ML19338D882

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Responds to 800818 Memo Re Proposed AO Classification Re Reactor Coolant Pump Seal Failure.Event Did Not Involve Major Reduction in Degree of Public Safety & Should Not Be Considered AO
ML19338D882
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 08/29/1980
From: Harold Denton
Office of Nuclear Reactor Regulation
To: Haller N
NRC OFFICE OF MANAGEMENT AND PROGRAM ANALYSIS (MPA)
Shared Package
ML19338D883 List:
References
NUDOCS 8009240106
Download: ML19338D882 (3)


Text

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MEMORANDUM FOR: Noman M. Haller Director Office of Management

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and Program Analysis PROM:

Harold R. Denton, Dimetor. Office of Nuclear Reactor 3

Regulation L

SU80ECT:

PROPOSED ABNORMAL OCCh?.RENCE - REACTOR C00U M V

PLMP SEAL FAILURE 1

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We have reviewed your August 18, 1980 memorandum conceming the above

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subject. After careful consideration of the event at Arkansas Nuclear

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One Unit 1 (AND-1) and the NRC policy statement published in the l@

Federal Register (42 FR 10950) on February 24,1977, it is our opinion

e that this event did not involve a major reduction in the degw of

'r protection of the public he:lth or safety. Thus, this event should not be considered as an abnomal occurrence. The ANO-1 pug seal failure was a degradation of the primary coolant pressum boundary but the event was not a " major" degradation of this boundary.

'y The ANO-1 pu@ seal failure did result in a leak rate similar to a

,t saml1 break LOCA; however, the plant msponded as designed and expected k

and plant personnel reacted in an established and orderly manner. At p

no time did the reactor approach an unsafe condition. At all times, the plant shutdown was performed in a controlled manner and the margin

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to saturation was at least 100 F.

Neither fuel integrity nor the p

containment boundary were degn ded.

3 The criteria for abnonnal occurrences listed in 42 FR 10950 was 47 developed to comply with Section 208 of the Energy Reorganintion F

- Act of 1974. The intent of this Act was to keep Conqress and the i

pelic infomed of unscheduled events which the Conurission considers significant from the standpoint of public health or sefety. - The Cosmissioners defined an abnormal occurrence as an event which involves a anjor reduction in the dogme of protection of the public health or

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safety in Section 3(a) of general statement of 42 FR 10950. Appendix

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i A was pmvided to give examples of types of svents which might qualif.y <

as abnomal occurrences under the above general definition. The final determination of whether a specific event would be determined to be an abnormal occurance would depend on the specific facts and i

circumstances of the event.

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Norman M. Haller AUb 2 91980 Example II.A.2 of Appendix A is " major degradation of fuel integrity, prisery coolant pressure boundary, or primary containment boundary." ^

i The key element in this example is " major degradation" of the primary coolant pressure bounoary. The maximum leak rate fer the ANO event w s 350 gpm, which is certainly a degradation of the pmssure boundary but in itself is not clearly a major degradation.

In such cases, the umgnitude of the leakage is not the only criteria.

For example, stuck open BWR relief valves constitute a primary coolant system degradation of a greater flow magnitude than the ANO event. However, actuation of a relief valve is not considered a " major degradation" because of other factors important to public health and safety. It is these other factors tat must be considered when judging if the ANO event was an abnorw.! occurrence. Key factors include operator response (training and procedures), plant response (equipment operation) and potential consequences. Details of these aspects are provided in Enclosum 1, OEEB's evaluation, and Enclosures 2 and 3, ORAB's Operating ReactorsExperience Memorande Nos. #80-10 and #90-11, on this subject.

Consequently, it is our opinion that the ANO-1 event did not result in a major reduction in the degme of protection of the public health or safety, because the plant responded as designed in an established, safe, orderly, and controlled manner. We do, however, consider it appropriate to mport this as an Appendix C, Other Event of Interest, item.

, H. R. C:ntca Harold R. Denton, Director Office of Nuclear Reactor Regulation Enclosums:

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OEEB Evaluation l

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OREM #80-10 3.

OREM #80-11 DISTRIBUTION 5

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