United States Nuclear Regulatory Commission

Office of Public Affairs

Washington, DC 20555

Phone 301-415-8200 Fax 301-415-2234

Internet:opa@nrc.gov

No. 96-74 FOR IMMEDIATE RELEASE

(Wednesday, May 22, 1996)

NRC STAFF COMPLETES SURVEY OF REFUELING PRACTICES

AT NATION'S NUCLEAR POWER PLANTS

A Nuclear Regulatory Commission staff survey has found that

most of the 110 nuclear power plants in the nation are conducting

refueling practices consistent with their license requirements.

The survey further found, however, that 15 nuclear power

plants at nine sites may not have acted consistent with license

commitments when they moved all the fuel from the reactor to the

spent fuel storage pool during refueling, rather than a partial

offload. Since the survey was completed, utilities which operate

these plants have either updated their license documents to

reflect the refueling practices or have firm commitments to NRC

that such action will be completed before the next refueling

outage.

Unloading the full reactor core during refueling is

practiced by the majority of nuclear power plant licensees. NRC

considers the practice one which can be beneficial to safety,

particularly in reducing the hazard to workers who perform

maintenance in or around the reactor vessel during outages. The

agency's concern is that, before it is used, the practice be

properly analyzed and documented.

NRC staff conducted this survey as part of a wider project

to measure the extent to which problems encountered at the

Millstone Unit 1 plant in Connecticut exist at other facilities.

A copy of the survey report is attached.

####

Attachment:

As stated
1

May 21, 1996

MEMORANDUM TO: Chairman Jackson

Commissioner Rogers

Commissioner Dicus

FROM: James M. Taylor

Executive Director for Operations

SUBJECT: REPORT ON SURVEY OF REFUELING PRACTICES

In my memorandum to Chairman Jackson dated December 28, 1995, I

committed the staff to conducting two activities that would

measure the extent to which problems encountered at Millstone

Unit 1 regarding compliance with the Final Safety Analysis Report

(FSAR) existed at other facilities. The first activity, which is

the focus of the attached report, compared current refueling

practices against the licensing basis (drawn from the FSAR,

Technical Specifications, license amendments and other docketed

correspondence) for decay heat removal from spent fuel pools for

all operating reactors. The second activity was to review

licensee compliance with other aspects of the facility

description contained in the FSAR through revised NRC inspection

guidance. The results of this latter activity will be presented

separately.

The staff's goal was to complete the spent fuel pool related

survey for those plants with pending outages before refueling and

no later than May 1996 for all other facilities. Although there

were several plants that had started refueling before the staff's

review, the review results from these plants were consistent with

the comments and findings noted herein for other plants.

As described in the attached report, the staff has completed its

review of core offload practices for each operating reactor.

Based on the survey, the staff has concluded that plants have

spent fuel pool cooling systems and backup cooling capability

that the NRC staff had reviewed and approved. System design

features and licensee operating practices were found to be

adequate in assuring protection for public health and safety. It

is noted that margins of safety, although adequate, and the

clarity of requirements varied from plant to plant. In addition,

the staff concludes that, based on the information collected and

reviewed and the specific licensee actions taken and commitments

made during the course of this review, core offload practices are

currently consistent with the spent fuel pool decay heat removal

licensing basis for all plants or will be prior to the next

refueling outage. However, during the course of the review, the
2

staff determined that nine sites (fifteen units) needed to modify

their licensing bases or plant practices, pursuant to 10 CFR

50.59 or 10 CFR 50.90, to ensure that their reload practices were

in compliance with their licensing basis. This is an indication

that, similar to Millstone, Unit 1, a number of other plants

appear to have previously performed full core offloads

inconsistent with their licensing basis.

To gain additional perspective on these nine sites, the staff is

examining the results of the recent broad scope FSAR compliance

regional inspection activities to see if these sites show

evidence of potential programmatic FSAR non-compliance problems.

The broad base FSAR compliance review at all plants and the

comparison of existing FSAR compliance data for the nine sites

documented in the attached fuel pool survey report is ongoing.

The results of these activities will be presented separately.

Due to previously identified concerns regarding FSAR compliance

at the Millstone and Haddam Neck plant, the staff has issued

letters pursuant to 10 CFR 50.54(f) to Northeast Utilities

regarding compliance with the FSAR for those plants. The

problems identified to date at the shutdown Millstone Units 1, 2

and 3 are broader in scope and more serious in nature than the

core offload compliance discrepancies noted in the attached

report. The staff has not identified any concerns at Haddam Neck

regarding compliance with the core offload and spent fuel pool

decay heat removal licensing basis as a result of its spent fuel

pool survey. However, through the 10 CFR 50.54(f) request

mentioned above, the staff is seeking information which is

broader in scope than the spent fuel pool survey and the

resulting information could potentially alter our current

findings on Haddam Neck.

In addition to the nine plants mentioned above, the staff noted

that the FSARs for ten sites (eighteen units) did not reflect the

most recent licensing basis information as required by 10 CFR

50.71(e). However, since the affected information was already

captured elsewhere in the licensing basis (i.e., in docketed

submittals and staff safety evaluations), the staff considers the

non-timely updating of the FSAR to be an indication of

administrative program failures to maintain plant documentation.

Such administrative program failures could have safety

significance if they were widespread and resulted in violations

of other requirements such as 10 CFR 50.59.

The staff is taking steps to ensure that the details of the staff

findings for these plants are documented in inspection reports.

It is expected that the characterization of the report findings

for individual plants may be revised as the staff completes the

detailed documentation activity. The staff will complete

documentation of spent fuel pool survey discrepancies in plant-
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specific inspection reports by June 28, 1996. Concurrently, the

staff is developing enforcement guidance to address the instances

of non-compliance with the FSAR identified in the spent fuel pool

survey and the broader FSAR compliance review. Application of

any enforcement guidance to the findings of potential noncompliance identified through the fuel pool survey would follow

accordingly.

In addition to the compliance issues identified, the staff will

review the data collected as part of the survey and will identify

specific plant design features and operating practices which are

candidates for safety enhancements using the backfit process (10

CFR 50.109). An example of potential candidates for design

enhancement is spent fuel pool instrumentation. The staff will

develop its plans for plant-specific backfit activities or

generic improvements in the regulation of spent fuel pool decay

heat by June 28, 1996.

After addressing the compliance issues and potential safety

enhancements, the staff will consider ways to improve the clarity

and consistency of our spent fuel pool requirements. One

approach currently under consideration is to include spent fuel

pool design and operational issues in the shutdown rule-making

activity which is already well underway.

This will be made publicly available in five working days from

the date of this memo. SECY please track.

Attachment: Refueling Practice Survey: Final Report

cc: SECY

OGC

OCA
4

REFUELING PRACTICE SURVEY: FINAL REPORT

1.0 INTRODUCTION

In July 1995, Northeast Utilities submitted a proposed license

amendment for Millstone Unit 1 requesting that the staff approve

a full core offload as a normal refueling practice, approve

certain new methods for analyzing decay heat removal, and approve

certain new technical specification (TS) requirements. In August

1995, a petition was filed, pursuant to 10 CFR 2.206 which

sought, among other things, the denial of the Millstone 1 license

amendment request. The staff conducted an extensive review of

the Millstone application and the issues raised in the 2.206

petition. To address the amendment request and the petition, the

staff examined a number of design issues, operating and

administrative procedural issues, and licensing basis issues.

One of the fundamental issues in both proceedings concerned the

operational limits on core offload practices as documented in the

Millstone 1 licensing basis. The Millstone 1 spent fuel pool

cooling system is designed to remove heat from the spent fuel

pool, and the system design capabilities are documented in

various licensing documents. During the review, the staff became

concerned about whether the licensee's practice of conducting

full core offloads was consistent with the licensing basis of the

spent fuel pool decay heat removal systems. The staff was

concerned that routine refueling offload practices may not have

been consistent with licensing basis assumptions regarding

routine or normal operation.

Through the fall of 1995, the staff became aware of several

discrepancies between the current spent fuel pool licensing basis

and the refueling practices at other nuclear plants. The staff

issued Information Notice 95-54, "Decay Heat Management Practices

During Refueling Outages," dated December 1, 1995, to inform the

industry of the discrepancies observed at Millstone 1 and the

other facilities. Based on the staff's ongoing "Task Action Plan

for Spent Fuel Storage Pool Safety," which is intended to address

technical concerns, and the continued confidence of the staff in

the substantial, though variable, safety margin provided by the

design of existing spent fuel pools and their associated support

systems, the staff did not consider immediate regulatory actions

appropriate to address the observed licensing basis

discrepancies.

On December 28, 1995, the staff forwarded a memorandum to the NRC

Chairman on the lessons learned from the Millstone 1 review. In

this memorandum, the staff committed to review the refueling

practices at all operating reactors against the current spent

fuel pool decay heat removal licensing basis (as documented in
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the Final Safety Analysis Report (FSAR) and other documents) for

those facilities. The staff committed to review each operating

plant before the next scheduled refueling outage, but no later

than May 1996 for all plants. Although there were several plants

that had started refueling before the staff's review, the review

results from these plants were consistent with the comments and

findings noted herein for other plants.
6

2.0 SCOPE OF REVIEW AND PROJECT EXECUTION

To meet the spent fuel pool survey commitments described in the

December 28, 1995, memorandum, the staff developed a program to

evaluate each operating reactor's refueling practices relative to

each reactor's current spent fuel pool decay heat removal

licensing basis. Table 1 lists the plants that were included in

the survey as well as the routine offload practice at that plant.

2.1 Licensing Basis Review

To determine the licensing basis, the staff reviewed relevant

licensing documents that discussed the capability to remove decay

heat from the spent fuel pool including:

- relevant Final Safety Analysis Report (FSAR) sections

- relevant Technical Specifications

- documentation associated with license amendments related to

the spent fuel pool (Common examples of this are amendments

that increase the licensed storage capacity of the spent

fuel pool ("rerack" amendments), amendments that increase a

reactor's licensed thermal power ("power uprate"

amendments), and amendments that increase the licensed

enrichment or energy production density ("burnup") of fuel.)

- other docketed correspondence addressing spent fuel pool

decay heat removal capabilities that further defined the

systems or practices

The staff focussed on certain specific areas in determining the

licensing requirements for each plant:

- descriptive phrases that imply the frequency of certain

offload sequences (e.g., normal, abnormal or emergency)

- configuration of spent fuel pool cooling systems assumed to

be operating in the design analyses (e.g., single failure

considerations, backup systems)

- assumptions that affected spent fuel pool heat load (e.g.,

delay time and operating history)

- plant specific spent fuel pool temperature limits and the

bases for those limits.

The staff observed that the licensing basis for spent fuel pool

decay heat removal varied among plants. This variation in

licensing bases stems from differences in spent fuel decay heat

removal system design accepted by the staff, from differences in
7

the level of detail provided in the licensing documents and from

evolving NRC review criteria. As a result, the margin of safety

with respect to system capacity and reliability differs from

plant to plant.

2.2 Operating Practice Review

To determine the operating practices of each operating reactor

during refueling, the staff visited the plant site or the utility

corporate office and reviewed plant specific operating

procedures, administrative controls and engineering analyses.

The staff compared the operating practices with the licensing

basis developed for each operating reactor to identify

discrepancies with the design basis assumptions for the spent

fuel pool cooling system.

As part of the survey, the staff also gathered detailed design

information on the spent fuel pool storage facilities at all

operating reactors. This information will be used in developing

plans for resolution of the staff's "Task Action Plan for Spent

Fuel Storage Pool Safety."

3.0 COMMENTS AND FINDINGS

Operating Practice Reviews

Except as noted in the attached Tables 2 and 3, the staff found

that for most plants, core offload practices were consistent with

the licensing basis and the FSAR reflected most recent changes to

the licensing basis. Also, applicable procedures and

administrative controls were found to be adequate. The staff did

note, however, that many plants were considering or processing

changes to the FSAR to correct minor inconsistencies and were

enhancing applicable procedures to better control outage

operations.

However refueling practices at several plants were potentially in

conflict with that plant's spent fuel pool decay heat removal

licensing basis. Plants that the staff concluded were in this

condition are listed in Table 2. In some cases, the licensee had

independently recognized the discrepancy and took steps to modify

the plant's spent fuel pool decay heat removal design basis or

the plant's refueling practices. In other cases, the staff

promptly informed the licensee about its understanding of both

the plant's licensing basis and the plant's operating practices

and identified the discrepancies between the two. In all cases,

affected licensees took action or committed to take action to

reconcile refueling offload practices with licensing requirements

before the next core offload activity took place.
8

Because these plants may have operated outside their licensing

basis during previous refueling outages, the staff will document

the detailed findings for these facilities in appropriate

inspection reports and will take appropriate regulatory action.

Periodic FSAR Updates

Some plant-specific FSARs did not reflect information associated

with spent fuel pool decay heat removal from applicable license

amendments. An NRC regulation, specifically 10 CFR 50.71(e),

requires that the FSAR be periodically updated to reflect such

information. Plants where this discrepancy was observed are

listed in Table 3 although such plants may be within the update

periodicity provided in 10 CFR 50.71(e) and thus may not be in

violation of 10 CFR 50.71(e). The staff will document the

detailed findings for these facilities in appropriate inspection

reports and will take appropriate regulatory action.

Control of Design Basis Assumptions

At a number of plants, the staff identified weaknesses in the

procedural control of design basis assumptions. An example of

this includes weak procedure control of in-vessel decay time

prior to fuel transfer. In some cases, licensees upgraded

procedures to directly implement the design basis assumption, in

other cases the licensee revised existing procedures and

performed engineering analyses, documented pursuant to 10 CFR

50.59, as necessary, to ensure the planned activities would not

exceed design basis assumptions. In addition, some plants

perform outage-specific analyses as a matter of routine, while

other plants performed (or plan to perform) such analyses in

response to the staff's survey.

Other Observations

A number of facilities were found to remove spent fuel pool

cooling systems and/or support systems from service for

maintenance during refueling outages. While the staff did not

identify any specific instances of potential non-compliance in

this regard, the staff will consider the appropriate level of

operational controls during refueling outages as part of the Task

Action Plan on Spent Fuel Storage Pool Safety. Such an issue may

be appropriately addressed within the context of shutdown risk

rulemaking activities.

Also, a number of facilities had installed significant additional

spent fuel pool decay heat removal capability pursuant to 10 CFR

50.59 (Table 4). For example, one plant installed a two-train,

alternate decay heat removal system such that either train could

reject the heat associated with the full core offload. The

system was installed to facilitate performance of full core
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offloads while allowing simultaneous maintenance of RHR systems

which might otherwise be needed for spent fuel pool cooling.

The staff reviewed the 10 CFR 50.59 evaluations for several of

these modifications and found them adequate. In general, it is

expected that this kind of modification could be performed under

50.59 without prior staff approval. However, plant specific

circumstances may require a license amendment.

4. CONCLUSIONS

During the course of the survey, the staff evaluated the

compliance of refueling operating practices at each operating

reactor with respect to that plant's spent fuel decay heat

removal licensing basis. The staff concludes that, based on the

information collected and reviewed and the specific licensee

actions taken and commitments made during the course of this

review, refueling operating practices are currently consistent

with the spent fuel pool decay heat removal licensing basis for

all plants or will be prior to the next refueling outage.

However, the survey determined that nine sites (fifteen units)

needed to modify their licensing bases or plant practices,

pursuant to 10 CFR 50.59 or 10 CFR 50.90, during the course of

the review to ensure that their reload practices were in

compliance with their licensing basis. This is an indication

that some of these plants may have previously performed core

offloads inconsistent with their licensing basis. In addition,

the staff noted that the Final Safety Analysis Reports for ten

sites (eighteen units) did not reflect the most recent licensing

basis information.

The staff is taking steps to ensure that the details of the staff

findings for these plants are documented in inspection reports.

It is expected that the characterization of the report findings

for individual plants may be revised as the staff completes the

detailed documentation activity. The staff will complete

documentation of spent fuel pool survey discrepancies in plantspecific inspection reports by June 28, 1996. Concurrently, the

staff is developing enforcement guidance to address the instances

of non-compliance with the FSAR. Application and implementation

of any enforcement activities to the findings of potential noncompliance identified through the fuel pool survey would follow

accordingly.

The staff did not identify any safety issues regarding spent fuel

pool decay heat removal of core offload practices that have not

been captured for resolution as part of the staff's "Task Action

Plan for Spent Fuel Storage Pool Safety." As part of the action

plan, the staff concluded that the existing design and operation

of spent fuel pool systems do not pose an undue risk to public

health and safety. Because of the variation in spent fuel pool
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cooling system design bases accepted by the staff in the past,

the staff concluded that compliance with design limits does not

reflect a consistent margin of safety. To address this

conclusion and other technical concerns, the staff is examining

spent fuel pool design and operation to identify safety

enhancements through the implementation of the staff's action

plan for spent fuel storage pool safety.

During the course of the survey, the staff also collected

detailed design information on spent fuel pool systems for all

operating reactors. This information will be used in developing

plans for resolving the staff's "Task Action Plan for Spent Fuel

Storage Pool Safety." Plans for resolving action plan issues as

well as separate plans to address the license compliance issues

described in this report will be completed by June 28, 1996.
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Table 1: Routine Offload Practices

PLANT OFFLOAD METHOD

ANO-1 Full Core

ANO-2 Full Core

Big Rock Point Full Core

Beaver Valley 1,2 Full Core

Braidwood 1,2 Full Core

Browns Ferry 1,2,3 Full Core

Brunswick 1,2 Full Core

Byron 1,2 Full Core

Callaway Full Core

Calvert Cliffs 1,2 Partial Core

Catawba 1,2 Full Core

Clinton Partial Core

Comanche Peak 1,2 Full Core

D.C. Cook 1,2 Full Core

Cooper Full Core

Crystal River Full Core

Davis Besse Full Core

Diablo Canyon 1,2 Full Core

Dresden 2,3 Full Core

Duane Arnold Full Core

Farley 1,2 Full Core

Fermi 2 Full Core

Fitzpatrick Full Core

Fort Calhoun Full Core

Ginna Full Core

Grand Gulf Partial Core

Haddam Neck Full Core

Harris Full Core

Hatch 1,2 Full Core

Hope Creek Partial Core

Indian Point 2 Full Core

Indian Point 3 Full Core

Kewaunee Partial Core

LaSalle 1,2 Full Core

Limerick 1,2 Partial Core

Maine Yankee Full Core

McGuire 1,2 Full Core

Millstone 1 Full Core

Millstone 2 Partial Core

Millstone 3 Full Core

Monticello Partial Core

Nine Mile Point 1,2 Partial Core

North Anna 1,2 Full Core

Oconee 1,2,3 Full Core

Oyster Creek Partial Core

Palisades Partial Core
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Palo Verde 1,2,3 Full Core

PLANT OFFLOAD METHOD

Peach Bottom 2,3 Partial Core

Perry Partial Core

Pilgrim Partial Core

Point Beach 1,2 Full Core

Prairie Island 1,2 Partial Core

Quad Cities 1,2 Full Core

River Bend Partial Core

Robinson Full Core

Salem 1,2 Full Core

San Onofre 2,3 Full Core

Seabrook Full Core

Sequoyah 1,2 Full Core

South Texas 1,2 Full Core

St. Lucie 1,2 Partial Core

Summer Full Core

Surry 1,2 Full Core

Susquehanna 1,2 Partial Core

TMI-1 Partial Core

Turkey Point 3,4 Full Core

Vermont Yankee Partial Core

Vogtle 1,2 Full Core

Waterford Partial Core

Watts Bar Full Core

WNP-2 Partial Core

Wolf Creek Full Core

Zion 1,2 Full Core
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Table 2: Past Offloads in Potential Non-Compliance with Current

Licensing Basis

Cooper

McGuire 1,2

Millstone 1

North Anna 1,2

Oconee 1,2,3

South Texas 1,2

Summer

Turkey Point 3,4

Vogtle 1

Table 3: FSAR Update Needed to Achievew Consistence Within

Licensing Basis

Browns Ferry 1,2,3

Crystal River

Fermi 2

Kewaunee

LaSalle 1,2

Millstone 1,2,3

Salem 1,2

Sequoyah 1,2

Vermont Yankee

Zion 1,2

Table 4: Significant Plant Modifications Under 50.59

Brunswick 1,2

FitzPatrick

Hatch 1,2

Seabrook

Susquehanna 1,2