ML17209A472

Solicits Votes to Reconsider no-review Decision Re ALAB-603. Decision Must Be Reached by 801214

ML17209A472
Person / Time
Site:	Saint Lucie
Issue date:	11/26/1980
From:	Hendrie J NRC COMMISSION (OCM)
To:	Ahearne J, Bradford P, Gilinsky V NRC COMMISSION (OCM)
Shared Package
ML17209A468	List: ML17209A467 ML17209A469 ML17209A470 ML17209A471 ML17209A472 ML17266A376 ML17266A377
References
ALAB-603, NUDOCS 8012230046
Download: ML17209A472 (42)

Text

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5 h.~~4 OFFICE OF THE COh1h1ISSIONER 0-UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON,O.C. 20555 November 26, 1980

SUBJECT:

NEMORANDUM FOR:

Chairman Ahearne, Commissioner Gi1 7~sky Commissioner Bradford FRON:

'oseph N. Hendrie./'<+

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ALAB-603 (SECY-A-80-140)

On October 14th, three of us voted for no review on ALAB-603 (St.

Lucie-2) and the Commission s review period ended..Commisssoner Gilinsky did not participate but had indicated his preference for Commission review.

There is now running the 60-day period in which ihe Commission might reconsider its no-review decision..

The 60-day period will end about December 14th.

Denton's memorandum of November 10th to the Chairman on station blackout, discussing proposed staff actions related.to ALAB-603, and the attached memo from Bernero, set me to reviewing the whole business.

I conclude my vote not to review ALAB-603 was in error.

There are some generic aspects of ALAB-603 that I think the Commission should consider very carefully.

These, are the use of probability numbers in the site review section of the Standard Review Plan to determine what events should be within the design basis of a plant and the way in which station blackout is framed as a design basis event.

I solicit your votes, first to reconsider the no-review decision, and second to take review of ALAB-603.

SECY will please poll the ComIission.

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SECY OGC OPE

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'OFFICE OF THE SECRETARY Docket No. 50-389 CP (ALAB-603)

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"I gI'g'7 NUCLEAR REGU f)ATORY'COMMISSlON WASHINGTON.D.C. 20555 December 1,

1980 Norman A. Coll, Esq.

McCarthy; Steel Hector

5. Davis First National Bank Building - 14th Flr.

Miami, FL 33131 Jack R.

Newman, Esq.

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. Harold F. Reis, Esq.

Lowenstein, Newman,'eis, Axelrad 5 Toll 1025 Connecticut

Avenue, NW.

Washington, DC 20036 Martin Harold Hodder, Esq.

1130 Northeast 86th Street Miami, FL 33138 James R. Tourtellotte, Esq.

Counsel for NRC Staff U.S. Nuclear Regulatory Commission Washington, DC

'20555

Subject:

. In the Matter of'lorida Power 5 Light Company {St. Lucie Plant,

'nit 2), Docket No. 50-389 CP

'entlemen:

Sincerely, I

This is to inform you that Commissioner Hendrie has requested the Commission to reconsider its decision not to review the Appeal Board's decision in ALAB-603.

The basis for this request is explained'in the enclosed copy of Dr. Hendrie's memorandum of November 26, 1980 to the other Commissioners.

Also enclosed is a copy of a staff memorandum of November 10, 1980 which was not available to the Commission when it was considering whether to review ALAB-603, but which raises significant questions regarding the potential effects of that decision on the regulatory process.

For your convenience, I

have also included the other documents referred to in the above-mentioned memoranda.

The Commission has until December 13, 1980 to decide whether to reconsider ALAB-603, and you will be informed of its decision.

Samuel J.

ilk Secretary of th Commission

Enclosures:

1.

Memo, 8/20/80, Ahearne to Dircks 2.

Memo, 9/26/80, Denton to Ahearne 3.

Memo, 10/24/80, Ahearne to EDO 4.

Memo, 11/10/80, Denton to Ahearne 5.

Memo, 11/26/80, Hendrie to Ahearne, Gilinsky, Bradford

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$ y~~4 CHAIRMAN UN!TED STATES UCLEAR REGULATORYCOMMI Dbl WASHIHGTOM,D. C. 20555 August 20, 1980

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~,I 4 NEHORANDUN FOR:

William Dircks, Acting Executive Director for Ope'ratio FROM:

SUBJECT:

L John Ahearne STATION BLACKO In ALAB-603, the Appeal Board has concluded that station blackout should be a design basis event for St. Lucie Unit 2.

The Board goes on to say that such a result might also be appropriate'for most reactors and recoIlmends the Commission take expeditious action to ensure plants and operators are equipped to accommodate such an event.

Please review the current status of Task Action Plan A-44 in light of ALAB-603 and provide the Comnission with your comments'by September 15.

cc:

Commissioner Gilinsky Commissioner Hendrie CoIImissioner Bradford OGC OPE

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UNtTED STATES NUCLEAR REGVLATORY COViVilSSlON ViA,SHINGTOM,D. C. 20555 CwP p 0

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¹MORANDUli FOR Chairman Ahearne.

FROM THRU:

Harold R.. Denton, Director Office of Nuclear Reactor Regulation fSigmd> Y~'ilhzm J Dirc',illiam J. Dircks, Fxecutive Director for Operations SUBQiCT:

STATION BLACKOUT

- This memorandum is in response to your request dated August 20, 1980, concerning the current status of Task Action Plan A-'44 in light of ALAB-603.

In ALAB-603, the Appeal Board made specific. findings regarding St.

Lucie Unit 2, and recommended that the Cotmission take expeditious action to ensure that other plants and operators are equipped to accoimodate a station blackout event.

This would include items such as a thorough analysis of the plant behavior during the blackout period, development of writ, en procedures, an'd operator training for safe operation of the

.facility and restoration of AC power.

The Office o< Nuclear Reactor Regulation is currently evaluating the necessary actions for implementing the Appeal Board recommendation.

This effort will require contribution from several divisions, and it. is expec.ed that several weeks will be required to.develop a position for operating reactors and OL's under review.

1'e will report the results of this evaluation to the Conmission in approximately one month.

Mith regard to St. Lucie Unit 1, as a result of ALAB-603, we are requiring ti;at.the licensee implement actions similar to those required on St.

Lucie Unit 2.

Contact:

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Paul

Norian, NRR 49-294D7

Chairman Ahearne 0

The station blackout issue is also being considered under Task Action

'Plan A-44 which was approved in July 1980 with a scheduled completion date of October,1982 (copy attached).

Section 3 of TAP A-44 remains valid and provides the basis for continued plant operation and licensing pending completion of the action plan.

The purpose of TAP A-44 is to evaluate the adequacy of current licensing design requirements to assure that nuclear power'plants do not pose an unacceptable risk of a station blackout accident.

The first effort scheduled for completion in the program involves the reassessment and documentation of a preliminary survey conducted in October 1979.

The intent of this survey was to identify any operating plants having an exceptionally high probability of station blackout accidents.

The preliminary staff effort found that there were no currently operating plants of. unusually high susceptibility to a severe core damage accident resulting from a station blackout.

To take bette accourit of analytical uncertainties, it was decided to

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refine the survey.

The updated assessment is scheduled for completion

in the last quarter of 1980.

-The longer term portions of the task action plan involve extensive use

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of reliability and risk assessment studies; much of this work will be performed by contractor personnel.

The task action plan includes a

detailed ana,lysis-of AC power supply. reliability, an evaluation of

.potential accident sequence probabilities and consequences, and plant response analyses.

A contract was recently placed with Oak Ridge National t ~RIIA!~ '~

'~~Ca and accident sequence analysis tasks.

Also, preliminary plant response

.:analyses for several station. blackout accident scenarios are underway by the Division of Water Reactor Safety Research.

I In summary, the board recommendation for expeditious action is being

. considered by the current NRR evaluation of actions needed for operating reactors.

The results will be.reported to.the Commission next month.

We believe that the longer.'ange. generic aspects of the ALAB-603 recommen-dations are addressed appropriately'n Task Action Plan A-44.

The tasks under TAP A-44 are continuing as scheduled at this time.

Enclosure:

Task Action Pl a~-.44=---'

Harold R. Denton, Director Office of.Nuclear Reactor Regulation cc:

Commissioner Hendrie Commissioner Gilinsky Commissioner Bradford GC

. PE MCY

TAP A-44 STATION BLACKOUT g ~

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I Lead Responsibility:

Lead Supervisor:

Task Hanager:

NRR Lead Supervisor:

NRR.Lead Reviewer:

Appl s cabil s ty.

Projected Completion Date:

RES -

PAS G.

E. Edison P.

M. Baranowsky K. Kniel P. J.

Polk All BWR and PMR October 1982

l.

DESCRIPTION OF PROBLEM A.

Statement of Issue The complete loss of AC electrical power to the essential and non-essential switchgear buses in a nuclear power plant is referred to as a "Station Blackout."

Because many safety systems required for reactor core decay heat removal are dependent on AC power, the consequences of a station blackout could be a severe core damage accident.'herefore, the l

technical issue is ('a) whether the probability of a station blackout may be too high,. and (b) what the consequences of a station blackout are; that is, whether severe. core damage may result.

B.

Background

The issue of Station Blackout arose because of the historical experience regarding the reliability of AC power supplies.

A number of operating plants have experienced a total loss of offsite electrical

power, and mare occurrences are expected in the future.

During each of these loss of offsite ~wer events, the onsite emergency.

AC power supplies'ere. available to

.supply the power needed by vital-safety equipnent;- However,-.

in some instances, one of the redundant anergency power supplies has been unavailable.

In addition, there have been numerous reports of emer'gency diesel generators failing to start and run in operating plants.

The results of the Reactor Safety Study showed that for one of 1

t the two plants evaluated, a station blackout accident could be an important contributor: to the total risk from nuclear power plant accidents.

Although this total risk was found to be small, the relative importance of station blackout accidents was established.

This finding and the historical diesel generator failure experience raised the concern about Station Blackout to an unresolved safety issue.

C.

Purpose The purpose of this Task is to evaluate the adequacy of current E

licensing design requirements to assure that nuclear power plants do not pose an unacceptable risk of a station blackout accident.

The NRC safety design requirements applicable to station blackout can be grouped into three categories: "-

1.

reliability of the offsite AC power supplies; 2.

reliability of the-emergency AC power supplies; and 3.

capabiIity of pIaota to remove decay heairvith.AC=pose~~~~~

'supplies unavailable.

Appendix A to 10 CFR 50 defines a total loss of offsite power as 'an anticipated occurrence (Category 1 above).

As such, it I

is required that an independent emergency onsite AC power supply'e provided at nuclear plants.

It is further required by NRC safety criteria that electric power for safety systems at nuclear plants. be supplied by at least two redundant and

iadependent divisions (Categories 1

and 2).

Each electrical division for safety systems includes an offsite AC power connection, an onsite emergency AC power supply (usually a

diesel generator),

and DC power sources..

Those safety systems required to remove decay heat from the reactor, core following shutdown are required to have available these diverse AC power supplies.

Surveillance requirements include periodic testing for emergency diesel generators (Category 2) and other related electrical equipment.

Additional requirements are that diverse power drives and supporting systems independent of. AC power must. be provided for one emergency feedwater train in PHRs (Category 3).

The design practice for BHRs is to include at least one decay heat removal system (e.g.,

Reactor Core Isolation Cooling) driven by a source independent of AC power (Category 3).

2.

PLAN FOR PROBLEM RESOLUTION A.

Approach II

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Technical anal ses in all three of the above cate o

r eliabil ity of.-;emergency

-AG power-supply;-,"This=is"justified-by several considerations.

First, the questions raised about category 2 were basically responsible for identification of Station Blackout as a safety issue.

Second, if safety improvements are required, it will be easier to analyze and identify them and implement them in category 2 rather than in categories 1

and 3.

For example, offsite power reliability (category 1) is dependent g ries are planned for this task;

.f6wever, the principal focus vill. be on" category 2,--

oR a number of factors which are difficult to analyze and M

control, such as regional electrical grid stability, weather phenomena, local industrial and ~pulation growth, and repair and restoration capability.

Also, the capability of a plant to'ithstand a station blackout {category 3) would require many decay heat removal-related

systems, components, instruments and controls to be independent of AC power.

These will vary from plant to plant, requiring considerable effort to analyze all of them and to assure that the plants indeed have that capability.. Third, some progress has been made in category 3.

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A significant improvement is underway for all operating PMRs 4

by backfitting the auxiliary feedwater system to make it independent of AC.power.

Thus, the reliability of emergency AC power supplies is of principal importance to this task.

During the development of this task. action plan, a preliminary screening analysis was begun to identify plants most likely.to.

suffer core damage due to a loss of all A.C. power supplies.

The intent of this work was to survey the 'frequency and impli-

"cation"'of station'blackout:accidents-in operating plants"ahd--'"-

'dentify any especially high risk plants which might require further analysis or action on an urgent basis.

Initial results showed no such plants.

Completio'n of this task is the first step in resolving this issue.

~

~ A'more detailed evaluation of station blackout concerns will '

follow the completion of the prelimi.nary analysis.

It is recognized that this issue is centered around a concern for the adequacy of A.C. power, supply reliability, 'especially for emergency onsite AC power supplies.

As such, this area will comprise the major program effort to resolve this issue.

Typical offsite and emergency A.C. 'power supplies will be evaluated including a review of past operating (failure) experi'ence.

This effort is limited to ~wer,supply ava~lability and will not include an evaluation of power, distribution network'dequacy or power capacity r equirements

'n order to provide a consequence perspective, tasks to evaluate station blackout 'accident sequences and associated plant response analyses are included.

The Interim Reliability.

Evaluation Program (IREP), which will be carried out concur-rently with this program, will be used as a primary infbr-

'ation source. in developing the shutdown cooling reliabHity models and accident scenarios needed to perform these tasks.

Upon completion of the technical evaluation tasks, a regulatory position will be developed for review and comment.

'A NUREG report documenting the technical studies of this program and final regulatory position will be published.

B.

management of Work The res~nsibility for carrying out a program to resolve this issue was transferred to RES by memorandum dated July 13, 1979, from the Director of HRR to the Director of RES.

The l

Probabilistic Analysis Staff of RES will provide the program management;

however, NRR will remain cognizant through assignment of liaison personnel and participation in subtasks as identified in this TAP.

In addition, hRR has the r'esponsibility of P

obtaining and'providing to the task manager operating experience information required from licensees as identjfied in this plan.

NRR also has the res~nsibility of tak'ing licensing related actions on station blackout issues during the conduct of this program.

C.

Tasks 1.

Preliminary Screening Analysis of Operating Plants A probabilistic. safety assessment. will-be performed and documented to provide a preliminary evaluation of station blackout accident sequences at operating nuclear power--

plants;.

The purpose of thi~rk. will"-beM:. effectuatem screening analysis to identify any plants of unusually high susceptibility to station blackout and subsequent core damage.

As may be necessary, safety improvements in design and operation will be identified.

w7w A.C. Power Supply Reliability Evaluation Failure nodes and reliability analyses will be performed for typical offsite and anergency A.C. power supplies.

These analyses will include an indepth examination of the potential

causes, frequency, and duration relationships for station blackouts.

The A.C. power supply reliability

~ subtasks wil-1-include:

, 2,1 A.C. power supply design reviewTypical offsite and emergency A.C. power supply configurations will be 1

identified and'enerically grouped'.

Consideration I

will be given to type of power source,, line diagrams showing redundancy and swi.tching, plant systems supplied by each bus/division, AC power dependence on DC power,.and operational characteristics.

2.2 A.C. power supply operating experience review The operational experience regarding loss of offsite r

power and emergency A.C. po~er. supplies..(par.ticularly diesel generators) will be reviewed.

This will include the identification of data 'needs and the" collection of the information.

Knowledge gained from previous studies of offsite and emergency AC power supply reliability will be included.

The intent of this task is to obtain enough operational experience o

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c information to allow the construction of meaningful reliability models with due consideration to the limitations of such models.

2.3 Reliability of A.C. power supplies A reliability analysis of the typical A.C. power supply confi-gurations will be performed.

Both offsite and onsite power supplies will be nadeled with special consideration given to interactive and,common cause failure aodes, including those induced by human 1

error.

The effect of regional and, local factors on the loss and recovery of A.C. power will be considered

~

where possible.

Aspects of design and operation which have the potential to improve A.C. power supply reliability will be identified and the amount of improvement will be estimated.

Design and operational recommendations to assure AC power supply reliability will be developed.

3.

Accident Sequence Analysis...

An investigation into the probability and consequence of station blackout accidents will be conducted through both.....

generic and plant specific studies.

The insights gained from the IREP will be used to enhance the limited detail of the generic evaluations.

These studies will include-the reliability of shutdown cooling systems given a loss of A.C. power supplies, an evaluation of the hazards, posed by extended blackouts, and reactor coolant inven-tory requirements during station blackouts.

These considerations will be coupled with 'the results of Task 2 to identify a generic set of dominant station blackout accident scenarios.

The subtasks for this evaluation will include:

3.1 Accident sequence reviewEvent and fault tree

, analyses will be reviewed to identify dominant station blackout sequences, failure rodes, and consequences.,

These will include;the Crystal River 3 analyses and, if available, the first six plant group of IREP.

This information will,supplement that currently available from the Reactor Safety Study and follow-on studies.

1 3.2 Shutdown cooling reliability A generic review of systems and components used for shutdown cooling'ill be performed to identify'.C; power dependencies and requirements, adequacy of A.C. independent

systems, and the-reliability 'of these'systems.during:--

a station blackout.

The system reliability results obtained from accident sequence reviews will be factored into this subtask.

3.3 Generic accident sequence evaluation A set of generic'vent trees will be developed and the dominant station blackout accident scenarios will be characte'ri'zed.

The probability and consequence of these scenarios will be used to provide a simplified risk perspective.

This information will be used to establish acceptable requirements for AC power supply reliability'and decay heat removal capability for station blackout.

4.

Plant

Response

to Station Blackout.

,. Reactor coolant system response analyses will be performed I

for station blackout accident scenarios.

Typical HSSS designs (at least one for each LMR vendor) will be analyzed to provide an estimate of the core damage times and to determine the important operational characteristics associated with these accidents.

The subtasks for this work are:

4.1 Develop plant response models-'-Generic and plant specific response characteristics will be conside'red in the development of analysis models for each LMR vendor.

A preliminary and simplified event tree and accident scenario list will be used to determine the-

'odeling requirements.

thdels will be best estimate where possible using existing computer codes.

4.2 Analysis matrix An initial accident analysis matrix will be developed from simplified event trees.

The accident sequence evaluations of Task 3 and initial accident sequence analysis results will be used.to revise the accident analyses matrix into a final set of plant response analyses which will provide a

characterization of reactor thermal response for station blackout accidents.

4.3 Plant response analyses Analyses will be performed for each LHR vendor NSSS.to assess the time dependence and consequences of station blackout accident sequences;.

i.e., mitigation by adequate core cooling or damage I

to the core and possible melting.

,These 'results P

will be reviewed to identify important system or component avail abil.ity and operational characteristics, including operator actions.

5.

Licensing Requirements The results of Tasks 1-4 will be used to develop any licensing requirements which may be needed to resolve

'this issue.

. Upon completion of Tasks 2-4, a

recommended revision or reaffirmation of current licensing requirements will be provided; 'The development of a draft HUREG covering the conduct and conclusions of this program and appropriate internal and public review of the draft report are"included in this task.

D.

Schedule The following schedule has been developed for the completion of the major tasks of this program:

l.

Interim Study Draft report Final report August 1980 October 1980 2.

AC Power Reliability Power supply design review Operating= experience evaluation Reliability evaluation February 1981

.August..1981-December 1981 3

Accident Sequence-Analysis IREP.'eview Shutdown cooling reliability Accident sequence evaluation April 1981 August 1981 January 1982 4.

Plant

Response

to Station Blackout Plant response models Analysis matrix Plant response analyses December 1980 February 1981 June 1981.

5.

Licensing Position Internal-Peer Review March 1982 Draft position (draft. NUREG)...,....,

May 1982 Final position (NUREG approved)'-'-:; --"-:

October 1982."- ' '-

3.

BASIS FOR CONTINUED PLANT OPERATION AND LICENSING PENDING COMPLETION OF TASK As stated in Section 1, the purpose of this task is to evaluate the adequacy of current licensing design requirements regarding the risk of a station blackout accident resulting in unacceptable core o

damage:

In particular,.the adequacy of emergency AC power supplies t'eliability has been questioned.

The current licensing criteria require licensees to provide redundant emergency AC power supplies, to demonstrate emergency AC power supply reliability (R.G. l.108),

and to include the capability of removing decay heat using at least one shutdown cooling train independent of AC power.

In the event of 'a total loss of AC power at PMRs, the auxiliary feedwater.

(AFM) system can provide a heat sink via the steam genera-tors to remove the core decay heat.

Since the TNI-2 accident and I

subsequent studies further highlighted the importance of the AFM

systems, the Bulletins'and Orders Task Force performed a review of these systems foor operating Combustion Engineering and Mestinghouse designed PWRs.

The objectives of this study were to:

(1) identify necessary changes in AFM system design or related procedures to assure continued safe operation, and (2) to identify other system characteristics in the-AFM system design of. these plants which. on--

a long term basis, may require system mdification.

Based on this r

study, the Bulletins and Orders Task Force made a number of recom-

.mendations 'to'mprove..the rel iability-"of. the'- AFM"systems."=-Some=of

'~.

these recommendations were specifically made to cover the concern for the total loss of offsite and onsite AC power.

For the near term, the Bulletins.and Orders Task Force required that as-built-plants be capable of providing the required AFM flow for at least 2

hours from.one AFM pump train independent of any AC power source.

For the long term, it is required that this function be performed automatically in addition to various other improvements.

The near.;

tern recommendation has been met for vast CE and Westinghouse PHRs; the long term improvements are scheduled to be completed by January 1, 1982.

The reliability of the AFW systems for the Babcock and Wilcox operating PWRs was reviewed as part of the Yiay 1979 shutdowns for these plants.

This review resulted in various short-term system and emergency procedure aadifications.to improve the availability of these systems.

A more systematic reliability review of these plants is now in progress.

These plants will also be required to

'eet the long term requirements discussed above.

Boiling water reactors contain various systems to remove core decay heat following the total loss of AC power.

These systems include the isolation condensers on BWR/1 through BWR/3 plants and the steam driven high pressure coolant injection (HPCI) and reactor core isolation'cooling (RCIC). system.

For. BWR/1, BWR/2 and early-BWR/3 pl.ants, the isolation condenser will provide an adequate heat sink for a minimum of 40 minutes'.

For other BWRs, adequate cooling can be maintained'.%r-~pproxamately 2.hours=.-'=The Bulletins and"-'-;..-

Orders Task Force did not require any specific improvements for these systems following its review; however, a review of BWRs is included in this study.

In addition to the above, a preliminary study of operating plants

'was performed to assess plant vulnerability using probabilistic g ~

B.

Division of Systems Interaction.

Provides 'review and comment on the technical evaluations provided by=the Task Manager in the areas of instrumentation.and control;. electrical and power systems; reactor and auxiliary systems, and systems interactions.

DSI will provide assistance in the identification of design and operational characteristics of AC power supplies and I

systems required'or shutdown cooling.

In addition, DSI will contribute to the formulation, review, and approval of interim and final'icensihg positions.'

Manpower requirements Instrumentation and Control Systems Branch '

0.05 my Power Systems Branch 0.10+

my Reactor Systems Branch 0.05 my Auxiliary. Systems Branch 0.05 my Systems Interaction Branch 0.05 my

• reflects PSB responsibility directly related to station bl ackout C.

Division of Human Factors.

Provides review and comment on '.

-'hose technical. evaluations involving man/machine interfaces.

In this area, DHF will contribute to the. formulation,-..review,--

and approval of. interim and final-licensing positions. -..-

Manpower requirements Human Factors Engineering Branch Procedures and Test Review Branch 0.05 my 0.05 my D.

Division of Safety Technology.

Provides liaison between NRR and

PAS, and provides general assistance in the coordination of activities performed within NRR which are part of this Task Action Plan.

DST has primary res~nsibility for the initial

~

4

~ r C'review of draft licensing recommendations and for coordination' of the internal management and public review process required to adopt the final licensing positions.

DST will also coordinate the formal revision and publication of licensing documents (i.e., regulatory guides, standard review plan, etc.) with the Office of Standards Development.

Manpower r equirements

'eneric Issues Branch

. Licensing Guidance Branch

- Reliability and Risk Assessment Branch 0.20*

my 0.05.

my 0.05 my

• reflects GIB overall coordination responsibility 4

6.'ECHNICAL ASSISTANCE, Direct technical assistance to the program will be required for Tasks 2 and 3.

Funding will be provided by the Office of Nuclear Reactor Regulation.

Technical assistance requirements for Task 4 will be developed and funded directly by the Division of Reactor Safety Research, RES. -:-The following is a brief description of the technical assistance required for Tasks 2 and 3 for this program.

-A.

Offsite Power Reliability 1.

Contractor - to.be selected.

2.

NRC managing organization - PAS (RES).

3.

Scope - Identify initiating events which can cause a los's of offsite power,. evaluate the expected frequency-,-and determine.dominant factors affecting the reliability of offsite ~wer supplies and the recovery, of offsite power;,"

This will include consideraion of power supply and circuit configurations, operational characteristics (technical specifications, limiting c'onditions of operation, operating procedures, human interactions),

and location dependent factors (multiple unit sites, proximity to alternate power.-supplies, regional grid reliability).--In the context of these considerations, operating experience d'ata wi11 be evaluated, reliability models will be developed, and reliability estimates will be provided.

Features which may improve the reliability of offside power supplies will also be evaluated.

4.

Funding requirements - 4150K.

B.

, Bnergency A.C. Power Reliability 1.

Contractor - to be selected.

2.

NRC managing organization - PAS (RES).

3.

Scope - Identify range of emergency A.C. power supply design configurations'sed at: huclear-pow'er-plants Collect and analyze operating experience data.

quantify probabilities of dominant energency

~wer supply failure modes.

Review ex'perience at several operating nuclear plants.

Review emergency power. supply gael.iability experience..-

from other applications such as DOD and FAA.

Develop

~ /

~

~ "'predictive; reliability models for emergency A.C. power supplies including component and design differences, operational characteristics, and power supply recovery from failure.

Identify practical rel iability improve-ments and quantitative reliability goals.

Earlier NRR qualitative studies and other studies will be reviewed

. and incorporated. Estimate reliability increases ~ssible----

and associated costs.

I W 4.

Funding requirements - 5300K.

C.

Station Blackout Accident Sequence Evaluation'-~-

1.

Contractor - to be selected.

2.

HRC managing organization - PAS (RES).

3.

Scope - Develop generic event trees, characterize dominant accident scenarios, and provide a risk/consequence perspective for station blackout accidents.

A review of IREP accident

.sequences and shutdown cooling systems reliability associated with a station blackout will be conducted to supplement the generic'v'aluations.

The results of the offsite'nd emergency A.C. power supply reliability studies will be used in'onjunction with the generic accident sequence and shutdown cooling reliability assessment to provide station blackout accident perspectives.

4..

Funding requirements - )150K.

~

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c: 7.

INTERACTIONS MITH OUTSIDE ORGANIZATIONS

. Interaction with outside organizations could include EPRI,

NSAC, INPO,

FERC, FAA, utilities, HSSS vendors,

QEs, and emergency diesel generator manufacturers.

Peer review will be conducted through.ACRS briefings and by the establishment of a peer review panel selected from outside HRC having appropriate expertise.

8.

POTENTIAL PROBLEMS The potential problem areas which have been identified are provided 4

1 below:

A.

Program. funding must be approved and obtained.

If competitive contractor bidding is necessary, the program will be delayed by approximately one year.

B.

Identification of reliability goals and translation of probabi-listic results into licensing requirements.

C.

Obtaining necessary operating experience on AC power. supplies.

D.

Uncertainty in what information will be available from IREP and on what sch<dul.e.

E.

Uaison needed between NRR and RES.

REFERENCES l.

U.S. Nuclear Regulatory Commission, "Reactor Safety Study,"

NRC Report MASH-1400, HTIS, October 1975.

2.

NUREG-0645; "Report of the Bulletins and Orders Task Force,"

January 1980.

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CH4IRM4N JNITE STATES

~IUCLEAR REGULAiORY COVih'i.ON Ye'4SHINGTOM, D. C. 20555 October 2-':,

1980

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Yi>OPS'tiDUH FOR:

FROM:

SUBJECT:

Execuii ve D1I'~cto John Aheerne SiAi!ON BLAC Vi for Operat1ons I have. several follow-up qu stions regarding ihe September 26 report on.he s<<tus of Iask Action Plan A-L4 (TifP A-L4) station

"'blackout.

Section 3 of TAP 'A-44 relied on a prel iminary s.aff study which did noi identi,y any operating plani as having an "unusually high susceptibility" to severe core damage from a station blackout.

.This criierion is not de ined.

Please. ideniify the plants for which the

- probability of sta.ion blackout is comparable

.o or. exceeds the value for-St: Lucie No. 2.

For ihese plants is there any basis for not now reouirino ihe chanoes already made at.h two St.

Luci'e Uni is, including itIe implemeniaiion of training programs and procedures or Station opel ation during a blackoui and for restoration of ac power' P1ease provide a response wi h the report referenced in the Septem-ber 26 response.

cc:

~commissioner Gilinsky Commissioner Hendrie Commissioner Bradford

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~4 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHJNGTON, D. C. 20555 Nov 1 0 1980 HEI'GRAhOUYi FOR:

Chai rman Ahearne F ROY~

THRU:

SUMECT:

Harold R-Denton, Director Office of Nuclear Reactor Regulation William J. Dircks

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Executive Director for Operations STATION BLACKOUT

.'n cur memorandum dated September 26, 1980, we presented the A-44 Task Action Plan =or station blackout (loss of all AC power events) and indicated that imlem ntation of the ALAB-603 reconzrendations was being evaluated in response to your inquiry of August 20, 1980-The purpose of this m morandum is to describe the action plan which we believe will resolve the Board's concern and to respond to your s'ubsequent foll'ow-up questions of October 24, 1980.

The A omic Safety and Licensing Appeal Board (ALAB-603) concluded that station blackout should be considered a design basis event f'r St. Lucie Unit 2 and recommended that, in view of the coaqletion schedule for Task A-44, "for nuclear power facilities with a station blackout likelihood comparable to that of St. Lucie Unit 2, expeditious'measures b

taken to ensure that these plants and their operators are equipped to accomnodate such an event in a manner that assures the public health-and safety."

Our.initial response to the Board's, decision was to atnend the construction permit. for St. Lucie Unit 2 (September 18, 1980) to require that station blackout be included as a design basis

'vent, as was ordered by the Board..

A aimilarmequirement.has been imposed on St. Lucie Unit 1; ~nder the provisions of 10 CFR Part 50.54 (f), in order o provide consistency=-in<he design. basis for-4he sister-plant.

As descri bed in %he attached m mraadum from~t~erner o-date&Amust-ZZ 1980 (Enclosure 1), the probability of station blackout is not significantly

'i,ferent between St. Lucie and all other nuclear power plants.

This asser-tion is based on theyreliminary staff study mentioned-+n-Sec~ien-3.of TAP A-44.

All plants, including St-Lucie, are comparable in station&lackout,

probability.wiihin the uncertainty band.

Me are currently updating<hat study with improved data and more careful documentation of the assumptions and limitations.

Section 3 of TAP A-44 provides the basis for continued plant licensing and operation.

The preliminary probabilistic study provides supplementary information to the Bulletins and Orderswequimments -cited-in-that section,'hich were the principal bases for continued operation.

The-extent to which station blackout should be considered in the design of all o.he.

plants, and the criteria by which it should be considered.

will be es ablished by.Task%-44..

Me have reviewed the schedule for Task A-44 and conclude that, it, cannot -be si gnificantly.@proved.

Nevertheless,'e. concur.

wi h the Board's reconmondation that som interim measures should be taken while Task. A-44 is being conducted.

Contac:

C. Grimes,'DOL X28204

I Chairman Ahearne (0 2

w Consequently, we plan to issue -the enclosed generic letter (Enclosure 2),

which requires that all licensees and applicants develop interim emergency procedures and a training program for station blackout events.

We believe that this action will resolve the Board's concern for the period while Task A-44 is being conducted.

In addition, there are some short-term system

, improvements associated with other actions'which will reduce the potential for and consequences of a station blackout event.

These are:

1 The short-term improvem nts to the auxiliary feedwater system in PMR plants associated with Task II.E.1.1 of the TNI-2 Action Plan (NUREG-0660).

These improvements are scheduled to be comp1eted by July 1, 1981.

2.

The installation of quencher safety-reliei valve discharge devices in BMR plants associated with the Nark I Containment Long Term Program.

The schedules for the Nark I-related plant modifications are described in SECY-80-359 and SECY-80-359A N

3.

The recomnendations for improvements to the emergency diese1 gen-erators which have evolved from a recent contractor study of diesel reliability (NUREG/CR-0660).

These recommendations are currently

, being. implemented on OL license applications andm program for implementation for the operating reactors, including improvements to the related Technical Specifications, is being developed.

I We believe that the development of emergency procedures and training programs,

~ as described in the enclo'sed generic letter, coupled with the stated basis for continued plamt operation-described in the A-44 Task Action Plan, are suffic-ient'o resolve-the Board's concern relative to. the ability-of the-eperating plants to accomnodate a-station blackout event.

Harold R. Denton, Director Office of Nuclear React'or%'egulation

Enclosures:

1'emorandum from R. H. Bernero to H-R. Denton dated August 22,-1980.

2-Station Blackout Generic l etter cc:

Conanssioner Gilinsky Comrissioner Heodrie Comnissioner Bradford "

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UNITED STATES NUCLEAR REGULATORY COMMlSSION lYASHINGTOH,D. C. 20555 AUG 22 580 ENCLOSURE 1

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HEHORAHDlà FOR:

Harold R. Denton, Director Offfce of Nuclear Reactor Regulatfon THRU:

Thomas E. Hurley, Actfng Dfrector Offfce of Nuclear Regulatory Research Robert M. B mero, Dfrector DfYisfon of Systems and Reliability Research Office of Nuclear Regulatory Research

SUBJECT:

ALAB DECISION 603 DATED JULY 30, 1SBO ON STATION BLACKOUT AT ST.

LUCIE UNIT 2 The purpose of thfs metIerandImI fs to offer coenents on the recent rulfng by the App a1 Board on St. Lucfe 2 (ALAS-603).

Me do not agree vith conclusfon 4, 'that a complete loss of AC powerstatfon blackout-eust be considered a design basis event for St. fucfe Unft 2.

Flaws are apparent fn ALIT-603.fn a.number'f areas:

- The cpantftatfve criterion fbr actfon.

2.

The foreclosure of.. alternatives

.to deal Hth blackout.

3.'ssumptfon tha~t. Lucfe.2 fs.exceptfonally prone to blackout.

These problem-areas are discussed. further. below.

ant'ftatfve Criterion for Action It fs clear the crfterfon of-ac~eptabf14ty-.chosen.>y ALABgp. 3l..of.

th'e decision)'s-eever-fntended by-the-staff to be applfed fn such.:

a nay.

Seetfnn 2.).3.nf the Standard Review PIan exp1fnttly ifletta the use of the-30:- crfterfon-(areas of..review).to 'accidents fnvolvfng nearby fndustrfal; mflftary, and transportation facflftfes'nd potential accf dents -fnvol v4ng..Qazardous~terfaIsmr~if vft$gs~-

the vicinity of the plant'.that 4s,toexternal hazards such as nearby transprtatfon of toxfc-gases. or-explosfves. loafs fs not to say that a probabflity goal fs not appropriate for station black- :==.--

out.

Station blackout: lends,ftself narc readily to a probabflfstfc goal than do same other.'event sequences.

Rwgve~a believe-a......:

probabflfstfc goal fn the neighborhood of 10 per plant-year Cs xere reasonable for a ~tentfal core damage accident resultfng from sta+fon blackout.

As an interim goal, f'or..say S.years, a range of 10

. to 10"

.would. entail a mfnfmal rfsk at operating reactors

Harold R. Denton pUG 2 2 580.

2.

3.

while a mre permanent probabilistic staff objective fs developed.

Indeed, improvements over the last 7 or 8 years in our knowledge of=

the sev~rfty of core damage, accidents raise the qdestfon of whether the 1D criterion might be unnecessarily restrictive even for external hazards.

Me recognfze that there exfsts no criterion 'fn the record.

so one can hardly blame the Appeal Board for somewhat arbitrarily selecting Section 2.2.3 as their basfs.

Clarification of the staff obgectfve

$ s sorely needed, and we believe this should be a top prfotfty not only for station blackout but for other important transfents such as loss of feedwater.

Foreclosure of Alternatives P

The ALAS-603 conclu'sions do not provide for what, w

think fs an acceptable alternative to making station blackout a design basfs.

~ event.

Gne alternatfve: fs to reduce the probability of a station blackout.

This could be done by improving the reliability of the.

emergency onsfte AC ~wer supply system.

For example, an additional diesel generator (with diversity, fn manufacturer, size, testing, etc.),. or a gas turbine could make significant fmprovement.

Another alternative would be an NRC-approved plan and procedures foor the restoration of offsite ~wer and emergency onsite ~wer.

Ate that ALAB assumed the probability of restoring o.ffsfte ~wer was zero and also that the probabilfty of getting one of the diesel generators started (after initiallyfailing to start) was zero.

Yet, the conclusion was drawn on page 69 that 'there fs a high likelihood.

~that Allotting station b1ackout,-a source ef AC power can be restored.-

before events resulting frottL-fts 'toss produce reactor..core damage..'=-.'-.

=.=-.-..

If the Board had.fncluded a probabildiy for.AC: power restoration, ve think {and their above-stated conclusion supports us) it could d

tt Y*1td~g-:p they& tt Al I t=

by as much as a factor of 10..Approved'AC power-restoration procedures could also signfffcantly tfmft the time interval for wh1ch9t fs necessary to assure that-the decay%eat-rival systansmre independent of AC power.

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Assumptfon Shat St. Lucfe fs Exce tionall Prone to Blackout e

'There are at least tm gotentfal major fmpacts of ALAB-603 on the --

1 fcensing process and on operating-..reactors...Ff rst;ff. the-conclusion ~

reaufrfno station blackout" to-be a design basis event at.St. Lucfe 4s accepted, then-ft surely must be applied So other operating reactop since nest are fn the-.same probability range, f.e., 10 So 10 per plant-year fbr experiencfng a station blackout.

Current estimates, of station-blackout-probabGfty, Used-on-operating

'xperience, do not confirm the premfse that Florida-based plants--

are exceptionally prone ',ta ihat event.

Compared So other plants fn

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Harold R. Denton

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the U.S, for example, the loss of offsite ~war at FIoiida plants fs only a little more frequent. {perhaps a: factor of 2) than the natfonal average.

A crude survey of operating experfence indicates'o us that there are at least 8 plant sites with narc frequent 10ss of offsfte ~wer than ~an of the Florfda plants..

'Thfs may be because different failure mechanisms such as tornadoes, ice storms, lightning, electrical demand surges, grid reliability; etc. are operating fn different geographical regions.

For example, 5e Of

'he higher frequency plants are in the midwest {tornadoes2),

two are on northern great lakes (winds, ice, lightnfng7), three are an the northeast seaboard (weather, grid ties, demand surges7) and one

~'s near the Gulf of Fhxfco (weather, grid connectfon7).

Thus, while grid reliabflf+ may be some~hat lower for Florida plants, a

number of other caus'es of power loss are rat present in Florida.

. Furthermore,. the loss of onsfte anergency AC power does not appar to be a strong function of geographical location.

Thus, Florida

~

plants (fncluding St. Lucfe Unft 2) auld not appear to have inherent faflure mechanisms of their emergency AC ~wer that are p culfar to the p nfnsular geography.

<<7 A second ~ssfble fmpact could occur if the applicatfon of the 10

.'riterion to a potential accident sequence (such as a station blackout transient)'Ns accepted; 5t might-then become"a precedent by which to )udge other transients and LOCAs. It fs likely that m current or planned commercfa1 operating reactor could m et such a

.severe crfterion..: The probability of.core damage accidents due ta other transient.and LOCkmequenees has.-freguentIyPen-estimated by HRC over the last B-years'fa.. be-fn-the.40= to=10

. range'.at-.ep rating.

relcto rs

~ In sumac, while we agree with much of-ALAB-603 and=fee'1-it's;a we))-"

written lucid presentation of the station blackout concerns, we do not -.

agree that st&ion blackout must be considered a design basis event at V. Payton, ELD

Olmstead, ELD R. Bfrkel, NRR K; Knfel, NRR

6. Edison,.RES Robert N. Bernero;- Dire tor-.

-3fvfsion of Systens-. and.-ReUahfl ftg Research Office of Nuclear Regulatory Researdf P. Baranowsky, RES F. Rosa, HRR R. Fitzpatrick, NRR P.

Check, NRR D

Ross, HRR.,

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,i ENCLOSURE 2 TO:

ALL LICENSEES OF OPERATING NUCLEAR POMER REACTORS AND APPLICANTS FOR OPERATING LICENSES l4

SUBJECT:

EMERGENCY PROCEDURES AND TRAINING FOR STATION BLACKOUT EYENTS A recent decision by the Atomic Safety Licensing and Appeal Board (ALAB-603) concluded that station blackout (i;e., loss of all AC power) should be considered a design basis event for St. Lucie Unit 2.

An amendment to the Construction Permit for St. Lucie Unit 2 was subsequently issued'on September'8, 1980.

The NRC staff is currently assessing station blackout events. on a generic basis (Generic Task A-44).

The results of this'tudy, which is sched-uled to be conpleted in 1982, will identify the extent to which design pro-visions should be included to reduce the potential for or consequences of a station blackout event..

m However, the Board has recommended that narc imnediate measures be taken to ensure that station blackout events can be accomnodated while Task A-44 is

'being conducted.

Although we believe that, qualitatively, there appears to be sufficient. time available following a station blackout event to restore AC porter, we concur that some. interim measures should be taken.

.Consequently, we require that you promptly ioqlement interim emergency pro-cedures and a training program for.the existing systems in your facility.for

. station blackout. events, if such procedures and training do not already exist.

The emergency-procedures-should consider; but are not limited to:

a. The actions and equipment necessary to maintain. the reactor coolant inventory and heat repeval with only DC power available,- including consideration of the unavailability of auxiliary systems such as ventilation and coaqonent-..coolj~

b-The estimated.3imiting tim to.restoreAC pmer.and its basis c.. The actions for restoring offsite AC power -ie-the-event of-a-loss. of the grid.

d. The actions for restoring offsite AC=power when.its. loss is due to.

postulated onsite equipment faHures.-

e.

The actions necessary to restore emergency onsite AC power.

The actions required to restart diesel generators should-include-consid-eration of the unavailability of AC.pmer.

For

example, unsuccessful-attempts to start diesel generators may result in depletion of the-corrpressed air tanks.

After repairs or adjustments, further.attempts to start the diesels may not be possible without recharging the air tanks.

In the absence of AC pater, provisions may-be-necessary for-portable air tanks, manual air pumps, DC conpressors, etc.

f. Consideration wf the availability of em rgency lighting;and-any--

actions required to provide such lighting, in equipment-areas" where- ---.

operator or maintenance actions may be necessary.

/

g.

Precautions to prevent equipment damage during the return to normal operating conditions following restoration of AC power.

For example, the limitations and operating sequence requirements which must be followed to restart the reactor coolant pumps following an extended loss of seal injection water should be considered in the recovery procedures.

The annual'equalification training program should consider the emergency procedures and include simulator exercises involving the postulated loss of all AC power and decay heat removal accomplished by natural circulation and the steam-driven auxiliary feedwater system for PWR plants, and by the stear~driven RCIC and/or HPCI and the safety-relief valves in BWR plants.

~

We require that the actions described above be completed by June 1, 1981 for the licensed nuclear power, reactors and plants licensed before that date, or prior to licensing for plants licensed after that date.

The staff's review of these actions will be accomplished as part of the implementation of the

.recomnendations-which evolve from Task A-44 and implementation of the long-term programs related to emergency procedures and training in the TNI-2 Action Plan (NUREB-0660)..

The interim procedures developed-in response to this request will eventually be placed by the final procedures which evolve from Tasks I.C.l.(3) and I.C.9 of, the,THI-2 Action Plan..

\\

Accordingly,,yursuant<o 10 CFR,50.54(f) licensees are requested-to furnish, -.- --

wi hin forty-fixe (45) days of this letter, confirmation that the implementation date of'une 1,-19Sl-will be met.

For plants licensed.after this 3etter,.these actions and the implementation-schedule will be incorporated as license con-

~ ditions.

In.the event:that-%he completion-.date cannot be.met; furnish.a proposed-revised date, just&ication.-for the..delay, and any planned-compensatiag safety actions during-the. interim...,After.-our<valuation of your.-response, the NRC staff wi 1 1 take acM on;-as-necessary to-assure tha~-such wequam.-ements. and~omi are appropriately enforceable.

-3'his:may include;.as

needed, issuance of 'a Confirmatory or. Show-Cause Order Darrell G. Eisenhut, Director Division of Licensing

W~gg REMI C

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OFFICE OF THE COhlh1ISSIONER UNITED STATES NUCI EAR REGULATORY COMMISSION WASHINGTON,D.C. 20555 November 26, 1980 SVBJECT:

MEMORANDVM FOR:

Chairman Ahearne, Commissioner GilfIIsky Commissioner Bradford FROM:

Joseph M. Hendrie./~V,i ALAB-603 (SECY-A-80-140)

On October-14th.

three of us voted'or no review on ALAB-60$ (St.

Lucie-2) and the Commission s review period ended.

.Commisssoner Gilinsky'id not participate but had indicated his preference for Commission review.

There is now running the 60-day period in which the Commission might reconsider its no-review decision..

The 60-day period will end about December 14th.,

'enton's memorandum of November 10th to the Chairman on station blackout, discussing proposed staff actions related to ALAB-603, and the attached memo from Bernero, set me to reviewing the whole business.

I conclude my vote not to review ALAB-603 was in error.

There are some generic aspects of ALAB-603 that I think the Commission should, consider very carefully.

These are the use of probability numbers in the site review section of the Standard Review Plan to determine what events should be within the design basis of a plant and the way in which station blackout is framed as a design basis event.

I solicit your votes, first to reconsider the no-review decision; and second to take review of ALAB-603.

SECY will please poll the Conmission.

cc:

SECY OGC OPE

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WITED STA'S OF A".ERICA hv'CLEAR BZGU~ ~TORY COM"HSSIOh

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"FLORIDA POVER PND LIGHT COMPANY (St.

~ucie Plant, Unit No. 2)

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Docket ho.(s) 50-389

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CERTIFICATE OF SERVICE

hereby cert' that I have this day served the foregoing document (s) pon each persotn designated on the o=ficial se vice list compiled by

.the 0=fice of the Se'cretary or the Commission

.'n ths proceeding in a"c"radance vith tne reau2rements of Section 22712 of 10 CFR Part 2-

.=.:es o= Practice, of the Nuclear Regulatory Com ission s Rules and

leguLations

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Docket No.(s) 50-389 U"ITED S

='. ES OF A~fERICA UCL AR P~Gi;LATORv C01C'EMISSION In the Hatter of

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FLORIDA PO~KR AND LTGHT COTP 4

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(St. Lucie Plant, Unit 2)

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SERVICE LIST Atomic Safety and Licensing Boa"d U.S. Nuclear Regulatory Commission

',!ashington, D. C.

20555 Dr,. David L. Hetrick Professor of Nuclear Engineer'ng The Universty of Arizona

Tucson, Arizona 85721 Dr. Frank F. Hooper School of Natural Resources University of 'Michigan Ann Arbor, Kichigan 48104 Jack R'.

Newman, Harold F. Reis, Lowenstein, Ne 1025 Connecticu

$iashington D.C Esq.

Esq.

wman, t Ave 20 Norman A. Coll, Esq.

HcCarthy, Steel, Hec First National Bank Hiami, Florida 3313

!fartin Harold Hodder, Esq.

1130 Northeast 86th Street Miami, Florida 33138 Reis Axelrad

& Toll

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036 tor

& David Building, 14th Flr.

Counsel for NRC Staff Office of the Ezecutive Legal D'"ector U.S. Nuclear Re'gulatory Commission

$~ashington, D.C.

20555

.'.ichael C. Farrar, Esq,,

Chai~a-..

Atomic,.afety and Licensing Appe-Board U.S. Nuclear Regulatory Commiss'on Pash"ngton, D.C.

20555 Florida Power

& Light Company ATTN:

Dr. Robert E. Uhrig, V. Pres.

Advanced Systems

& Technology P.O.

Boz 529100

'.iiami, Florida 33152 Richard S.

Salzman, Esq.

Atomic Safety and Licensing Appeal Boqrd U.S. Nuclear Regulatory Commission

'lashington, D.C.

20555 Dr. U.

Reed Johnson Atomic Safety and Licensing Appea'oard U.S. Nuclear Pegulatory Commissio"..

Vashington, D.C.

20555