ML16224A121
| ML16224A121 | |
| Person / Time | |
|---|---|
| Issue date: | 10/14/1993 |
| From: | Wilkins J Advisory Committee on Reactor Safeguards |
| To: | Taylor J Advisory Committee on Reactor Safeguards |
| References | |
| D931014 | |
| Download: ML16224A121 (2) | |
Text
D931014 Mr. James M. Taylor Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Taylor:
SUBJECT:
PROPOSED RULE AND DRAFT REGULATORY GUIDE TO ADDRESS RESOLUTION OF GENERIC ISSUE 23, "REACTOR COOLANT PUMP SEAL FAILURE" During the 402nd meeting of the Advisory Committee on Reactor Safeguards, October 7-8, 1993, we reviewed a proposed rule and draft regulatory guide developed for resolving Generic Issue 23, "Reactor Coolant Pump Seal Failure." Our Subcommittee on Decay Heat Removal Systems met on October 5, 1993, to review this matter.
During this review, we had discussions with representatives of the NRC staff, Northeast Utilities, and NUMARC. We also had the benefit of the referenced documents.
We do not believe that the proposed rule and draft regulatory guide should be issued for public comment in their present form. There are several aspects of the rulemaking package that need further attention. For example, the proposed rule is too deterministic and does not permit consideration of the wide variation in risk from pump seal LOCA among the different plants. We believe that the proposed rule should be revised to permit the use of a risk-based approach. Furthermore, the provision in the regulatory guide that either seal cooling be restored within 10 minutes or a seal leakage rate of 480 GPM per reactor coolant pump be assumed appears to be overly conservative. This provision will have a serious impact on the coping analyses already performed to meet the strictures of the Station Blackout Rule.
There is clearly a need for further dialogue among the NRC staff, the nuclear industry, and the ACRS. We wish to be kept informed regarding the resolution of this matter.
Sincerely, J. Ernest Wilkins, Jr.
Chairman
References:
Memorandum dated August 3, 1993, from C. J. Heltemes, Jr., Office of Nuclear Regulatory Research, to J. Ernest Wilkins, Jr., ACRS Chairman,
Subject:
Proposed Rule for GI-23, "Reactor Coolant Pump Seal Failure," with following enclosures (1) Draft NUREG-1483, "Regulatory Analysis Supporting
Proposed Rule on Reactor Coolant Pump Seals" (2) Proposed Federal Register notice (3) Draft Regulatory Guide, DG-1008, Revision 1, "Reactor Coolant Pump Seals."