ML18093B329

Forwards Generic Ltr 88-17 Re Loss of DHR During Nonpower Operation.Belief That Industry as Whole Has Not Aggressively Responded to Resolve Concern Following Identification in Generic Ltr 87-12 Stated

ML18093B329
Person / Time
Site:	Salem
Issue date:	12/02/1988
From:	Murley T Office of Nuclear Reactor Regulation
To:	Ferland J Public Service Enterprise Group
References
GL-87-12, GL-88-17, NUDOCS 8812070216
Download: ML18093B329 (7)

Text

1"*.J t--: (.).

j\\Jf**.fQ

.=:,;,=*CL

.e*4*::::

..-!()

COLO COC1

~::i:::

~(.)

("*40

()Q i'<I I:~

'...-!Cr::

ft"iQ r:6u...tl..

Docket Nos. 50-272/311 DISTRIBUTION Docket Fi1e-NRC PDR/LPDR PDI-2 Reading SVarga/BBoger Mr. J. Ferland, Chairman, President and WButler M0 1 Brien Chief Executive Officer JStone/MThadani Public Service Electric and Gas Company 80 Park Plaza, Mail Code 48 OGC EJordan BGrimes ACRS (10)

Newark, New Jersey 07101

SUBJECT:

LOSS OF DECAY HEAT REMOVAL We have just issued Generic Letter 88-17 which addresses loss of decay heat removal (OHR) during nonpower operation.

For your information a copy of the associated transmittal letter is enclosed.

This letter was issued because of the potential serious consequence of loss of shutdown cooling concurrent with significant core decay heat.

Further, it is our belief that the industry as a whole has not aggressively responded to resolve the concern following its identification in our earlier Generic Letter 87-12.

In particular, the industry's response to the Generic Letter 87-12 was deficient in the areas of (1) prevention of accident initiation, (2) mitiga-tion of accidents before they potentially progress to core damage. and (3) control of radioactive material if a core damage accident should occur.

Generic Letter 88-17 prescribes expeditious actions which should immediately ease the concern; and parallel, but longer term, programmed enhancements which effectively address the root cause of the problems and permit greater flexi-bility in operation.

We consider this issue to be of high priority and request that you assure that your organization addresses it accordingly.

Enclosure:

As stated cc w/enclosure See next page Previously concurred*

PDI-2/LA*

M0 1 Brien 11/02/88

/

rM~IDl\\ \\ t'\\~b tJJC'rutchfield tV \\188 Sincerely,

• Original signed l:Yf

• ~'.!;49llJqS E. Murle')I'.

Thomas E. Murley, Director Office of Nuclear Reactor Regulation PDI-2/D*

WButler 11/0&

¥~~;~~v rvff /BB

{\\rtrt!f(

~~&aer f(IJ/88

I Docket Mr. J. Ferland, Chair an, President and Chief Executive Offi er Public Service Electric~nd Gas Company 80 Park Plaza, Mail Code '48 Newark, New Jersey 07101

Dear Mr. Ferland:

DISTRIBUTION Docket File NRC PDR/LPDR PDI-2 Reading SVarga/BBoger WButler MO'Brien JStone/MThadani OGC EJordan BGrimes ACRS (10)

We have just issued Generic Letter 88,17 which addresses loss of decay heat removal (DHR) during nonpower operation""

This 1 etter was issued because of the pote*nti al serious consequence of 1 oss of shutdown cooling concurrent with significan~core decay heat.

Further, it is our belief that the industry as a whole has not aggressively responded to resolve the concern following its identificati~~ in our earlier Generic Letter 87-12.

In particular, the industry's response to~the Generic Letter 87-12 was deficient in the areas of (1) prevention of accide.t initiation, (2) mitiga-tion of accidents before they potentially progress o core damage, and (3) control of radioactive material if a core damage acci~ent should occur.

Generic Letter 88-17 prescribes expeditious actions wh~ should immediately ease the concern; and parallel, but longer term, programmE\\? enhancements which effectively address the root cause of the problems and perm~ greater flexi-bility in operation.

. ~

We consider this issue to be of high priority and request that you assure that your organization addresses it accordingly.

Sincerely, Thomas E. Murley, Director Office of Nuclear Reactor Regulation \\

cc:

See next page ADP DCrutchfield I

/88 t1£lt;DI-2/PM l ~Stone:mr

\\\\ I d-f88 ONRR/DD JSniezek I

/88 PDI-2/D i \\2J, ADRI WButler

~_,....... BBoger

\\, I z,,. I 88 I

I 88 ONRR/D TMurley I

/88 DRPI/I I SVarga I

/88

\\

\\. \\

\\

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Docket Nos. 50-272/311 Mr. J. Ferland, Chairman, President and Chief Executive Officer Public Service Electric and Gas Company 80 Park Plaza, Mail Code 48 Newark, New Jersey 07101

SUBJECT:

LOSS OF DECAY HEAT REMOVAL We have just issued Generic Letter 88-17 which addresses loss of decay heat removal (DHR) during nonpower operation.

For your information, a copy of the associated transmittal letter is enclosed.

This letter was issued because of the potential serious consequence of loss of shutdown cooling concurrent with significant core decay heat.

Further, it is our belief that the industry as a whole has not aggressively responded to resolve the concern following its identification in our earlier Generic Letter 87-12.

In particular, the industry's response to the Generic letter 87-12 was deficient in the areas of (1) prevention of accident initiation, (2) mitiga-tion of accidents before they potentially progress to core damage, and (3) control of radioactive material if a core damage accident should occur.

Generic Letter 88-17 prescribes expeditious actions which should immediately ease the concern; and parallel, but longer term, programmed enhancements which effectively address the root cause of the problems and permit greater flexi-bility in operation.

We consider this issue to be of high priority and request that you assure that your organization addresses it accordingly~

Enclosure:

As stated cc w/enclosure See next page Sincerely, Thomas E. Murley, Director Office of Nuclear Reactor Regulation

f.'.lr. '!* Ferland~ Chainnan, President and Chief EKecutive Officer cc:

Mark J. Wetterhahn, Esquire Conner and Wetterhahn Suite 1050 1747 Pennsylvania Avenue, NW Washington, PC

~0006 Richard Fryling, Jr., Esquire Law Department - Tower SE 80 Park Place Newark, Nll 07101 Mr. L. K. Miller General Manager - Salem Operations Salem Generating Station P.O. Box 2~6 Hancocks Bridge, NJ 08038 Mr. S. laBruna Vice President - Nuclear Operations Nuclear Department P.O. Box 236 Hancocks Bridge, New Jersey 08038 Robert Traee, Mayor lower Alloways Creek Township

~unicipal Hall Hancocks Bridge, NJ 08038 Richard W. Borchardt, Resident Inspector Salem Nuclear C:ienerating Station ll.S. Nuclear Regulatory Commission Drawer I Hancocks Bridge, NJ OP038 Richard F. Engel Deputy Attorney General Department of Law and Public Safety CN-112 State House An.nex -

Trenton, NJ 08625 Mr. David M. Scott, Chief Bureau of Nuclear Engineering Department of Environmental Protection State of New Jersey CN 411 Trenton, NJ 08625 Salem Nuclear Generating Static~

Richard R. McGlynn, Commission Department of Public Utilities State of New Jersey 101 Commerce Street Newark, NJ 07102 Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Lower Alloways Creek Township c/o Mary 0. Henderson, Clerk Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038 Mr. Bruce A. Preston, Manager licensing and Regulation Nuclear Department P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. David Wersan Assistant Consumer Advocate Office of Consumer Advocate 1425 Strawberry Square Harrisburg, PA 17120 Morgan J. Morris, III General Manager - Operating license Atlantic Electric P.O. Box 1500 1199 Black Horse Pike Pleasantville, NJ 08232 Delmarva Power & light Company c/o Jack Urban General Mana~er, Fuel Supply 800 KinQ Street P.O. Box 231 Wilmington, DE 19899

e e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 October 17, 1988 TO All HOLDERS OF OPERATING LICENSES OR CONSTRUCTION PERMITS FOR PRESSURIZED WATER REACTORS (PWRs)

SUBJECT:

LOSS OF DECAY HEAT REMOVAL (GENERIC LETTER NO. 88-17) 10 CFR 50.54(f)

Loss of decay heat removal (OHR) during nonpower operation and the consequences of such a loss have been of increasing concern for years. Numerous industry and NRC publications have addressed the subject. The Diablo Canyon event of April 10, 1987, and ensuing work by both the staff and industry organizations have provided additional insight. Yet the problems continue, as illustrated by (1) the inadequacies demonstrated by many licensees in their response to Generic Letter (GL) 87-12; (2) the event at Waterford on May 12, 1988; (3).the event at Sequoyah on May 23, 1988; (4) the DHR perturbations due to inadequate level at San Onofre on July 7, 1988; and (5} the apparent lack of a complete industry understanding of the potential seriousness of such events.

The report of the Diablo Canyon event, NUREG-1269, stated that operating a plant with a reduced reactor coolant system {RCS) inventory was a particularly sensitive condition and identified many generic weaknesses in OHR.

GL 87-12,

• which requested information from all PWR licensees, provided additional in-sight, and NUREG-1269 was transmitted with the generic letter to ensure that licensees had the latest information. Despite this, many of the responders to Gl 87-12 demonstrated that they did not understand the identified problems.

Deficiencies exist in procedures, hardware, and training in the areas of (1) prevention of accident initiation, (2) miti9ation of accidents before they potentially progress to core damage, and (3) control of radioactive material if a core damage accident should occur. Although deficiencies exist 1n all PWRs, certain design features make initiation and the time available for mitigation in the Westinghouse and Combustion Engineering designs of more concern than in the nuclear steam supply systems (NSSSs) designed by Babcock and Wilcox.

Nevertheless, we believe expeditious actions are necessary at all PWRs to rectify these deficiencies. These should be paralleled by progra111ned enhance-ments which supplement, add to, or replace the expeditious actions to accom-plish a more comprehensive improvement.

Reconmendations covering these items are susrmarized in the attachment, and additional information and guidance are provided in the three enclosures.

'8810188359 -

I i j I 2

Pursuant to 10 CFR 50.54(f), we request your response regarding your plans ~ith respect to each of the recolllllendat;ons as related to operat;on following placement of th~ NSSS on shutdown cooling, or following the attainment of NSSS conditions under which shutdo\\'tn cooling would normally be initiated. Your response is to include the following:

{l) A description of the actions you have taken to implement each of the eight reconvnended expeditious actions identified in the attachment. Your reply shall be submitted to us within 60 days of receipt of this letter.

(2) A description of enhancements 9 specific plans, and a schedule for imple-mentation for each of the six progra111T1ed enhancement reconrnendations identified in the attachment.

Your reply shall be provided to us within 90 days of receipt of this letter.

Individual deviations from the reconrnendations will be considered on a case by case basis provided compensatory measures are provided which will achieve a comparable level of protection.

No further responses are required to GL 87-12 and licensees or construction permit holders need not provide any supplemental information in a response to GL 87-1?. to which they previously corrmitted.

We will accept documents such as technical reports, action plans, and schedules prepared by industry groups when accompanied by conrnitments from participating licensees in lieu of individual documents from those licensees. Alternatively, such industry group documents may be incorporated by reference in licensee documentation.

We encourage your participation in cooperative efforts to effectively resolve these issues.

Your written response shall be submitted under oath or affinnation under the provisions of Section 182a, Atomic Energy Act of 1954, as amended.

Your written response is needed to determine whether actions to modify, suspend, or revoke your license are necessary. -n analysis as required by 10 CFR 50.109 has been performed regarding this request.

The original copy of your written response shall be transmitted to the U. S.

Nuclear Regulatory Cormiission, Document Control Desk, Washington. D.C. 20555 for reproduction and distribution.

This request 1s covered by Office of Management and Budget Clearance Number 3150-0011 which expires December 31, 1989. The estimated average burden hours is 200 person-hours-per licensee response, including assessment of the new requirements, searching data sources 9 gathering and analyzing the data, and preparing the required reports. Conments on the accuracy of this estimate and suggestions to reduce the burden may be directed to the Office of Management and Budget, Room 3208, New Executive Office Building, Washington, D.C. 20503, and to the u. S. Nuclear Regulatory Conmission, Records and Reports t1anagement Branch, Office of Administration and Resources Management, Washington, D.C.

20555.

I

~

3 If you have technical questions regarding this matter please contact Wayne Hodges at 301-492-0895. Other questions may be directed to the NRR Project Manager assigned to this issue, Charles M. TralTlllell (301-492-3121) or to the Project Manager assigned to your plant.

Attachment:

Recorrmended Actions

Enclosures:

~-~~~

~

crut'Cffff1e"l1 Acting Associate Di ector for Projects Off ice of Nuclear Reactor Regulation

1.

Overview and Background Information Pertinent to Generic Letter 88-17

2.

Guidance for Meeting Generic Letter 88-17

3.

Abbreviations and Definitions