ML19295A134

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Advises of Revised Implementation Schedules for Mark I containment-related Plant Mods.Mod Schedules & Sample Order Encl
ML19295A134
Person / Time
Issue date: 09/11/1980
From: Harold Denton
Office of Nuclear Reactor Regulation
To:
References
FOIA-81-82, TASK-CA, TASK-SE SECY-80-359A, NUDOCS 8009290504
Download: ML19295A134 (11)


Text

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September 11, 1980 SECY-80-359A COMMISSIONER ACTION For:

The Comissioners From:

Harold R. Denton, Director Office of Nuclear Reactor Regulation /

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d Thru:

William J. Dircks Acting Executive Director for Operations

Subject:

REVISED MARK I CONTAINMENT LONG TERM PROGRAM IMPLEMENTATION SCHEDULES

Purpose:

To revise the implementation schedules for Mark I-related plant modifications which have evolved since the issuance of SECY-80-359.

Discussion: The proposed plant modification schedules for Mark I containments contained in SECY-80-359 were based on comitments submitted by the affected licensees between March 1979 and June 1980. Because of increased attention to these schedules, several of the Mark I licensees have recently submitted revised proposed modification schedules. These licensee comitment changes primarily reflect changes in scheduled outage dates and to incorporate additional anticipated modifications which will be identified during the plant-unique analyses. The net effect of these changes to the total completion of the program is small, because it extends the schedules for only a few plants for what are considered relatively minor modifications.

Although plant-unique analysis work has been underway for some time and the Mark I licensees are familiar with the staff's Acceptance Criteria, there is still a considerable amount of analyses that must be completed before all of the plant modifica-tion designs can be completed. Consequently, several of the Mark I licensees have revised their comitments in anticipation of addi-tional modifications arising during the plant-unique analyses, as shown in the enclosed revised schedules. These modifications are typically associated with the supports for piping attached to the suppression chamber and the supports on internal structures.

Inasmuch as the anticipated modifications have not been specific-ally identified during the course of previous analysis work in the Long-Term Program, the licensees have proposed that these modifica-tions are of lesser safety significance (i.e., the change in the margins of safety are small) and, therefore, do not warrant more SECY NOTE:

This paper updates SECY-80-359 and require

,:senhut, DL vote by Comissioners who had voted previously.

2 800929050Y

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The Commissioners restrictive schedules or unscheduled plant shutdowns.

The revised modification schedules are predicated on estimated completion dates for the plant-unique analyses which range from mid to late 1981 and material delivery schedules based on other recent plant modifications.

A few of the Mark I plants have already completed all of the modifica-tions known at this time and the majority of the remaining plants have completed more than half of the known modifications. We have discussed the schedule revisions with the licensees and believe that they reflect the licensees' best efforts for a reasonably practical completion schedule in view of the considerations described above.

We have also enclosed a modified sample Order which more accurately describes the basis for the licensees' modification schedules. The proposed Order is "immediately effective" in order to ensure that the licensees' reassessments are completed as quickly as practical and, because what were voluntary actions would now be mandatory, to ensure that the plant modifications proceed as scheduled, rather than rely on the completion date. We recommend that the modified Order be issued to the affected licensees reflecting the revised completion schedules, with the provisions described in the footnotes, as shown in Enclosure 1.

/

k Harold R. Denton, Director 0 Office of Nuclear Reactor Regulation

Enclosures:

1.

Revised Mark I Modification Schedules 2.

Sample Order for Modification of License and Extension of Exemption Commissioners' comments should be provided directly to the Office of the Secretary by c.o.b.

Friday, September 26, 1980.

Commission Staff Office comments, if any, should be submitted to the Commissioners NLT September 19, 1980, with an information copy to the Office of the Secretary.

If the paper is of such a nature that it requires additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.

DISTRIBUTION Commissioners Commission Staff Offices Exec Dir for Operations ACRS ASLBP ASLAP Secretariat

MARK I MODIFICATION SCIIEDUI.ES 1980 1981 1982 1983 SONDJ FMAMJJAS0ND.IFMAMJJAS0NDJFMAMJJAS0NDJFMAMJJA Browns Ferry #1 XXXXXXXX Y

Browns Ferry #2 XXXXXXXX Y

Browns Ferry #3 XXXXXXX Y

Brunswick #1 XXXXXX XXXXXXX Brunswick #2 XXXXXXXXXXXXX XXXXXX Cooper XXXX XXX XXX Dresden #2.

XXXXXXXX VXXXXXX Dresden #3 XXXXXXXXX XXXXXXX Y

Duane Arnold XXXXXX XXXX XXXXX Y

FitzPatrick XXXXXXX XXXXXXX Ilatch #1 XXX XXXX llatch #2 XXXX XXXXXX Mil 1 stone #1 XXXX XXXXXXXXXX Monticello XXXX XXXXX XXXXX H

Nine Mile Point XXXXXX Y

Oyster Creek XXXX XXXX XXXX l

Peach Bottom #2 XXXXXXXX XXX Y

I Peach Bottom #3 XXX XXXXXXX Y

l Pilgrim XXXXXXX XXXXXXX 2/

Quad Cities #1 XXXXXX XXXXXXXV -

Quad Cities #2 XXXXXXX XXXXXXXXX Y

I Vermont Yankee XX XXXXX a

plant-unique P

analysis complete

?n si t11 e

Y Completion dates for external modifications.

1] Cooper: The 1982 outage is needed for drywell SRV discharge line restraints and attached piping modifications that are not completed during the 1981 outage.

These modifications are minor, relative to safety, and do not warrant extending the 1981 outage to complete them. The 1982 outage may occur in the spring, if a new turbine rotor is delivered early.

2/ Commonwealth Edison plants: The late 1982 outage for Quad Cities #2 and the early 1983 outa6e for Dresden #2 are only needed if additional internal plant modifications or external modifications requiring a shutdown are identified during the plant-unique analysis. External modification conpletion dates are based on delivery schedules for anticipated attached piping modifications and manpower availability.

The additional modifications are considered minor relative to the modifications that have already been installed or which will be installed during the upcoming outages.

3/ Nine Mile Point:

All known modifications have been completed. Any additional modifications identified during the course of the plant-unique analysis will be completed as soon thereafter as practical, but no later than December 31, 1982.

ts

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

)

)

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Docket No.

1 ORDER FOR MODIFICATION OF LICENSE AND GRANT OF EXTENSION OF EXEMPTION I.

(the licensce) is the holder of Facility Operating License No. ORP-which authorizes t licensee to operate the at power levels not in excess of megawatts thermal (rated power).

The facility is a boiling water reactor located at the licensee's site in II.

On February 28, 1978, the Coranission granted to [ INSERT LICENSEE] an interim exemption from the requirements of General Design Criterion 50, " Containment Design Basis," of Appendix A to 10 CFR Part 50 (Federal Register Vol. 43, No. 61, March 29,1978) [ NOTE: ORESDEN #2 - (Federal Register Vol. 43, No. 79, April 24,1978)] This exerrption is related to the demonstrated safety margin of the Mark I containment system to withstand recently identified suppression pool hydrodynamic loads associated with postulated design basis loss-of-coolant accidents and primary system transients.

Although there was a reduction in the margin of safety from that called for by General Design Criterion 50, the Commission found that a sufficient margin would exist to preclude undue risk to the health and safety of the public for an interim period while a more detailed review was being conducted.

ENCLOSURE 2

The Comission's evaluation was documented in the NRC staff's " Mark I Containment Short-Term Program Safety Evaluation Report," NUREG-0408, dated December 1977, which concluded that the BWR facilities with the Mark I con-tainment design could continue to operate without undue risk to the health and safety of the public while a more comprehensive Long-Term Program was being conducted.

The purpose of the Long-Term Program was to define design basis (i.e., conservative) loads that are appropriate for the anticipated life (40 years) of each BWR/ Mark I facility, and to restore the original intended design safety margins for each Mark I containment system.

The review of the Long-Term Program has now been completed.

As a result of our review of the extensive experimental and analytical programs conducted by the Mark I Owners Group, the NRC staff has concluded that the Owners Group's proposed load definition and structural assessment techniques, as set forth in the " Mark I Containment Program Load Definition Report," NED0-21888, dated December 1978, and the " Mad I Containment Program Structural Acceptance Criteria Plant Unique Analysis Application Guide,"

NED0-24583-1, dated October 1979, (subsequently referred to as NED0-21888 and NED0-24583-1) as modified in certain details by the staff's Acceptance Criteria, will provide a conservative basis for determining whether any stnactural or other plant modifications are needed to restore the original intended margin of safety in the containment design. The staff's Acceptance Criteria are attached.

The bases for the staff's requirements and conclusions are described in the Mark I Containment Long-Term Program Safety Evaluation Report, NUREG-0661.

. Since the staff has completed its generic evaluation and has determined that there are acceptable methods for assessing suppression pool nyoro-dynamic loads for all elements of the Mark I containment cesign, I have determined that the public health, safety, and interest require that such assessments be completed as promptly as practicable, and that any plant modifications needed to conform to these accepted generic procedures should be designed and installed as soon as practicable.

III.

In letters dated March 12, 1979, each BWR/ Mark I licensee was requested by the NRC to submit a schedule for carrying out an assessment of the need for plant modifications for each of the licensee's BWR/ Mark I units, based on the Owners Group's proposed generic load definition and assessment tech-niques, and for the subsequent installation of the plant modifications determined to be needed by such an assessment.

In res,ponse to our letter, the licensee's letter (s) dated [ INSERT RESPONSE DATES] indicated its commit-ment to undertake plant-unique assessments based on the Owners Group's generic assessment techniques, to modify the plant systems as needed, and also indicated that its schedule for this effort would result in a plant shutdown to complete the plant modifications by [ INSERT LAST OUTAGE DATE FOR EACH UNIT].

On October 31, 1979, the staff issued an initial version of its acceptance criteria to the affected licensees. These criteria were subsequently revised in February 1980 to reflect acceptable alternative assessment techniques which would enhance the implementation of this program. Throughout the development of these acceptance criteria, the staff has worked closely with the Mark I

. Owners Group during the development and changes to the acceptance criteria in order to encourage partial plant-unique assessments and modifications to be undertaken.

The modification schedules submitted in response to the March 12, 1979 letter have subsequently been revised to reflect the development of the acceptance criteria and additional information concerning plant modifications that will be needed to demonstrate conformance with those criteria.

In consideration of the range of completion estimates reflected by all of the affected licensees and the staff's assessment of the nature of the effort involved in the reass-essment work and in the design and installation of the needed plant modifica-tions, the staff has concluded that the licensee's proposed completion schedule is both prompt and practicable.

Under the circumstances, the NRC staff has determined that the licensee's comitment to undertake the reassessment of suppression pool hydrodynamic loads and to design and complete installation of the plant modifications, if any, needed to conform to the generic acceptance criteria by [ INSERT COMPLETION DATE FOR EACH UNIT] should be confirmed and formalized by Order, and that the public health, safety, and interest require that such Order be effective immedi ately.

IV.

The Commission hereby extends the exemption from General Design Criterion 50 of Appendix A to 10 CFR Part 50 granted to the licensee on February 28, 1978, only for the time necessary to complete the actions required by the Orcer.

Substantial improvements have already been made in the margins of safety of the containment systems and will continue to be improved during this period whenever practicable, and, in any event, all needed improvements, if any, must be completed not later than [ INSERT LAST OUTAGE DATE FOR EACH UNIT].

The Commission has determined that good cause exists for the extension of this exemption, that such exemption is authorized by law, will not endanger life or property or the common defense and security, and is in the public i nterest. The Commission has oetermined that the granting of this exemption will not result in any significant environmental impact and that pursuant to 10 CFR 51.5 (d)(4) an environmental impact statement or negative declara-tion and environmental impact appraisal need not be prepared in connection with this action.

V.

Accordingly, pursuant to the Atomic Energy Act of 1954, as amended, and the Commission's regulations in 10 CFR Parts 2 and 50, IT IS HEREBY ORDERED THAT the license be amended to include the following conditions:

1.

the licensee shall promptly assess the suppression pool hydrodynamic loads in accordance with NED0-21888 and NED0-24583-1 and the attached Acceptance Criteria; 2.

any plant modifications needed to assure that the facility conforms to the attached Acceptance Criteria shall be designed and its installation shall be completed not later than [ INSERT LAST GUTAGE DATE FOR EACH UNIT),

or, if the plant is shutdown on that date, before the resumption of power thereafter.

VI.

The licensee or any person whose interest may be affected by the Order set forth in Section V hereof may request a hearing within thirty days of the date of such Order.

Any request for a hearing will not stay the effectiveness of such Order. Any request for a hearing shall be addressed to the Director, Office

6-of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Commission, Washington, D. C. 20555.

If a hearing is held concerning such Order, the issues to be considered at the hearing shall be:

1.

whether the licensee should be required to promptly assess the suppression pool hydrodynamic loads in accordance with the requirements of Section V of this Order; and, 2.

whether the licensee should be required, as set forth in Section V of this Order, to complete the design and installation of plant modifications, if any, needed to assure that the facility conforms to the Acceptance Criteria attached to this Order.

Operation of the facility on terms consistent with this Order is not stayed by the pendency of any proceedings on the Order.

VII.

For further details concerning this action, refer to the follcwing documents which are available for inspection at the Commission's Public Document Room at 1717 H Street, N. W., Washington, D. C. 20555 or through the Commission's local public document room in [ INSERT LPDR]:

1.

" Mark I Containment Program Load Definition Report," General Electric Topical Report, NED0-21888, December 1978.

2.

" Mark I Containment Program Structural Acceptance Criteria Plant Unique Analysis Applications Guide," General Electric Topical Report, NED0-24583-1, October 1979.

~.

3.

" Mark I Containment Long Term Program Safety Evaluation Report,"

NUREG-0661, July 1980.

4.

[ INSERT LICENSEE LETTERS REGARDING MODIFICATION SCHEDULES).

5.

[ INSERT TRANSMITTAL LETTER FOR THIS ORDER].

FOR THE NUCLEAR REGULATORY COMMISSION Harold R. Denton, Director Office of Nuclear Reactor Regulation Effective Date:

Bethesda, Maryland

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