ML20150C365

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Forwards Rept for CY87 on All Changes to Sys,Components, Structures,Procedures,Organization or Design of Operating Plants Where Such Changes Imposed by Commission or Staff
ML20150C365
Person / Time
Issue date: 03/09/1988
From: Zech L
NRC COMMISSION (OCM)
To: Bevill T
HOUSE OF REP., APPROPRIATIONS
References
TASK-A-46, TASK-OR CCS, GL-87-02, GL-87-03, GL-87-2, GL-87-3, NUDOCS 8803180190
Download: ML20150C365 (15)


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UNITED STATES

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March 9, 1988 CHAIRMAN The Honorable Tom Bevill, Chainnan Subcommittee on Energy and Water Development Comittee on Appropriations United States House of Representatives Washington, D.C.

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Dear Mr. Chairman:

In accordance with the direction provided by House Appropriations Committee Report 99-195, I am enclosing a report for CY 1987 on all changes to systems, l

components, structures, procedures, organization, or design of operating plants j

where such changes are imposed by the Commission or its staff.

Sincerely, AV-Op.

LandoW.Zc,Jr.y 4

Enclosure:

As Stated cc: Rop. John Myers I

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Report on Changes to Systems, Components, Structures, Procedures, Organization or Design of Operating power Plants Imposed by NRC 1.

Purpose The purpore of this report is to advise Congress of any changes to operating power plants imposed by NRC during CY 1987,

===2.

Background===

Final rules, generic letters, bulletins, orders, policy statements, regulatory guides, and the plant specific backfit trackina system were reviawed in order to identify charges to systems, components, structures, procedures, organization, and design of operating reactors imposed by the NRC in CY 1987.

It should be recognized that the term "imposed" as used in thi', report is defined broadly to refer to those items which licensees are required to follow, as well as those items containing NRC recommendations (i.e., bulletins, regulatory guides, generic letters, and policy statements) which licensees generally follow, but which would require further NRC action to constitute a legal requirement imposed on the licensee,

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3.

Bulletins The staff issued two bulletins in CY 1987. Neither of these bulletins imposed new requirements which entailed changes to systems, components, structures, procedures, organization, or design at operating power plants.

4.

Generic letters The NRC issued sixteen generic letters in CY 1987. One of these did not 4

apply to operating power reactor licensees. Three requested licensees to submit certain information pursuant to 10 CFR 50.54(f); nine transmitted information related to new rules, policy statements, or NUREGs; and one i

requested schedule information for operator licensing exams. Two of these generic letters entailed changes to systems, components, structures, procedures, organization, or design at operating power plants and are summarized below.

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Generic Letter 87-02:

"Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Raactors" (USI A-46) reported that as a result of the technical resolution of USI A-46, Seismic Qualification of Equipment at Operating Plants, the NRC concluded that the seismic adequacy of certain equipment in operating nuclear power plants must be reviewed against criteria not in use when these plants were licensed.

Because affected plants were asked to carry out the evaluation against criteria not used to establish the design basis of the facility, this action was determined to be a backfit according to 10 CFR 50.109.

Generic Letter 87-03:

"Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors" (USI A-46) transmitted the same information to CP holders that GL 87-02 transmitted to licensees for operating reactors. The letter required that seismic adequacy of equip-ment in operating nue 'ar power plants not previously reviewed to current licensing requirements for seismic qualification must be reviewed to seismic criteria defined by the technical resolution of USI A-46.

The total cost for all plants affected by these two letters was estimated to be $58,800,000, 5.

Rules Nine amendments to Title 10 of the Code of Federal Regulations, Part 50 were published in final form in CY 1987. Three of these imposed changes to operating pcwer plant systems, components, structures, procedures, organization, or design at operating power plants.

An amendment to Part 50 (52 FR 16823) changes the timing requirements for a full participation emergency preparedness exercise for power reactors prior to NRC issuance of a full power operating license.

The rule change requires that the full participation exercise be held within two years prior to issuance of a full power operating license instead of one year.

This rule will result in a cost savings to the industry.

A second amendment to Part 50 (52 FR 41288) broadens the scope of a previous mcdification to GDC-4, allowing the removal of numerous pipe i

whip restraints and jet impingement barriers.

This change will also result in a shorter duration for inservice inspections.

This rule will result in a cost savings to the industry.

A third amendment to Part 50 (52 FR 1292) requires that licensees must notify the Regional Administrator of the appropriate Region following the filing of a petition for bankruptcy.

Notification must include the date of filing and the court in which the petition was filed.

The cost of implementation of this rule by operating reactor plants is insignificant since this would be an extremely unusual situation.

3 One amendment to Part 55 (52 FR 4601) defined NRC requirements for operator licensing, including operator eligibility for taking exams and information exams will cover. Although this information does not impose requirements which resul' in changes to operating pcwer plant systems, components, structures, procedures, organization, or design at operating power plants, the rule also requires iicensees to either have a training simulator or tell NRC what they will use for this kind of training. Some utilities purchased simulators before the rule was published in anticipation of the rule.

The estimated cost to industry, including utilities which purchased simulators after the rule was published and utilities who are considering alternate methods for complying with the rule, is $90,000,000.

One amendment to Part 20 (52 FR 4601) requires that personnel dosimeters that require processing must be evaluated and processed by a dosimetry processor who holds accreditation by NVLAP of the National Bureau of Standards.

The estimated cost to the industry is $478,000 per year.

Five amendments to Title 10 of the Code of Federal Regulations, Part 73 were published in fina) form in CY 1987. One of these imposed changes to operating power plant systems, components, structures, procedures, organization, or design at operating power plants.

The amendment to Part 73 changes the requirements for criminal history checks of individuals granted unescorted access to a nuclear power facility or access to safeguards information by power reactor licensees. The estinated implementation cost to the industry is

$5,680,000. The estimated industry operational cost is $468,000 per year.

6.

, Regulatory Guides The NPC issued two new Regulatory Guides and revised four Regulatory i

Guides (division 1 - reactors) in CY 1987. Two of the Regulatory Guide revisions were issued to provide information to licensees on acceptable I

methods for complying with a new rule published in 1987 Neither the revisions nor the new Regulatory Guides imposed changes to operating plants.

7.

Policy Statements The Comission issued three final policy statements, one proposed policy statement, one interim policy statement, and one revised policy statement during CY 1987. Only the one interim policy statement imposed any new requirerents on operating plants.

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4 One interim policy statement, "Policy Statement on Technical Specification Improvements for Nuclear Power Reactors," establishes a specific set of objective criteria for determining which regulatory requirements and operating restrictions should be included in Technical Specifications.

It encourages licensees to implement a voluntary program to update the Technical Specifications to be consistent with revised vendor-specific standard Technical Specifications to be developed by industry based on these criteria and subject to NRC staff approval.

8.

Plant Specific Backfit Tracking System One plant specific modification judged to be a backfit reached the final imposition stage in 1987.

In February 1987, the NRC issued a letter to Northeast Nuclear Energy Company, discussing four actions identified as backfits for Millstone 3.

The backfit requirements involved licensee review and modification of certain procedures for station blackout at Millstone 3.

The licensee notified the staff by letter in March 1987 that it had initiated or completed three actions but wished to appeal the fourth regarding a Technical Specification change. The appeal was resolved following the staff's determination that the licensee already had procedures which would accomplish the purpose of the Technical Specification change.

The estimated cost to Northeast Nuclear Energy Company of implementing the backfit is $175,000.

Six additional items entered into the backfit tracking system were imposed by the staff based on their determination that the issue was one of compliance with a previously existing regulatory position.

9.

Orders In 1987, several orders were issued to operating power reactors. Most of the orders were confirmatory, approving a schedule change from a previous order or confirming plans proposed by the licensee to correct operational safety problems. Three enforcement orders were issued in 1987 for potential violations of NRC requirements.

These orders did not impose any new regulatory requirements but constituted enforcerrent actions as a result of a utility not meeting previously existing regulatory requirenents.

In March 1987. Philadelphia Electric Company was issued an order, effective immediately, suspending power operation at Peach Bottom Units 2 and 3 because operators were found sleeping or inattentive to licensed duties, licensee management knew or should have known about this problem, and a history of other operational occurrences existed. These factors were a significant regulatory concern to the NRC and caused the NRC to question the management effectiveness for the facility.

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5 In October 1987. Florida Power and Light Company was issued an order, effective inniediately, for its Turkey Point Units 3 and 4 because numerous civil penalties had proven ineffective in assuring lasting safety improvement and compliance with NRC requirements. Because of continuing problems, the NRC issued this order rodifying the licensee's commitments to conduct an independent third party review of certain site and corporate activities, as well as their connitment to provide management coverage on the operating shifts.

In November 1987, General Public Utilities Nuclear Corporation was issued a confirmatory order, effective immediately, for the failure to maintain Oyster Creek in accordance with a safety limit and an apparent attempt by a member or members of the operating shift to conceal or destroy records associated with the safety limit violation. This order confirms the licensee's removal of the shift crew from licensed duties, requires that the licensee obtain NRC approval before returning any of the involved operators to licersed duties, and requires the licensee to provide the NRC a copy of their internal investigation of the matter when it is completed.

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