent Fuel,
Over Fuel in the Reactor Core, or Over Safety-Related Equipment," describe limitations on the
movement of heavy loads over the spent fuel pool. The stated purpose of these limitations is to
prevent damage to irradiated fuel stored in the spent fuel pool to conform with the requirements of 10 CFR Part 50, Appendix A, General Design Criterion 61.
Section 50.59, " Changes, tests, and experiments," to 10 CFR requires all licensees to evaluate
proposed chaiges to their facilities for potential unreviewed safety questions. In essence, if a proposed
activity is not enveloped by the plant's licensing bases, it is an unreviewed safety question that
requires NRC review and approval before it can be performed.
The Millstone Unit 1 Updated Final Safety Analysis Report does not discuss the storage ofitems such
as " broom heads" in the spent fuel pool. If the licensee performed safety evaluations in accordance
with Section 50.59 of 10 CFR prior to placing these items in the spent fuel pool, then it is not
I
apparent why an unreviewed safety question was not identified. An object, such as a broom head or
filter hose, dropped into the spent fuel pool and blocking flow into or out of one or more irradiated
fuel assemblics would appear to constitute a new failure mode. Depending on the size of the object
and the number of blocked assemblies, the consequences from this postulated scenario could exceed
that from the previously analyzed fuel handling event at Millstone Unit 1. For example,if a panel
Washngton Offce: 1616 P Street NW Suite 310 Washhgton DC 20036-1495 202-332 0900 FAX: 202-332 0905
Cambridge Ofree: Two Brattle Square Cambridge MA 02238-9105 617-547-5552
FAX: 617-864-9405
Califomia Omce: 2397 Shattuck Avenue Suite 2o3 Berkeley CA 947041567 510-843-1872
FAX: 510-843-3785
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May 9,1997
Page 2 of 2
measuring 2'x4' fell into the pool and came to rest across the top of the racks, the flow from up to 18
irradiated fuel assemblies might be partially or full restricted. A similar scenario could be postulated
for a rag or a sheet of plastic that drops into the spent fuel pool and winds up blocking the inlet to
one or more irradiated fuel assemblies. Considering that Millstone Unit 1 is a boiling water reactor
with its irradiated fuel assemblies possibly having fuel channels that prevent cross-flow, any inlet or
outlet flow restriction has the potential for causing fuel damage from inadequate cooling. To our
knowledge, no analysis or evaluation has been performed to demonstrate the irradiated fuel can be
adequately cooled under restricted / blocked flow conditions.
If the licensee did not perform safety evaluations in accordance with Section 50.59 of 10 CFR prior to
placing these items in the spent fuel pool, then it is not apparent why the licensee seemed to have
,
violated the law.
UCS respectfully requests that the NRC determine:
1)
Whether the Millstone Unit I licensee complied with Section 50.59 of 10 CFR when items
such as broom heads were stored in the spent fuel pool.
2)
Whether the Millstone Unit I licensee is currently conducting activities in the spent fuel pool
in accordance with GDC 61.
Please note that the concern about objects lighter than a fuel bundle (i.e., items not covered under the
heavy load guidance in NUREG-0612) applies at least to all boiling water reactor plants that store
irradiated fuel assemblies with channels and perhaps to all plants to a lesser degree. Thus,it seems
prudent that the results frcm the recommended inquiry into this matter at Millstone be considered
generically as appropriate.
Sincerely,
k0
David A. Loch aum
Nuclear Safety Engineer
cc:
Chairman Shirley Ann Jackson
Commissioner Edward McGaffigan, Jr.
United Statn Nuclear Regulatory Commission United States Nuclear Regulatory Commission
Washington, DC 20555
Washington, DC 20555
Commissioner Kenneth C. Rogers
Mr. George Mulley
United States Nuclear Regulatory Commission United States Nuclear Regulatory Commission
Washington, DC 20555
Washington, DC 20555
Commissioner Greta J. Dieus
Mr. William D. Travers
United States Nuclear Regulatory Commission United States Nuclear Regulatory Commission
Washington, DC 20555
Washington, DC 20$55
Commissioner Nils J. Diaz
United States Nuclear Regulatory Commission
Washington, DC 20555
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