ML20247C221

Raises Concerns Re Commercial Nuclear Power Plants Failing to Fully Implement TMI Action Plan Requirements,Specifically Control Room Habitability

ML20247C221
Person / Time
Site:	Seabrook
Issue date:	05/08/1989
From:	Markey E HOUSE OF REP.
To:	Zech L NRC COMMISSION (OCM)
Shared Package
ML20247C215	List: ML20247C208 ML20247C221
References
NUDOCS 8905240372
Download: ML20247C221 (5)

Text

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. COOPERATION IN EUROPE May 8, 1989 The Honorable Lando W. Zech, Jr.

Chairman Nuclear Regulatory Commission 1 Washington, DC 20555

Dear Chairman Zech:

Thank you for your May 4 response to the sixth question contained in my letter of March 23, 1989.

I remain concerned that more than two-thirds of the commercial nuclear power plants in the United States have failed to fully implement the_ requirements of the Three Mile Island Action Plan and that new plantsare not being required to fully implement those requirements prior to licensing. Ten years after TMI, this is not an acceptable situation. Moreover, it is unacceptable that the Commission cannot even respond on a timely basis to basic questions about the industry's compliance with the TMI Action Plan.

The information you have provided concerning New Hampshire Yankee's failure to fully implement Three Mile Island Action Plan items at the Seabrook nuclear power plant. raises the following questions:

1. According to your response, two of the three outstanding TMI Action Plan items must be completed before the issuance of a full power license Why shouldn't the third, changes to the SPDS system software, be completed before full power operation as well?

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2. No deadlines are given for outstanding items one and two, yet there is a target date of May 31, 1989 for implementation of changes to the SPDS system software. Why are there no deadlines or target dates for implementation of the other two .

outstanding items? What action will the NRC take if the May  !

31, 1989 target date is'not met?

3. Please explain how items one and two can be incomplete, yet adequate, for low-power operation but not for full-power operation. Why is it not appropriate to complete them, as well as the software requirements or item three, before the issuance of a low-power license? j i

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8905240372 890512 1 PDR COMMS NRCC 1 CORRESPONDENCE PDC q E- _ l

The Honorable Lando W. Zech, Jr.

May 8, 1989 l Page 2

4. The second outstanding TMI Action Plan item, modifications for control room habitability, was approved by the NRC staff on August 24, 1988. Please describe the modifications which remain to be made and why they have not yet been fully implemented. What is the significance of having the modifications made as the plant begins start-up? Should not all major modifications be completed before start-up?

5. As indicated in New Hampshire Yankee's April 18, 1989 response to the Commission's TMI Action Plan Status questionnaire, item II.D.1--Relief and Safety Valve Test Requirements--is considered to be completed. Other than New Hampshire Yankee's assurances, does the Commission have cause to remove this from the list of outstanding items? Have confirmatory actions oeen taken? Please explain why this item is considered to be completed.

I would appreciate responses to these questions within 10 working days or by May 19, 1989. If for any reason the Commission is unable to comply with my request, please provide an interim response explaining why and indicating when a complete response will be forthcoming.

I thank you in advance for your assistance and look forward to receiving the remaining responses to my March 23 latter as well.

With best wishes, Sincerely, Edward J. rkey Member of Congress EJM/awc Enclosure

ENCLOSURE Question and Answer Concerning the Status of TMI Action Plan Requirements at Seabrook QUESTION 6 What is the status of TM1 Action Plan requirements at the

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Seabrook nuclear power plant?

ANSWER The NRC staff has recently ca.;pleted a review of the status of all TMI Action Plan items at Seabrook. As described below, three TM1 Action Plan items remain to be completed and three others that have been implemented require confirmatory actions by the licensee. Before these confirmatory actions can be completed, however, specific plant conditions, including operation at power, must be achieved. These conditions cannot be met at the current stage of facility licensing. All other opplicable TMI Action Plan items at Seabrook have been completed.

A. TM1 Action Plan items To Be Completed

1. III.A.2.1 - Upgrade Preparedness - Upgrace Emergency Plans to Appendix E 10CFR 50 Two octions remain to complete this item: Implementation of the Public Alert ano Notification System in Massachusetts and fir,al distribution of public 1

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e information brochures. .These are awaiting completion of ASLB Emergency Prepared-ness Hearings on the Massachusetts portion of the Seabrook Emergency Planning Zone. The licensee will complete these actions after the hearings and prior to-l issuance of a full power license, i

2. 111.D.3.4.3. - Control Room Habitability - Implement Modifications i

Actions required to complete this item for power levels up to 5% have been completed and approved by the staff. Before exceeding 5% power, the licensee will implement a design change to bring the control building air system into conformance with the Standard Review' Plan and General . Design Criter. ion (GDC)

19. As presently constructed, control room pressurization could be compromised under certain conditions of a vitel bus failure coupled with a design basis accident. Although acequate for operation at less than 5% power, this potential failure mode must ae corrected before power operation. The NRC staff approved the licensee's design change on August 24, 1988. Implementation of this design change will close this item.

3. 1.D.2.3 - Plant Safety Parameter D15 play System (SPDS) Fully implemented The SPDS has been installed. Several system software changes are being imple-mented'ond will be completed by May 31, 1989. In accordance with an ASLB March 25, 1987 Partial Initial Decision, as it relates to the SPDS, system availability calculations and a loao test must be conducted and reported to NRC stoff. This cannot be completed until power operation.

, 8. TM1 Action Plan items Requiring Confirmatory Action

1. 1.D.1 - Control Room Design Reviews The licensee has committed to provide an evaluation of the control room environ-ment confirming the acceptability of parameters that will not be available until power operation (e.g. , temperature, noise, humidity). All other aspects of this item are complete.

2. II.B.3.4 - Post-Accident Sampling - Plant Modifications The Post-Accident Sampling System is complete but must be tested to show it will perform its intended function. Reactor coolant system activity is required to verify operability. Subsequent to low power testing, and prior to issuance of a full power license, confirmatory testing will be completed.

3. II.F.1.2.B - Accident Monitoring - Iodine /Porticulote Sample All needed instru'nentation has been installed. Operability of the system has been recently demonstrated by using moceling and andlysis by the licensee.

l The results of the modeling, which indicdte acceptable transmission factors  ;

for gaseous effluent sample lines, are to be documented in a report to be submitted to NRC by May 30, 1989. Confirmatory testing of the system under actual plant conditions cannot be accomplished without the presence of reactor coolant activity; however, the modeling and analysis appreoch has been accepted by the NRC staff.

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