ML19332D509
| ML19332D509 | |
| Person / Time | |
|---|---|
| Issue date: | 11/22/1989 |
| From: | Tam P Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| TAC-40577, NUDOCS 8912040067 | |
| Download: ML19332D509 (13) | |
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P ORGANIZATION: NUMARC(NuclearManagementandResourceCouncil)
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SUBJECT:
MEETING
SUMMARY
- STATION 3 f(/.0MT ISSUES (TACNO.40577)
Reference:
Meeting Notice, P. S. Tam to v. F. Stloz, November 2,_1989' h!
l Th'e meeting was held on November 8, 1989, as specified in the referenced j
meeting notice.- It:was a-sequel'to the_ meeting cated October 30,1989(see l
. summa n by P. S Tam,' dated November 6, 1989). is a list of the i
,= meeting attendees,
,.m i
Before the meeting, NUMARC transmitted a draft response to the staff's draft
! generic. letter. Copies of the draft NUMARC response.were available to meeting attendees.ab0 isLincluded in this summary as Enclosure 2.
The staff provided a revised item 7 (Enclosure 3) of the draft generic letter. A second staff handout, Enclosure 4, provides sketches of acceptable and unacceptable l
alternate AC configurations for multi-unit iites, and excerpts from guidance i
' documents on emergency diesel reliability programs.
-NUMARC personnel stated that they plan to formally submit the respcases
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(Enclosure 2) in about 10 days. They also stated that NRC's concerns, as o
expressed in its draft generic letter, have received executive level attention at member utilities, and therefore proposed that NRC not issue a generic
__ letter on station blackout. The 3 additional Q&A's be issued, instead, to communicate th sta s concerns.
- 1he' staff ( A. Thadani, chief spokesman) commended NUMARC's efforts in j
reen k ing the concerns, and re-emphasized the importance of elevating the concerns to utility executive levels. The staff heard NUMARC's proposal not
- to issue a generic letter,- but the staff made no decisions in this reaard.
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'US' Peter am, Senior Project Manager T@-
Project Directorate I-4 i coul -
Division of Reactor Projects - I/II T6' N-
Enclosures:
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NOV221999 I
p ORGANIZATION:
NUMARC (Nuclear Management and Resource Council)
SUBJECT:
MEETING
SUMMARY
- STATION BLACK 0UT ISSUES (TACN0.40577)
Reference:
Meeting Notice, P. S. Tam to J. F. Stloz, November 2, 1989 The meating was. held on November 8, 1989, as specified in the referenced meeting notice.. It was-a sequel to the meeting dated October 30,1989(see summary by P. S. Tam, dated November 6,1989). is a list of the meeting attendees.
.Before the nieetibg, NUMARC transmitted a draft response to the staff's draft
. generic. letter. Copies of the draft NUMARC response were available to meeting attendees and is included in-this summary as Enclosure 2.
The staff provided a revised' item 7 (Enclosure 3) of the draft generic letter. A second staff handout, Enclosure 4, provides sketches of acceptable and unacceptable alternate AC configurations for multi-unit sites, and excerpts from guidance U
.docun.ents on emergency diesel reliability programs.
.Nul: ARC personnel stated that they ' plan to formally submit the responses (Enclosure 2) in about 10 days. They also stated that NRC's concerns, as L
Lexpressed in its draft generic letter, have received executive level attention 1
l letter.on station blackout. They proposed that (1) a NUMARC letter, (2) a
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'at nerber utilities, and therefore proposed that NRC not issue a generic L
revised NUMARC-8700 report and.(3) additional Q&A's be issued, instead, to communicate the staff's concerns.
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.The staff'(A. Thadani, chief spokesman) commended NUMARC's efforts in L
resolving the concerns, and re-en.phasized the importance of elevating the concerns to utility executive levels. The staff heard NUMARC's proposal not to. issue a generic letter, but the staff made no decisio this regard.
p Pet r S. Tam, Senior Project Manager Project Directorate I-4 Division of Reactor Projects - I/II J
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Enclosures:
As stated I
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Draft NUMARC Comments on Proposed SB0 Generic Letter The following are NUMARC comments on the draft Generic Letter general,g NRC findings from review of several utility SB0 response regardin Jn these comments sarallel those delivered verbally to the NRC staff on Monday, October 30.
Both general and specific comments are provided below.
As we discussed October 30, certain of the Staff's findings identified in the proposed GL suggest weaknesses in utility implementation of NUMARC 87-00 guidance. We believe suct finctings were foreseeable given the complexity-of the 580 issue and the plant specific nature of $B0 rule implementation.
NUMARC has' sought and appreciates this opportunity to address concerns of the Staff relative to consistent im;1ementation of NUMARC 87-00 guidance.
As a result of these discussions, NWMC will provide to industry, as necessary clarification of existing $30 guidance to ensure that NUMARC 87-00 is implemented consistently and that SB0 coping analyses are properly supported.
The envisioned NUMARC cernunication would address the concerns raised by the GL and would, we believe, cbviate the need for issuance of a
$B0 GL at this time.
We look forward to meeting with the NRC staff on November 8th to discusa y
the issues raised. Draft NUMARC corTents on the proposed GL are as follows:
fdHral Comments We find that certain of the plant specific concerns raised in the GL may have generic implications, and that NUMARC clarification of NUMARC 87-00 guidance is appropriate to advise industry of problen areas encountered.
Potentially generic concerns raiseci can be characterized as follows:
1.
instances where utilities may not have verified and documented that NUMARC 87 00 assumptions and bases are applicable to
'E their plant (s),
2.
instances where utilities have misapplied aspects of NUMARC 87-00
- guidance, 3.
instances where departures from selected aspects of the pre-approved methodology of NJMARC 87-00 were not identified and supported.
To address these concerns, NUMARC will provide a list of primary assumptions which should be verified by utilities in ordar to utilize the various portions of the NUMARC 87-00 methodology.
In addition, comon areas of utility departure from NUMARC 87-00 methodology will be identified, and utilities will be advised that such deparcures require separate supporting documentation be provided for NRC review.
Further, whene existing guidance has been misinterpreted by utilities, NUMARC will provide the necessary clarification to ensure consistent ir.terpretation.
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NUMARC will advise utilities tn reevaluate their previous submittals to NRC and consider supplementing their generic $80 responses, if necessary,-to reflect departures from NUMARC 87 C0 nethodology or to correct a misapplication of the guidance.
Certain plant specific concerns raised by the Staff, including improper credit for hurricane procedures and inadequate modificatiens (both discussad later not be), addressed in the envisioned N7%h communication to indu Two areas identified for further hmion at our scheduled November 8th meeting, (1) operability assessments for certain SB0 equipnent in less than 120F environments and AC (AAC) power systems (2) application of a sirgle failure relative to Alternate
, have consicerable generic implications. As discussed later, we are hopeful that based or fJrther disCu$sion of these areas, previously established understandirgs will be reaffirmed, and that no change to existing SB0 guidance will requiraj, jagtific Comments Item 1 Some utilities may have inappropriataly deternined their I group.
Lack of clarity of NUMARC 87-00 guidance in this area has likely caused improper determinations.
NUMARC will provide 4 communication to industry to clarify existing SB0 guidance contained in NUIMRC 87-00, Section 3.1.D.
Item 2 A) proved SB0 guidance (and therefore the rule response format) is silent on tie use of auxiliary shutdown capability for recovery from 580.
We believe this issue is limited to very few plots and is therefom not a generic con:ern.
NUMARC will recommend to utilities utilizing remete shutdown panels to identify-this aspect of their SBD coping strategy to the Staff.
We note that in the first example ci:ed by the Staff, evacLation of the main control room was only one.galign being considerec for a temocrarv coping strategy'-- pending the installation of new station batteries. "his option was not pursued.
In the other example, we do not beliem that similar evacuation of the main control room is contemplated by the utility, i
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1 tem's The Staff has identified instances where utilities have either i
Emisapplied/ misinterpreted NUMARC 87 00 methodology or did not identify and support use of alternative methodolc.gy, We believe it is important to note that NUMARC 87-00 consists of guidarce acce demonstrating compliance with the SEC rule.ptable to the Staff for Acceptable alternative methodologies certainly exist, however these generally require the utility to identify aled support departures fron the pre approved guidance of NUMARC 87-00.- NUMARC will identify common prcblem areas encountered and recommend that such departures from NUMARC 87-00 be identified to the Staff.
- Further, NUMARC will remind utilities that they may need to consider providing NRC with additional supporting information to that previously furnished in the geretic rule response, l-Item 4 i
The concern noted is believed to be linited to the utility in the example, i
and it is understood that the plant specific natter is being resolved between the utility and the NRC.
As already noted, NUMARC will reemphasize to utilities the need to identify and support departures from methodologies contained in NUMARC 87 00.
Item 5 We believe the Staff position that A C power systems must be designed to withstand an arbitrary single falltre is inap:.ropriate and inconsistent with understandings achieved between industry and NRC and reflected in approved SB0 guidance, Concerns relative to the susceptibility of a given AAC configuration to disablement by a single event are adequately addressed lay Criterion B.8.e of NUMARC B7-00 which requires that "no single point vulnerability shall exist whereby a likely weather related evel; or single active failure could disable any portion of the on site EAC or the preferred power sources and
- simultaneously fail the AAC power source (s)."
Detailed discussion of this matter was deferred to our nesting scheduled for November 8th, We consider the previously established understanding on this matter to be extremely important, and we will be prepared to discuss the issue fully on November 8th.
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Item 6 As previously stated, NUMARC intendi; to remind utilities that departures from pre approved methodology estabiished in NUMARC 87 00 need to be identified and supported.
calculations and analyses contributing to SB0 coping assessments I appropriate and properly supported. RCS inventory and suppression pool heat-up calculations are examples where proper documentation is necessary.
The example cited of the undefined ttmospheric dump valve modification
$B0 modifications. underscores the need for utilities te clearly identify and underst I
lital In general, and as previotsly s*ated, utilities using NUMARC 87-00 are expected to verify the applicability of caseline assumptions to their plant.
The Staff has indicated that such operability assessments are required for equipment rated.for service below 104F expected to operate in SBD environments up to 120F.
This'is apparently a new position that is beyond the scope of SBC guidance pertaining to the establishment of reasonable assurance of equipment operability.
NUMARC 87-00, p.2-12, notes that temperature rises of up to 120F are not expected to adversely affect operability of most SB0 equipment.
Also, NUMARC SB0 semintr responses to questions G 6 and 82 form the basis for industry understanding that operability assessmerts for SB0 equipment in environments up to 120 are not required.
Detailed discussion of Staff concerns in this area were deferred to our meeting scheduled for November 8th. We corsider previously established undarstandings
'to be extremely important, and we will be prepared to discuss.the issue fully on November 8th.
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Item 8 As stated at our October 30 :aeeting, he Staff is well aware of the coordinated industry activity on the B 56 issue. The suggestion that utility $80 responses L
have been deficient due to a lack of a documented commitnant is inappropriate.
1 Due to the on-going nature of B 56 activities on the part of the industry and NRC, we do not believe it appropriate for the Staff to seek specific utility commitments in this area at this time.
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assessing"ecuipment operability:-
y During'the site audit review,'several licensees stated that the assessment of l580 equipment operability in the control room and other areas was not required
-based sa the NUMARC'87-00 assumption that the equipment would be operable at
' a final temperature up to 120*F. However, section 1.3 of NUMARC 87 00. states:
30tilities are expected to ensure that the baseline assumptions are applicable
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Por muhi anit shes, EAC sources available from a non blacked out snit, aher asuming a single fa!!are at tbs ace blackad out anit, may be designated as Alternate AC, if they
--~ h AAC in Arc.h B and are capable of meeting the necessary si io k.ds of bah nia. " '
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I l of APPENDIX B. ALTERNATE AC POWER CRIfERIA of (e) No single point vulnerabih.y shall exist whereby a likely weather related event or single active failure could disable any portion of the onsite ernergency AC power socrees or the preferred
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power sources, and simultaneously fail the AAC power source (s).
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- C. REGULATORY POSITION.
- 1. ONSITE EMERGENCY AC POWER SOURCES (EkERGENCY DIESEL GENERATORS) i' l.2-ReliabHity Preyam
-The reliable operation of onsite emergency ac power sources should be ensured by a reliability program designed to maintain and monitor the,yeliability level t
of each power source over time for assurance that the selected reliability levels are being achieved. An EDG reliabnity program would typically be composed of the
- following elements or activities (or their equivalent):
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I GUIDELINES AND TECHNICAL BASES FOR NUMARC INITIATIVES NUMARC 37 00 3.2.4 Step Four: Determine Allowed EDG Target Reliability The minmuon EDG reliability shsuld be sargeted at 095 per demand per EDG for plants in EAC Groups A.B. C. and 0.973 per demand per EDGfor plants in EAC Group D. These ietiability levels should be conridered minmuun target reliabilities. Each plant should establish an EDG Reliability Program at outlined in Appendix D so this document.
Plants which select a target EDG reliability of 0973 should udlise this target levelin their reliability program. lf the 1
di'3*l generator performancefalls below the serget reliability level specified. acdon should be taken through an EDG 1'
'*li*bility program such as setforth in Appendix D so restore the taget reliability level.
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