ML20206M747
| ML20206M747 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/12/1986 |
| From: | NORTHEAST UTILITIES |
| To: | |
| Shared Package | |
| ML20206M730 | List: |
| References | |
| NUDOCS 8608210369 | |
| Download: ML20206M747 (12) | |
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NORTHEAST UTILITIES oeneral omcoe e Seiden Street. Benin. Connecticut
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June 12, 1986 Integrated Safety Assessment Program In approving SECY-85-160 (May 6, 1985), the Nuclear Regulatory Commission approved an Integrated Safety Assessment Program ("ISAP") involving two volunteer operating power reactors - Northeast Utilities' Millstone Unit No. 1 and Haddam Neck plants.
The final reports for the Millstone Unit No. 1 and the Haddam Neck ISAPs are scheduled to be submitted to the NRC Staff in July 1986 and November 1986, respectively.
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Northeast Utilities advocates and is prepared to commit to participate in ISAP for its Millstone Units Nos. 2 and 3.
Northeast reiterates its willingness to fully fur.d the NRC ISAP review process through payment of appropriate fees to the NRC.
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l Northeast believes that it is in the nation's interest to continue with the next phase of ISAP through the participation of Millstone Units Nos. 2 and 3 in the process.
We believe that continuation of ISAP will further I
8608210369 860818 PDR ADOCK 05000336 P
.- demonstrate the most efficient regulatory process for enhancing safe reactor operations on a properly prioritized and cost-effective basis.
We believe that this further demonstration can best be achieved by Northeast because it has an experienced ISAP team in place.
We urge the Commission to evaluate the feasibility and desirability of continuing ISAP from the broad perspective that such attempts to demonstrate important and pervasive regulatory reform warrant.
A fundamental part of the Commission's decisionmaking process in this regard should be the 1986 NRC Policy and Program Guidance, NUREG-0885, Issue 5 (rebruary 1986), which establishes the principal philosophies, goals, policies and planning guidelines The pronounced by the Commission to govern its activities.
in our purpose of the following analysis is to describe how, fulfills the Commission's vision articulated in view, ISAP NUREG-0885.
Most significantly, ISAP is completely in harmony with the NRC's Philosophy of Regulation and Strategic Goals.
According to NUREG-0885, " excellence" is the NRC's standard of performance.
The NRC states that "[e]xcellence can be achieved by having a clear sense of purpose through candid by valid analysis and effective decisionraking, assessment, and by f
by developing strong and vigilant management, 1
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.. continually searching for ways to do things better."
NUREG-0885, at 3.
We believe ISAP represents all of the above.
First, ISAP is a new approach, responding to and furthering the long-standing support within the NRC for-a systematic review of the safety of operating nuclear power plants.
Second, ISAP utilizes both deterministic and probabilistic techniques to resolve outstanding licensing issues, to evaluate plant-specific resolutions to unresolved safety issues, and to implement licensee-initiated plant improvement projects.
The program is a logical successor to the Systematic Evaluation Program ("SEP") and the Interim Reliability Evaluation Program ("IREP") for candid assessment, valid analysis, and effective decisionmaking.
Finally, a crucial element of ISAP is the Integrated Living Schedule -- a prioritized schedule, based on the ISAP evaluations, for implementation of all proposed projects.
The Integrated Living Schedule will allow focused and 4
coordinated management response to regulatory and utility initiated bodifications.
The Integrated Living Schedule, we believe, will serve as the basis for implementation of future NRC regulatory actions.
In NUREG-0885 the NRC also sets out specific policies and planning guidance.
These policies and planning guidance are intended to promote the NRC's Strategic Goals of
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improving assuring safe operation of licensed facilities, regulation of the nuclear industry, and protecting public health and safety from risks associated with the wide-scale t
ISAP fulfills many of these use of nuclear materials.
Specific specific NRC policies and planning standards.
examples are listed below.
One of NRC's fundamental tasks is to assure that existing nuclear reactors and those coming on-lineConsequen Policy A.1_:
operate safely.-
operating facilities maintain adequate given to assuring (1) levels of protection to public health and safety, and (2)and reactors are adequately designed, built, operation.
The staff should carry out NRC regulatory that licensees have the Policy A.2:
activities cognizant o,f the fact construction, primary responsibility for the safe design, and operation of nuclear facilities.
These policies are fundamental to the NRC's role of overseeing nuclear reactor operations and resolving reactor ISAP fulfills these policies by providing safety concerns.
l systematic review of all open licensing and a complete, A framework is established to regulatory issues.
respond to operational accommodate new regulatory issues, events, and assess other factors which will influence the The Integrated Living Schedule decision making process.
will assure that issues with the greatest potential impact on public health and safety will be assigned the highest
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,, priority for resolution.
Issues with little or no impact will be deferred or dropped with NRC concurrence, thereby conserving resources for allocation to the most important matters.
Moreover, ISAP is a licensee-initiated program.
It allows the licensee to determine appropriate plant specific resolutions to various issues and incorporates the licensee's own "self-improvement" projects.
This reflects the policy that licensees should have the primary responsibility, and the flexibility, to achieve excellence in plant performance.
Policy A.3:
The NRC must be sensitive to the large number of requirements imposed on licensees.
Requirements imposed on the regulated industry by NRC shall be imposed only in accordance with the Commission's backfit rule.
Planning Guidance A.26:
Existing regulatory requirements should be reviewed to see if some could be eliminated without compromising safety, safeguards or environmental protection.
For those requirements that are necessary, effective measures should be taken to ensure that they are implemented in a time'.y manner.
ISAP embodies the " sensitivity" incorporated in the i
l above policy.
The NRC has imposed a large number of backfits in response to the Three Mile Island accident and l
as part of the resolution of generic issues.
Significant requirements have also been imposed in the areas of fire i
protection, equipment qualification, and onsite emergency response.
The ISAP process for prioritizing issues allows a
--6 coordinated, orderly, and reasoned approach to implementation of these backfits.
4 Moreover, as part of ISAP, Northeast Utilities has individually evaluated the public safety benefit of each of the numerous proposed projects considered in the program.
This plant-specific evaluation will allow elimination of backfits without compromising safety, safeguards, or environmental protection.
As discussed above, the ISAP evaluation and process for prioritizing issues also fulfill the Commission's guidance of assuring timely implementation of significant projects.
Policy A.5:
Where data permit, probabilistic risk assessment is a useful tool for assessing the reliability of safety systems and for weighing risks against one another.
Quantitative risk assessment techniques will be used judiciously by the staff and the boards to estimate risks as an aid to decisionmaking.
l Planning Guidance A.4:
Attention should be given to j
refining the use of probabilistic risk assessment techniques to implement Commission policy on safety goals, as directed l
by the commission, and in other regulatory applications i
especially amenable to risk assessment.
Whenever probabilistic risk assessment is used in the decision-making there must be clear statements of the scope and
- process, depth of the assessment, clear identification of the most significant assumptions, a systematic evaluation of the uncertainties, and a clear description of how uncertainties have been treated in making decisions.
ISAP expressly makes use of probabilistic risk assessment techniques for evaluating the relative merits of the various licensing and plant improvement projects.
Specifically, Northeast Utilities has completed Probabilistic Safety Studies ("PSS") for both Millstone Unit No. 1 and Haddam Neck.
The Millstone ISAP final report will draw from the insights of the PSS and various probabilistic sensitivity analyses based on the PSS.
Combined with deterministic reviews, operating experience data, person-rem implications and the other elements of the ISAP process, these analyses provide an excellent framework for decisionmaking.
Moreover, ISAP does not rely exclusively upon probabilistic risk assessment.
The scope and depth of assessments on indiv'idu'al ISAP topics will be clearly i
identified in the ISAP final reports.
In addition, the Staff is familiar with Northeast Utilities' use of I
Previous interactions with the probabilistic techniques.
Staff on the plant-specific PSS's for Millstone Unit 3, Millstone Unit 1, and Haddam Neck, and the topic specific evaluations have established the foundation for efficient fe'ure communications.
l Unresolved safety issues should be promptly Policy A.6: Priorities for implementation should be resolved.
established in light of the safety significance of the issue and all other requirements imposed on the licensee.
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,. Planning Guidance A.7:
By the end of 1986, to the extent the staff will issue for public comment draft practical, technical resolutions for currently-identified unresolved The staff should continue to review and safety issues.
approve the addition of new generic safety issues in accordance with current Commission policies and resolve the high priority issues first.
The Commission's policy is to promote expeditious resolution of generic issues.
ISAP incorporates plant-specific resolutions to several USI's and high-priority generic issues identified in NUREG-0933.
The program therefore assures appropriate and timely resolution of these issues.
Moreover, through ISAP, these resolutions will be incorporated in light of their safety significance and in light of all other pending requirements imposed by the NRC.
We remain hopeful that selected USI and high priority issues can and will be resolved prior to formal NRC issuance of generic technical resolutions.
Policy A.14:
One of NRC's goals is to ensure a high level The NRC of quality in reactor operations and maintenance.
and industry need to better understand the causal factors the repetition of past mi problems and to work to eliminate leading to stakes.
is dedicated to achieving excellence in nuclear ISAP The ISAP evaluation models include power plant performance.
a model for assessing the impact of proposed modifications In on plant maintainability and plant availability.
several specific ISAP topics for both Millstone
- addition, i
. Unit No. 1 and Haddam Neck have focussed on plant maintenance.
Operating experience assessment is a specific element of the ISAP process.
ISAP therefore, has been designed to be responsive to this Commission policy.
Policy A.16:
The Commission continues to believe that radiation protection of workers must be a major consideration when engineering and operational decisions for nuclear facilities are made.
ISAP explicitly incorporates a model to evaluate the effect of proposed modifications on occupational exposures and personnel safety.
In addition, Northeast Utilities, in developing the Integrated Living Schedule, will continue to consider ALARA constr,aints on implementation of modifications.
A recent example of how this policy was applied concerns modifications which were identified to comply with 10 C.F.R. 50.49, the environmental qualification rule.
For a limited number of valve motor operators, man-rem exposure associated with implementing the backfits was a key element of the rationale to not implement the modifications, a proposal advanced by NU and approved by the Commission.
Therefore, through ISAP, radiation protection of workers is a major consideration in Northeast Utilities' engineering and operational' decisions related to implementation of backfits.
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Planning Guidance A.1:
The Commission will consider alternate regulatory approaches which recognize the contributions of cooperative industry initiatives to the extent that such initiatives are effective and consistent with NRC regulatory responsibilities.
The Commission supports such industry efforts as INPO's Training Accreditation program, the INPO Operating Plant Evaluations, the Nuclear Plant Reliability Data System, and fitness for duty and maintenance improvements, i
The 1 SAP pilot program is an alternate regulatory approach and is a cooperative industry initiative.
As a result of ISAP, Northeast Utilities expects to achieve enhanced reactor operations through less prescriptive These regulation and greater licensee flexibility.
as reflected in represent essential regulatory improvement, the NRC's regulatory philosophy (see NUREG-0885 at 4).
I Planning Guidance A.13:
The staff should continue to assure that licensees implement all existing and new requirements which are imposed and to verify licensee implementation.
Planning Guidance A.14:
The staff should continue its efforts to establish an integrated implementation schedule for new and existing requirements reflecting relative Where priorities.for each power reactor licensee.
practical, and where the degree of understanding and data the results of cost-benefit analysis should be used
- permit, as one tool for evaluating new requirements.
The schedules 4
should reflect the importance of the requirements.
The schedules should reflect the importance of the requirement to safety or safeguards, as well as the licensee's ability to complete the necessary engineering, evaluation and design.
Once compliance dates have been established, the NRC will vigorously enforce license requirements associated 1
with such schedules.
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ISAP embodies these two planning standards.
The program will assure prioritized implementation of the majority of existing NRC requirements.
As part of the program, Northeast Utilities has evaluated the costs and benefits of each NRC backfit or licensee-initiated project in the areas of five evaluation models:
public health and safety, personnel safety, the plant's economic performance, The personnel productivity, and external impacts.
Integrated Living Schedule will reflect agreement with the NRC on the relative importance of each project evaluated in the program.
Compliance dates will be established as is appropriate and as is realistic.
This will help to assure that compliance dates are not arbitrary and that schedular extensions are less common.
In sum, the ISAP process for prioritizing issues will minimize plant disruption and related costs, while maximizing the aggregate public safety benefits.
When existing NRC requirements are downgraded in priority with NRC concurrence, a detailed justification will be provided, and the appropriate regulatory documents will be published (e.g.,
exemption).
Planning Guidance A.25:
The staff should expeditiously carry out those activities necessary to implement the Commission's severe accident policy.
For Millstone Unit No. 1 and Connecticut Yankee, ISAP reprasents a very important step toward implementing the i
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.. Commission's severe accident policy statement (50 Fed. Reg. 32138).
In conjunction with the already completed
- SEP, IREP, and plant-specific PSS, ISAP is responsive to the Commission's recommendation for a " limited-scope accident safety analysis."
These reviews assure that any "particular vulnerabilities to core melt or to unusually poor containment performance" have been identified and are being addressed.
For Millstone Unit No. I and Connecticut Yankee, through ISAP, the severe accident policy is, in large measure, being addressed far ahead of the schedule established by the Commission.
See 50 Fed. Reg. 32138, 32144 at col. 3.
In conclusion," Northeast Utilities believes that the continuation of the ISAP pilot program through the inclusion 2 and 3 in ISAP would be consistent of Millstone Units Nos.
with and in substantial furtherance of the goals of NUREG-0885.
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