ML19312E441

Forwards point-by-point Response to Arcs 800311 Rept Re near-term OL Requirement from NRC Action Plan Development Resulting from TMI-2 Accident

ML19312E441
Person / Time
Site:	Crane
Issue date:	04/01/1980
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Ahearne J NRC COMMISSION (OCM)
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ML19312E442	List: ML19312E441 ML19312E446
References
NUDOCS 8006040407
Download: ML19312E441 (10)

Text

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f(S/0 APR.,1 19ga MEtO?.WDU". FOR:

Chairman Ahearne FRCrM:

William J. Dircks Acting Executive Director for Operations SUSJECT:

ACRS REPDRT ON NEAR-TERM OPERATING LICENSE REQUIREMENTS Enclosed is a point-by-point response to the March 11, 1980 ACRS Report on Near-Term Operating License Items fract Draft 3 of NUREG-0660, NRC ktion Plan Developed as a Result of the THI-2 Accident.

W.:.,i T. A 3.d; Willia:n J. Dircks Acting Executive Director for Operations k

Enclosure:

as stated DA Y

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1. ' CE S C 07..E NT Part 1. Requirement (3), Item I.3.1.2, "Evaluatien of Cr;ani:ation and

anagement Im:revements of Near-Term Opera:1no License Aeolicants."

The C:::ittee is c n=erned about the specificatien as.an NTOL requirement Of an " Interoffice NRC review of licensee management to determine organi-

ati:nal and manager'al capabilities, using internal NRC draft criteria pending devele; ment of formal criteria."

If it is to be assumed that this requirement refers to utility c.anagement (rather than plant management),

then it appears that assurance of cc:petent manager.ent should be obtained as soon as feasible fer all utilities that are :perating pcwer reactors, inde;endently of NTOL activity.

Coupling this determination to an operating license (0L) appears logical only if the reactor is the first to be operated by the applicant.

The Staff has indicated that the criteria for judging canagement capability are in an early state of development.

The ACRS reccamends that due regard be given to the need for a learning period in developing and applying the criteria, and that there be a continuing effort to make tha criteria as clear as possible to these organizaations being evaluated.

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RESpCNSE The staff does not agree with this ACRS corrent.

First the Committee assumes that the requirement refers to utility canagement rather than plant manage-ment,which is not ccrrect.

The scope of the evaluaticns will include onsite and offsite organizations, both manacenant and technical, including the radiological protection organization.

Evaluation of an applicant's management and Organizatien has been a part of the staff's ncrxal cperating license revias,but not in the depth now intended.

The acditicnal review being given to the near term OLs is an appropriate interim measure fer new units, even if they are the second at a site, until the revised criteria (see Action plan Item I.3.1.1, Organization and Management long-term Improvements) have been developed.

Eecause the criteria are being used in the NTOL reviews in an early state of devel:ptent, they are act suitable to be i ediately and brcadly applied to all licensaes, nor are they being applied rigidly to the new licensees.

The SRC review of licensee management for the next few operating licenses provides 1 unipue Opportunity for a learning period in develeping and applying such cri t eri a.

This learning period shculd serve to strengthen and clarify the final criteria before they are applied to all cperating plants and all subse-

en

OL applicants.

2.

ACRS C07. MENT Fart 1, Recuirement (4), Item I.3.1.2, "Evaluatien cf Or:ani:ation and

a na cement I=:revements of Near-Term 0:eratino License Acolicants."

The 'CRS endorses the Objective of impr:ving the engineering capability tr. site, but has not studied the criteria that will, be used to qualify the gr up.

2

...e No ~;r. er.t.

The Staf: will censult with the ACRS during the final develop-ent of :ne criteria discussed in Ite: I.B 1.1.

r. :. S m...v _:n..

Part 1, F.equirement (6), Item I.C.7, "NSSS ' lender Review of Procedures."

'n'ith res;e:: to Emergency ?rocedures, the ACRS rec::: ends that Architect-Engireers (AE) or the AE ccaponent of the c;erating utility also be re-quired to review and verify the adequacy of such prc:edures in the context of ac:uracy and cc pleteness to meet emergency conditions, including the specificati:ns of actions to deal with inadequacies in the single failure c.-i t e ri en.

.......c.

n e s. u.i -

• 'e de not agree with the ACRS cc= ent at this time.

The ; resent OL review of emar;ency peccedures is being 1,imited to the NSSS vendor, since the reactor supplier has the greatest kn:wledge of the respense of the reactor to trans-ients anc the requirements for protecting the core.

Review by the AE may also 52 desirable, and as indicated in the Action Plan, the staff will decide whether to c:ntinue or expand this requirement to include procedure review by the AE after trial use in a few cases and in light of the more comprehensive long ter: program for upgrading procedures (see Action Plan Ite: I.C.9).

i;ot involving the AEs at this time also reflects cur concern that industry can-p:-er not be totally diverted to 1cw payoff activities at the expense of other activities of hicher safety significance.

Adding the AE review of procedures to the N555 vendor review w:uld not significantly increase the safety payoff cf the ra.*iew, in our current judgment.

a.

. :. S. c_..v. : h Fart 1, F.ac,uirement (7), Ite: I.C.8, "Filot :bnitcrinc cf Selected Emer ency Frt:efu es for Near-Ter: 0:eratino License A olicants.'

To ersure a;ainst relaxatien of continuous vigilance to acet emargencies, the C:.--ittee recommends nonscheduled rande: che: kin; cf :perating persen-nel in res;ect to verifying _their ability to meet ur. anticipated accident C nditi;r.s.

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It is ass;:ed the ACRS d:es not intend this be a separate NTOL requiremant.

I Fers:nnei qualification and requalificatica requirerents, including periodic simulat:r t.aining and plant drills, are addressed in cther parts of the Actica ?lan. (See I. A.2.5 and I. A.2.5.)

1 m.

_3_

Althouch the require ents for drills are nca being develcped and are not scheduled to be issued until January,1981, the current concept is that the type of drill would not be announced, but the time of the drill would be scheduled so that the shift crew could be supplemented during the drill to assure minimal effect on operations or scheduled after the normal shift.

5.

ACRS COMMENT Part 1, Requirement (11), Item II.K.1, "IE Sulletins on Measures to Mitiaate S all Ereak LOCAs and Loss of Feeduater Accidents."

This list includes some items which are useful, some which are of marginal merit and some which may, upon deeper analysis, turn out to have been wrong.

Among these that deserve care careful analysis are: (a) criteria for early RCS pump trip; (b) criteria for HPSI termination; (c) autcmatic PORV blocking; (d) several requirements that increase scram frequency; (e) subcooling meters (versur voidmeters); etc.

Each of these is a subject in itself, deserving deliberate study.

RESPC"SE a.

Ue agree with the ACRS that the criteria for early RCS pump trip deser.e further study.

The Action Plan Item 5 of Table C-3 will be revised in the next version to provide fo'r continued study of these criteria to be cc pleted by January 1,1981.

Implementation, if any, will be required by January 1,1982 instead of 1981.

b.

The current criteria for HPSI termination have been LSoroughly ana'.vzed by the staff and the HSSS vendors, who propose no changes.

c.

An overall safety assessment of the autematic isolation of the PORY is to be completea by January 1,1981 (see Item 2 of Table C-3 in the Action Plan).

To acccmodate the ACRS comT.ent, the icplementation of the requirement to install an automatic isolaticn system will be chanced frca January 1,1981 to July 1,1981 and after the studies are completed (see Item 1 of Table C-3), if the studies confirm such change to be necessary.

d.

Scre modifications have been required that have increased the fre-quency of scram of B&W plants.

However, the data n:a available indicate that the increase was nadest and the frequency of scram in S&W plants is approxir.ately that of Uestinghouse plants. The desicn sensitivity of S&W plants is being studied further (see Action Plan Item II.E.5) and design chances may be required.

Futhermore, B&W plants are free to suggest return to for er PORV control cathods with approximate safety justification.

e.

Althcugh the r,2ans of indicating inadequate core cooling are not limited to subcooling (see Action Plan Item II.F.2), subcoci;ng meters (as ccrpared to void reters) are a r.,are useful indication since they provide a e

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.4.

enticu:;s

nitoring of the c.argin (which void meters co not). Thus they indica e when cooling c:nditions are detericrating and pr:vi:e an immeciate indica-i:n cf hen thermodynamic conditions are in -he range where voids are pessible (void meters would require a significar.: void fracti:n to be present).

Investigation of the applica-ion cf other instu ents (such as gamma der.simeters in the RCS loops, neutron detectcrs for core voids, and capaci-tvo level prebes) to large reactors is c:rtinuing (See Action Plan : e: I.O. 5).

a.

eco..e c v.:.u r, Part 1, Requirement (12), Item II.K.3, " Final Rec::randaticns of S&O Task Iccce."

1. Refer tc the ACRS report dated March 11,19S0 on the Bulletins and Orders Task F:r:e raport, which documents scme of our concerns.

RESPONSE

The ;ncarns c:ntained in the March 11 ACRS repcrt en The Bulletins and Orders Task Force report are discussed individually, belcw.

c..

:: Ce.v. v e..yT Reacter C lant Pump Trip and High Pressure Injectica (HPI) Termination Criteria:

The NRC Staff has required pro.pt trip of the reactor coolant pumps in the event of a small-break LOCA. Recent transients at scre Operatin; plan s have resulted in RCP trip for ner.-LOCA events and, in scre casas, the use of the NRC approved procedures for HPI termination have res 1:ed in FORY cr safety valve actuation due to overfilline of the primary system.

The NRC Staff shculd, in conjunctica with the licensees, review the criteria for HPI termination and reactor coolant pump trip to red;;e ur.necessary challenges to the pressurizer safety valves and pre-ver.t ur.na:essary trips of the reactor coolant pumps.,hich =ay increase the difficulty in establishing uninterrupted ccre c: cling.

r-..ce a.-

See res;:7sas 5a and 55 to ACRS C ::ent 5, abcve [ Fart (1), Requirement (11),

te:II.K.1].

b.

r...g t r.

ey:a..T Feed-a.-d-Slaec Cooling of the Primary System:

At the March 4, 19SO Sub-corr.ittee rae-ing,- the NRC Staff said that there are ;resently no require-cents for the use of feed-and-bited cooling fcr decay heat rer.: val.

The Cce:it ee believes that the availability of a diverse heat remo,al path such l

3 as feed and !leed is desirable, particularly all secon ary-side ccoling is unavailable.

The ACES has established an Ad Hoc Succ:mmittee to review

nis n-er.

.......S.

-ar,a :

The staff believes that desirability of a diverse heat removal such as feed-and-bleed should be investigated and the Acticn ?lan will be revised to in-clude the develcpment of such a study.

The staff participated in an ACRS Subc:mmi: ee meeting on this subject on March 25 and will work with the

mittee to deveicp a natually ac:eptable study program.

Ec. ACRS CCPMENT Redu::icn of Challences to the PORVs in B&'.i Plan:s:

As a result of the TP.:-2 accident, the 5RC S aff has required that all 33W plants raise the 3 CRY actuatien setpoint and icwer the High-pressure reacter trip se: point in crcer to reduce the number of challenges to the PCRV.

While recent E&W :perating react:r excerience indicates that the FORY challenge rate has been reduced, there has been a corresponding increase in the number of reac: r scrams.

The Ccr.mittee notes that an increase in the scram rate increases the pr:bability of a deletericus impact en safety, and recoca. ends that the NRC Staff continue to evaluate the overall impact of the above acti:n on plant safety.

e. r.- - -.. S e

.. r.a See resp:nse 5d to ACRS C : ment 5, above (Part 1, Requirement (11), Item II.X.1]

Ed.

ACRS CCMMENT

c en-tal nreviewed Safety Question with Es;ard to Autcmatic Initiation

f :..e Auxiliary Feedsater System:

Several utilities have raised the issue f a ;: antial unreviewed safety questien with regard to automatic initiation Of the AFW system, in the event of a main steamline break inside containment.

This issue should be revisaed.

......a...

We a;ree.

Those licensass who have raised the issue of the effect of autcmatic AFW ini:iation during a main-steamline-break ac:ident have been issued letters requesting an analysis of the potential unres:1ved safety issue.

l Thesa :nalyses are scheduled to be received and reviewed by the staff by lune, '.?30 (see Acti:n Flan : tem II.E.1.2).

S

e.

n. e. : '..:... a e The Task. cree has recem: ended tha: :he tend:r c+ hecs used fcr small : rep.t LOCA analysis shculd be revi:ed, dccumented and s.::itted for NRC review, and that plan; specific cal:ulations using *P.C a >.-: ec ce:heds shovic te pr vided thereafter.

The NRC Action Plans also i cluce an ite: ani:n recermen:s that the NRC develop and issue 'a :ost i n on required c:nserva: isms in snall break calcula:icns.

The Ccemittee :elie.xs that the schedule used for deve'.::ing a et eised NRC approach to small breat calculaticns shocid, if prac-ical, be ta de c::catible with the schedule re:uired of the NS35 vendcrs f or revising their small breeak codels.

This shoulc lead to a more efficien:

use of aralyses.

This implies some increased flexibility in he schedule.

.o.c..e : u..c t.

. ~~.

Tne Eval.atien of small-break analysis uncertain-ies and conservatisms is scheduled to be :::pleted by vendors by July,1930 (See Action Plan Item II.E.2.3).

A :::issien paper on pr:pesed changes resulting f rom the evaluati:ns, if needed, is scheduled to be c:mpleted by September,1930.

The implimenta-icn of any changes can then be made censistent with the January,1.:32 schedule for revisions to vendor methods for small-break analyses (Acticn ?lan I am 31 of Table C-3).

.c

-e.

u-c e.2.: L.. v.e. a 4 we.

'iith regard to the schedule prepcsed for the imple. en:aticn of the

.reco cen:3ticas, The Committee believes that the cederly and efffective implementaticn and the appropriate level of review and approval by the i

NRC staff will require a screwhat more flexible, and in scme cases more extended, s:hedule than is implied by the Task Force reports.

. :.: : r - c ;

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..a..

Ccnsideration of the S&O Task Force recommendations in light of the other require:Ents included in the Action Plan and the limited rescurces available to 5:th the industry and staff has resulted in scme changes in schedule which are reflected in Table C.3 of Draf: 3 of the Action Plan.

Further chan;es Tay be made in the next revision of the plan.

7.

.....S..........

_ w..c.a i Pa rt 1 2.tquiricent (13), Ite: III.D.3.4, "Ccntrol Ec:: Habitabilitv."

The

• CRS c:es that this item merely sets a ;;al to "::nfirm c::pliance with exis:in; Regulatory Guides and Standard Review ?lan...."

The TMI i nci den i.di:a es that existing requirements to prctect the ccrupants of the ::,; 31 r::: against radiation may not be ade:uate, particularly with res;e:: :s 'eakage c:ntrol and arrangement of air intakes.

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'icensees anc appli: ants are new being required to pr: vide for -he accurate

.determina-icn of the airborne iodine c:ncentration in areas where plant

ersennel mi;nt be ; resent during an ac

icent and to also take ccrrective acti:ns based on a radiati:n and shielding design review to assure adect.te access te vi al areas in the event of an accident.

(See Action Plan Item

!.D.2.3)

In the len;er erm the design criteria fcr the control room area ven-ilation system will be reviesed (see Ac-icn Plan Item III.D.1.3) and tne habitabililty of c:ntrol roces under degraded core conditions will

e evalua ed in the rulemaking on degraded core consideraticns (see Ac-icn Plan :te: II.B.8).

E.

.'CRS CC".y.ENT Far 2, Requirement (45), Item I.C.1, "Short-Ter: Accident Analysis and Fr::edere Revision."

The c:cments in the first sentence concerning Part 1 Requirerant (11) regarding the need for careful analysis apply to a number of unresolved items in this requirement.

e-e.. e:

....r See Respense to ACRS Cer=ent 5, above [Part 1. Requirement (11)].

e.p.S e.n..vv.:.ih-

c..

e Part 2, Requirerent (15), Item II.E.4.1, "C ntair. rent Dedicated Penetrati:ns."

The ACRS rec :: ends that, in design and location of penetraticns for the re rbiner, the Staff pay particular attention to the pcssibility of hy-dr: gen ac:trulaticn at high points in the containment or c:n ainment

rpar! ents.

e:r. ce.

• atural diffussion and the return air fans, fan c clers or containment i

I sprays in the containren s that are nr.< required te have recembir.ers will

r

vide adequate mixing fcr the gasas which are relatively sicwly generated by radic'ytic decerpcsitica or small a :ents of retal watar reaction.

The questien of contrel f larger and :re rapidly generated ac:unts of hydr: gen sill be specifi: ally c:nsidered in the 1:ng term rulemaking on d ;raded c:res (see Acti:n Plan Ite: 11.3.3).

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30.

c Par-3, Requirement (4), Item III.A.3.1, " Role of NRC in Erargency Preparedness."

We believe tha: the respcnsibility for handling an emergency should be clear and urciluted, and should rest with the utility.

The NRC should be fully inf:rmed, prepared to intervene when necessary for the public health and safety, but sh:uld not, as a rule, take over respcnsibility in the event of an accident.

This issue rust be resolved.

- - ~...c e

....r

..e :eitsve that this issue has been resolved in c:nnection with the Commission's

r.sideraticn tf SECY 20-35 at its caeting on February 7,1930.

.. 3 CCvv.:qT 11 In c:r.sidering these catters, the ACRS also exam.ined th:se NTOL requirerents tha-ha.e already been issued in the NRC letters of September 27, 1979 and this gr:up are several requirements related to impr:ved syste:s for reasuring effluen releases. Although the Committee endorses these requirements, it believes tha: :re attention needs to be directed to assuring:

a.

That tar;1es collected are representative with er;hasis en the location and nature of the sample collector and the length, diareter, and specific nature of the samp, ling lines.

b.

The adequacy and reliability of the perform.ance of the associated sampling and c:nitoring equipment.

..e -..a. -

r:

r During the r:utine inspection program, IE Radiati:n Specialist Inspectors examine -he li:ensee's sampling sy: tems for technical adequacy, including:

a) :.evies :f as-built drawings to e t ermine c:nsisten:y with design seuire ar s as ; resented in the FLR and b) A review of the licensee's deferri ati:n :f the system sample and collectica efficiencies, particularly for :ase:us hai: gens and particulates.

The technical basis for this inspection review is :resan ed as reculat:r~v cuidance in Regulat:ry Guide 1.21, ""easuring, Evalua:ing', and Repcrting'Radicactivity in Sciid "astes and Releases of Racio-active "aterials in Licuid and Gaseous Effluents fr: 'ight-Water-Cooled "u:'. ear.::.ter Pl a nt s. " ' Reculatcry Guide 1.21 end:rses :he general principles

~

cf A*iSL 'C3.1 '9 9, " Guide to Sargling Airb rne 7.adicactive P.aterials in "uc'.sar F a:ilities" as being generally acce;:able and providing adequate bases f:r the design and c:nduct of conitoring pr:grars for airborne effluents.

The desi:n review cf these systems is addressed in Standard Review Plan, Se:ti:n fl.5, '?rccess and E'ffluen: Radiolocical "cnit: ring and Sampling Syste s", v.hich als; end:rses the ANSI N13.i Standard ar.d-calls for a syster desi;n to include pr: visions for reducing plat:-cut in sample lines.

NER will s::n issue a letter that clarifies the nee:s to assure that samples are represar.:stive and that the associated sappling and ::nitoring equip-

ent is ade:uate and reliable.

w

_c.

T.e U;51 s ar.dard provides c,uantitative guidance On system design, he eever, the ; :ential cr:blem of chemically reactive forms of radioisc;: pes, especially radi:i:dir.e. i: cnly cua.litatively ackne. ledged.

5;ecific guidance en the evalua-icn anc determinaticn of the exten; of sample have depcsition/ reactivity is n: presen ed.

The NRC li:ensing rev'iew and the IE inspecticn revies evaluete the adequacy of tne licar.see's sa gling syste:/ program.

Hesever, the pctential proble:s ess: cia ed with sample line depositen/ reactivity is an aspect of sampling that is in need of additicnal guidance and will be considered by the staff for icil mi-up evaluation.

..a.

r.e.v.v.r.h'T

, 2.

t s

The C ::ittee wishes to c:mment at this time en two items in the Action Plans in erfer :: recommend the initiation of acticns whi'ch relate to the NTOL plants.

In the C:rmittee's opinion, the issuance of an cperating license should not be c:ntir;ent :n cocpletion these matters.

In its letter of Ce:s:ber 13, 1979 on the TMI-2 Lessens Learr.ed Task Force Re;cr:, the ACRS supper:ed the Integrated Reliability Evaluatien Program

(:RE?).

M:. ever, the ACRS went en to state, "The Cccaittee coes not agree

-ha: the pr:pesed IREP will fully satisfy the need.

The ACRS recommends the: the ":.C develop a pr.: gram in which licensees, acting ir.dividually or jein-ly, develop reliability assessments of their plants in addition to the aR,.

...r. r, s.nicn would uwe per cr ed concurrently.,

The AC:.5 balieves that, en an expedited but practical schedale, the NTOL

. l a n: :...ars, as well as current licensees, should be required to perform s*.udies of the type referered to above.

i

.r.e p wg.r The de

isi:n as to the divisicq of work cn reliability assessment between the NRC and the industry will be based on the results of the initial six plant Inte; rated Reliability Evaluation Program (see Action Plan Item II.C.1)

In parallei with the six plant study, discussiens will be held with reactor corers and industry gr ups as to pessible eff:r:s by industry in IREP.

A ;a:er that discusses the alternatives is scheduled t: be submitted to the ::rr.issi:n in Octcher 1930 (see Action Plan Item II.C.2).

e.:. 5 r.~.u.v.r. I'l r

In its letter of Cecember 13, 1979, the ACRS supper:ed the rec: mendatien of the Lessens Learned Task Force concerning design features fcr c:re-damage ar.d ::re-relt accident.

The-ACRS futher recc : ended that design studies e

e G

s

. Of ;:ssible hycrogen c:n:rol and filtered-venting sys:ers for contair. en:

te re:uired frem licensees.

The ACRS also rec:rrended that special attentien be given :c making a timely decision on possible interim measures for ice-corda..s:. c:ntainments.

The ACRS recc:.: ends initia:icn of such studies for NT L plants.

.r_e:,er An ir:erim rule and notice of intent to conduc rule:aking is scheduled to be issued by July,1980.

In drafting these dccuments the staff is new

r.sidering including a requirement that licensees and applicants provide esi;n studies of possible hydrogen control and fil ered-venting systems f r ::ntainments.

(See Acticn Plan Item II.S.E.)

The staff reccamendatiens and evaluation of possible concepts for hydrcgen control in ice-condenser c r.: air.nents are presented as part of the Cc.7:ission ? aper SECY 80-107;

?r:p: sed Interim Hydrogen Control Requiremen:s fer Small Containments (See Actica Plan Item II.C.7.)

ACRS :C".M~NT The A RS has noted in previcus letters that it is important that the improve-car.:s in safety propcsed as a result of the Three Mile Island accident be c:r.sidered in a bread perspective and that other ratters of importance to saf ety receive proper priority.

The ACRS believes it important that the

iversicn cf reesources needed to deal with NTOL related activities not

r

d :e neglect of prcblem areas which shculd have a high pricrity.

The Cern;i::ee expects to ccament en this in detail when it reports on the NRC Acti:n Plans.

: c.e r., _e r_

The s: hee ling and impler-sntation of requirerents in the TMI Action plan are ising developed with consideration of the relative priority of TMI re'.a:ad and cther safety issues.

The staff is n s developing rescurce es-irates for the TMI related issues and reassigr.ed resources and adjusting s:Pe:;1es of this work and ether programs to attempt to provide an cptimum use cf the available.escurces to obtain the greatest effective increase in safety.

This informaticn will be presanted with the next revision of the

• -i:n ?lan.

c The ;:ssible diversion cf res:urces of both the staff and :he industry due to the NTOL requirements, both individually and as a whole, was carefully

sitered in ceveloping the list.

The industry cce:Ents on the list of ST:'

equirements, which were solicited at the s;;gesti:n of the Commission, als; er;hasized this c:ncern.

9 m

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