ML19345E491
| ML19345E491 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 05/17/1976 |
| From: | Rusche B Office of Nuclear Reactor Regulation |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML19345E484 | List: |
| References | |
| NUDOCS 8102040670 | |
| Download: ML19345E491 (19) | |
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V UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
' En the Matter of
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ybONSUMERSPOWERCOMPANY
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Docket No. 50-155 sf
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-(. Big Rock Point Nuclear Power Plant )
NRC STAFF RESPONSE TO REQUEST FOR INFORMATION BY TF& COMMISSION In connection with its review of the exemption request by Consumers Power Company (CPCo) for the captioned facility presently pending before the Commission, the Commission, on Fby 12, 1976, requested the 6txIf to infora it promptly:
(1) whether the exemptions from requirements of 10 CFR 50.46 which Big Rock Point.n'eeds to reeume operation at the end of the current refueling outage are fairly comprised within the exemption request now pending before the Commission, as revised and amended by the applicant's letter of February 27, 1976; and (2) if the necessary exemptions are not so comprised, what steps would be necessary prior to operation of Big Rock Point to meet the Commission's legal obligations.
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Background===
On July 25, 1975, the Consumers Power Company requested (1) an exemption from the requirements of 10 CFR 50.46 to permit plant operation while bmodifications to the emergency core cooling system (ECCS) of the Big Rock oint Plant were being performed and (2) an exemption extending for the
- life of the plant with respect to the Commission's ECCS single failuie f{f
i criterion "when applie,d to the specific case of a break in either core spray line," (CP Co.'s letter of July 25, 1975, p.3).
The CP Co. letter
- Nindicated that the deficiency related to the second of the two requests
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- gias_ identified during the course of anal'; sis of the facility under the if,ECCS Final Acceptance Criteria and "only exists when the break location is selected as one core spray line and the single failure is taken as failure of the alternate core spray line valves to open".
The Commission published notice of this exemption request in accordance with 10 CFR 50.46(a)(2)(vi) (40 F.R. 37273, August.26,1975).
On December 31, 1975, the Commission granted the first of the two exemption requests, granted '
the second for a limited period until March 1, 1976,and provided the licensee with the opportunity to provide further information relevant to the second exemption request.
(CLI-75-15, RAI-75-12-847)
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On February 27, 1976, Consumers Power Company submitted information in response-to the Commission's Memorandum and Order of December 31, 1975, and requested further Commission consideration of its request for exemption-from the ECCS single railure criterion. The February 27, 1976 request was accompanied by licensee's " Report on Evaluation of Adequacy of Emergency Core Cooling System" (Report). This Report identified a number of single fillures "which'will cause failure to achieve ECCS performance within the FAC requirements" when the break location is'in the nozzle spray line or jrintheringsprayline.
(Licensee's Report, p.13).
A number of these Ib O
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singic failures were in_ components in other than the valves identified as the specific deficiency in the July 25, 1975 request.
The Commission mpeterminedthattheReportconstitutedasignificantadditiontothe
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- preexisting record and treated the February 27, 1976 request as a new Ar, exemption request.
Notice of suc'.4 request and opportunity for public comment thereon was published in the Federal Register on March ~15, 1976 (41-F.R. 10969).
On March 26, 1976, the Director of the Office of Nuclear Reactor Regulation submitted comments on the new exemption request which discussed the status of pending matters related to ECCS still under review by the Staff at that time,-and requested an extension'of time to complete comments on the Licensce's exemption request.
Additional information on a number of these matters was submitted,by the Licensee on March 26, 1976. The Commission on April 8, 1976 published notice of the extension of time granted to the Staff and of the receipt of the additional information from the Licensee, and extended the time for public comment (41 F.R. 14958, April 8, 1976).
Scope of the Exemption Request The Licensee has requested an exemption "from the ECCS single failure et terion of 10 CFR 50.46 Appendix K, Paragraph I.D.1 as applied to the specific case of a break in either core spray line."
(See 41 F.R. 10969; See also 40 F.R. 37273, CP Co's requests dated July 25, 1975 and February 27,
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}$976;andtheCommission'sMemorandumandOrderofDecember 31, 1975, RAI-75-12-847).
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it..s difficult to ascertain whether the original CP Co. request for exemption from the ECCS single failure criterion as set forth in its July 25, 1975 letter was limited to single failure of valves in one ccre 2
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- gpray line in the event of a break in the other core spray line, or.
Af, hether the valve failures were discussed as the only identified inse ince w
of a single component failure in the core spray line which, in the event of a break in the other core spray line, would necessitate an exemption from the ECCS single failure criterion. Houever, the licensee's submittal, the staff's comments and the Commission's Memorandum of December 3?,
- 975, focused principally on instances.of valve ~failt,.;
,* one core spray line in the event of a break in the other core 4f+ef line.
Subsequently, the Director's comments, submitted on January 7, 1976, in response to the Commission's request, identified the potential of other ECCS deficiencies which should be assessed in determining whether the requested life time exemption should be granted.
Among the potential deficiencies noted was possible intdequacy of the on-site power sources t
,covide for ECCS long term. cooling requirements.
Whatever ambiguity there may have been as to whether the original July 25, 1975 request covered single component failures other than valves in one co'fe spray line in the event of a break in the other core spray line, the February 27, 1976 CP Co. exemption request an'd its appended Report specifi-
[- tally identify single component failures, other than valve failures, which il 4
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result in the failure to achieve ECCS performance in the event of breaks in either core spray line.
As noted above, the Commission treated the
. February 27, 1976 requestLand its appended Report as a new exemption
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- request and provided notice and opportunity for public comment thereon.
ifAccordingly, the Staff believes that the exemption request by the licensee clearly extends to all single component failures of concern in the event of a break in either core spray line, and is not limitad only to valve failures in the alternate core spray line.
However, the February 27, 1976 CP Co. letter raises a further question as to the scope of the exemption requested. This question, which is the one at issue bi determining the proper response to the Commission's questions, t
is whethet-the request:
(a) broadly encompasses those single component failures that result.,in non-compliance with the ECCS Criteria in the event of a break in either core spray-line, and includes non-compliance resulti.s from failure of those same components when the break is in some other loc.
'.on in the reactor conlant pressure boundary, or (b) is limited to those single component failures that result in non-compliance with the ECCS Criteria only when the break is in either core spray line and excludes any non-compliance resulting from failure of those same components whdh the break is at a location other than in the core spray lines.
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1 6-The comments contained in the April 19, 1976 Comments by the Director, NRR were based.on the broader view of the scope of the requested exemption.
"the Director's broad view is also reflected in the discussion of pending it L hatters sti11'under review provided in the March 26, 1976 request for an
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-extension of time by the Staff.
The Commission's request for further information appears inclined towards the more narrow view of the scope of the requested exemption.
The Commission's-comments on p.3 of its May 12, 1976' request suggest a view that the requested exemption is limited to single compcnent failures which result in departing from the ECCS performance criteria only to the extent that such departures result from a break in either core spray line.
The questions further suggest a view that the request is not broad enough to encompass the departures from the ECCS criteria that would result from the same single failures in these same components which would also follow breaks in other locations in the reactor coolant system pressure boundary.
With this background, the specific items discussed in the April 19, 1976 Comments by the Director have been reviewed as presented below, to assess whether further exemptions from the single failure criterion of 10 CFR 50.46 wo,uld be required should a narrow rather than broad view of the scope of the pending exemption request be adopted by the Commission.
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Items Contained in the Director's Comments of April 19, 1976 1.
Single Failure of the Core Spray Valves.
.This item commented on the exemption request pertaininc to the single failure
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- pf the valves in one core spray line in the event of a break in the other
' core spray line and the considerations that arise due to breaks in the core spray-lines only. This is the exemption request specifically addressed in
-the July 25, 1975 exemption request, and is covered under either a narrow or broad view of the scope of the February 27, 1976 exemption request.
2.
Use of 900 lb Class Valves in the Ring Spray Line.
This matter has been resolved as discussed in the comment. No exemption to 10 CFR 50.46 and no other Commission action is required with respect to this item.
3.
ECCS Water,'Supp1v.
As noted in the Director's comments, active componcats o# this system are either redundant or adequately protected against single failure.
In this comment the Staff addressed concerns with potential passive component failures in the fluid portions of this system.
These concerns were addressed by the Staff to provide the Commission with appropriate perspective concerning the nature of the ECCS at Big Rock.
, However, the Commission's ECCS singl-failure criterion does not require
- .rthatsinglepassivefailuresoffl td systems be considered.
(See note 2 er
['to Appendix A to 10 CFR Part 50, " General Design Criteria.")
Although t._t e
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, specifically required by the General Design Criteria, the Staff does assess in its' review of ECCS designs the potential for damaging passive failures of
, portions of fluid systems in instances in which they may be of special safety ti ificance. As noted in the April 19, 1976 comments by the Director, the
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- sr, Staff believes that at 3ig Rock point, the fire protection system reliability has a vital bearing'on overall safety of the plant.
This in turn is of primary importance in assessing the effect of deviations _from the Commission's ECCS-performance requirements.
Therefore, while not itself specifically encompassed by the ECCS single failure criterion, the Staff has assessed the effects of passive failures of the fire protection system to enable the Cocnission to judge the overall reliability of the Big Rock ECCS, which we believe has an important bearing upon whether the requested specific deviations from the ECCS single failure requirements should be granted. Accordingly, whether either a
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broad or narrow view of the scope of the ECCS' exemption request is assumed, authorizat ion to continue to operate the Big Rock Plant unde'r the conditions related to the fire protection system proposed by the Staff does not require an exemption from 10 CFR 50.46.
4.
ECCS performance Model.
No exemption from 10 CFR 50.46 is entailed in connection with this item.
5.
Effectiveness of Nozzle Core Sprav.
t.[Due to uncertainty as to the adequacy of nozzle spray distribution, the Staff f(asproposed4.nitsApril 19, 1976' Comments that tuo conditions be fulfilled 1
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.before the plant is returned to power, unless nozzle adequacy had been properly demonstrated:
1 (a) The first condition (see item 1 en page 14 of Staff Comments) is Ikddressed to the considerations related to ECCS performance that arise only if
-in the event of a break in the core ring spray line.
For this case, the Staff recommended that the exemption be granted if the licensee showed, before return to power, that there would be sufficient ecoling water to cool the core so 4
that the peak clad temperature did not exceed the Acceptance Criteria set forth in 10 CFR 50.46, based on usi of the feedwater system and flow through the nozzle. Reliance on the feedwater system, which is powered by offsite power, requires an exemption from the single failure requirements of 10 CFR 50.46, Appendix K I.D.1, implementing 10 CFR Part 50, App. A, Criterion 35, which provides that the ECCS system shall oe capable of adequate performance using onsite power only (assuming offsite power is not available) as well as with offsite power only (assuming onsite power is not available), assuming a single failure.
Although this specific single failure mode was not addressed in the Licensee's list of single failure deficiencies contr'aed in the Report submitted with the February 27, 1976 exemption request, it would be encompassed by either th'e' broad or narrow view of the scope of licensee's exemption request discussed
' previously, since the concern related to this particular failure is limited to a
he specific case of a break in the core ring spray line.
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. i (b) The second condition proposed by the Staff-related to the
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effects of single component failures following breaks at any locations
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in the reactor coolant system pressure boundary where reflooding does
'inot provide adequate cooling, which may include breaks in the nozzle L
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isprayline.
Since the probability of breaks that would be of concern is higher when the effects of. breaks at locations in addition to breaks in the nozzle spray line is considered, the reliability of needed ECCS components subject to failure should be enhanced. Accordingly, the Staff recommanded that the exemption be granted if the licensee provides the enhanced reliability through augmented surveillance of core _ ring spray valves and valve circuits, or by other means, to provide reasonable assurance that the core ring spray system can, by itself, nrovide reliable and adequate core cooling in the event of these breaks.
Plant operation in this mode requires an exemption from the Commission's ECCS single failure requirements. However, it should be recognized that these are exactly the same valves and the same single failure defects as those encompassed by Item 1, the exemption request for single failure of the valves in the core ring spray line in th2 event of break in the core nozzle spray line.
Under Item 1, when consideration was liuited only to the event a brea5 in
.the nozzle spray line, the Staff did not specifically recommend requiring 2enhancedvalvereliabilityforvalvesinthecoreringsprayline.
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the additional' potential for breaks requiring the use of the core ring spray line, in the event that the core nozzle spray distribution is defective or uncertain, warrants the' recommendation f r enhanced surveillance of these
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, alves as part of the exemption's request, if the performance of the nozzle dpray continues to be uncertain.
Under the broad view of licensee's exemption request, the exemption required for limited operation under.the conditions *.- forth in paragraph 2 of Item 5 of the April 19, 1976 Comments would be encompassed by the pending exemption request.
On the other hand, under a limited view of the pending exemption request,.which would exclude consideration of the effects of single failures which results in deviations from the ECCS performance requirements unless the effect of such failure is caused by a break in either core spray line, the continued op,eration under the conditions set forth in paragraph 2 of Item 5 of the April 19, 1976 comments by the Director would require a specific exemption from the requirements of 10 CFR 50.46 over and above the pending exemption request.
6.
Electric Power Suppiv.
As noted in the April 19, 1976 comments by the Director, single failure of the,on-site emergency diesel generator leav2s the srstion without onsite power for long term core cooling in the event of a LOCA. This deviater from kheCommission'sECCSperformancerequirementsin10CFRPart 50, 50.46 and
!r kpendixK,paragraphI.D.1, implementing 10CFRPart50,AppendixA Criterion 35.
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The Staff noted that failure of this diesel adversely affects system performance l
for a number of events,-but agreed with licensee that this sitjgle failure
$ gas encompassed by licensee's pending request.
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.The licensee specifically identified the short term loss of the emergency diesel generator as a single failure mode applicable in the event of a.
core rint; spring line break (Report p.13, and Attachment 1, Appendix A,
-p.A-5).
It also identified this single failure mode in its analysis of single failures during long term core cooling (Report, Attachment 2).
Although it-asserted its belief that Appendix K does not require the assuuption of concurrent loss of off-site power and the emergency diesel generator, for purposes of assessing conformity te ECCS long term core cooling requirements, the licensee nene-the-less provided an assessment of the very low probability of failure of the emergency diesel to provide long term cooling (Report, Attachment 2).
The Staff noted to the licensee its belief that the lack of redundancy in the emergency diesel generator required an exemption from the single failure requirements of 10 CFR 50.46, Appendix K implementing the requirements of Criterion 35 (See CPCO's letter of March 26, 1976 and of April 13, 1976).
A1,though licensee has repeated its belief that such exemption is not required, it asserted that if required, it was already encompassed by its pending hequest for exenption from the single failure criterion in the case of a e5 fl e
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break'in eithcr core spray line (CPCO's letter of April 13, 1976). The-Staff _ believes that such an exemption is required, and agrees with the
, Licensee that it is encompassed by its pending exemption request.
It should be
'tpoted that the March 26, 1976 Ictter was specifically addressed in the notice 4r blished in the Federal Register on April 8, 1976, extending the time for
,pu submission of views ~by the Staff and extending the time for public comment.
(41'F.R. 14958)
Even if the pending exemption request is viewed narrowly, an exemption from the single failure criterion for the emergency diesel for short term ECCS performance requirements is specifically encompassed by the Report appended to licensee's February 27, 1976 exemption request (Report, p.13).
However, the need for an exemption for single failure effects on long term cooling requirements is not limited solely to the case of a break in either core spray line, but applies as well to long term cooling requirements following other LOCA breaks.
Consequently, if licensee's er.cmption request is construed narrowly -- to exclude single failures whose effects consider in. stances of breaks in other locations as well as breaks in either core' spray line -- an exemption in addition to the pending exemption would be required for the single failure of the emergency diesel in the long tetm cooling mode. The conditions that the Staff recommends on page 18 of its April 19, 1976 Comments apply cpecifically to considerations related to gong-term.ECCScoolingrequirements.
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7.
Other Electrical Failures.
,All other electrical failurcs which have a direct' consequence during a LOCA,
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,except those discussed in Item 1, are to be corrected before return to power.
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- {t.istheStaff'sunderstandingthat-thisisprogressingonschedule.
Other
-%f, failures were noted in the April 19, 1976 Comments which do not have a direct consequence on ECCS performance and do not thus involve the need for i
an exemption from 10 CFR 50.46.
However, since these mattern are important to plaat safety, the Staff has informed the licensee of its position.that deficiencies must be corrected before the end of the next refueling outage scheduled for Spring 1977. We understand the licensee proposes to mane these corrections prior to that time.
8.
Surveillance Teatability of ECCS.
This item does not re, late to a specific requirement of the ECCS performance criteria and consequc*.ly does not entail the need for an exemption to 1G CFR 50.46.
Rather, this matter relates to assuring that the availability of the various ECCS components, assumed in the various probability estimates, can be verified by surveillance and subsequently by on-line testability.
Progress on the modifications and procedural changes recommeaded by the Staff is satisfactory.
9.
Submerged Components.
t'No exemption to 10 CFR 50.46 is required for this item since all circuitry It Ishich may affect the ECCS system and uhich are required to function in the T b J
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event of a LOCA will be protected against flooding resulting from a LOCA before the facility returns to operation.
'.!The Need for Exemptions not Encompassed by the Pending Request
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((Asoutlinedabove,onlytwooftheitems(Nos.5and6)discussedinthe
' April 19,1976 comments by the Director raise any question as to whether operation of C Sig Rock Point Plant, under the conditions recommended by the Director, requires an exemption from the Commission's ECCS Acceptance Criterion,10 CFR 50.30 Sed Appendix K, not encompassed by the pending exemption.equest.
With respect to the matters discussed above in paragraph (b) of Item 5, the failure of the valves in the core spray line would adversely affect ECCS performance, under the circumstances in the April 19, 1976 comments, for breaks in addition to breaks in the nozzle spray line.
If the pending exemption request were construed to be rastricted to those single failures whose effect is limited only to instances involving a break in either core spray line, an additional exemption not eacompassed by the pending request would be required. The Staff does not believe that the licensea's exemption request should be so narrowly construed. Moreover, it should be nu.?
that in,this circumstance, if an additional exemption were to be considered needed, it would' encompass the same failure modes for the same valves as those
'b. encompassed by the exemption request discussed in Item 1 of the. April 19,
!r 7,51976 Comments.
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a With reapect to the matter discussed in Item 6, again an additional exemption for the single failure of the emergency diesel generator woul,d be required,
- ff licensee's request were te be construed as limited to those single
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- jfailures whose effect is limited only to instances involving a break in if
.either core spray line.
The failure of the emergency diesel generator during the long term ECCS cooling mode results in a deviation'from the requirements of 10 CFR 50.46 and App. K, Paragraph I.D.1 Laplementing General Design Criterion 35 for a ' number of breaks in the reactor coolant system pressure boundary.
However, the effects of a single failure of the same emergency diesel generator during shcrt term ECCS cooling was specifically enco= passed by the licensee's Report appended to its February 27, 1976 exemption request.
It is included in the list on page 13 of the Report as well as in Attachment 1, concerning short term single failures.
Also, although licensee indicated its belief that reliance on off-site power during long term cooling did not deviate from the Commission's requirements in 10 CFR 50.46, it nevertheless analyzed the single failure effects of loss of the emergency diesel in the long term cooling mode in the absence of off-site powrr to demonstrate the unlikely nature of such failure (Report and Attachment 2; See also March 26,
'19'f6letterfromCPCO).
The licensee has indicated its belief that, if
- .. required, an exemption for the single failure of the emergency diesel is 2[encompassedbyitspendingexemptionrequest (CPCO's letter of April 13, 1976).
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The Staff believes, as noted in the April 19, 1976 Comments by the Director, that the exemption from 10 CFR !0.46 required to permit operation with the
_ single on-site emergency diesel to provide power for long term cooling in
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_ phe event of a LOCA is encompassed within the February 27, 1976 exemption
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hequest Procedural Steps Required Under the Staff's broad view of the scope of the pending exemption request, the only remaining step for the Commission to take is to act on the pending request. Thereafter, assuming the Commission adopts the recommendations by the director, che, Staff would assure that the conditions required to be completed before return to operation have been properly fulfilled.
Before completion of the refueling outage scheduled for Spring of 1977, the Staff would assure that the remaining conditions have also been properly fulfilled.
If the Commission views the exemption request more narrowly, such that further specific exemptions are required, such-exemptions would be needed in ordct to satisfy the findings required by 10 CFR Part 50.91 and 50.57.
Since th-extension provided by.the AEC's August 5, 1974 Memorandum and Order (RAI-74-8-213;
' 8 AEC Repts. 213) has now expired, action on such exemptions is required prior
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to further operation of'the facility.
In accordance with 10 CFR Part
'59.46(a)(2)(vi), notice in the Federal Register providing 141 days for the
' bmission of comments by interested persons would be necessary.
16 kummary In summary, the Staff responds to the. specific matters raised by the Commission in its May 12, 1976 request, as follows:
Item (1):
Whether the exemptions from requirements of 10 CFR 50.46_which nig Rock Point needs to resume operation at the end of the current refueling outage are fairly comprised within the exemption request now pending before the Commission, as revised and amended by the applicant's letter of-February 27, 1976.
Staff Response: For the reasons oiscussed above, the Staff believes that the required exemptions from the single failure requirements of 10 CFR 50.46 needed by the Big Rock Point in order to resume operation are fairly comprised within the exemption request now pending before the Commission.
Item (2):
If the necessary exemptions are not so comprised, what steps would be necessary prior to operr. tion for Big Rock Point to meet the Cemmissien's legal obligations.
Staff Response:
If the Commission reaches a conclusion contrary to that of the Staff above, additional public notice of the required additional two exemptions previously discussed woul,d be necessary in accordance with 10 CFR 50.46(a)(2)(vi).
P&,
Au Ben C.~Rusche,
- . rector Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland, 2'
this 17th day of May 1976 i[
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DISTRIBUTION Docket UNITED STATES Ol' AMLIJCA NUCLEidt REC'JLATORY C01stISS103 ORB,#2 Reading
.j RMDiggs
',p in the Matter of
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CStephens, DSS, Secry i
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N C0JSUMLRS POWER C0!!PA;Y
) Docket l'o. 50-155 N
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, (Big hock Point Nv:laar Power Plant) )
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CERTIFICATE OF SERVICE 1
I hereby certify that copies of the "NRC STAFF RESPONSE TO REQUEST i-FOR INF010'ATION BY Tile COM!IISSION - DOCKET NO. 50-155" dated May 17, 1976. In the above-captioned matter have been served on the fonoving by deposit in the United States Mail, first class, this 18th day of P.ay, 1976.
Consumers Power Cospany Chairman ATTh ?!r. Ralph B. Sewell County Board of Supervisors i
Nuclear Licensing Administrator Charlevoix County I
212 West !!ichigan Avenue Charlevoix,!iichiCan 49720 Jackson, Michigan 49201
!Ir. George C. Freeman, Jr.
Esq.
Mr. Paul A. Perry, Secretary Hunton, W1111ans, Cay G gibson Consumers Power Company 700 East Main Street 212 West liichigan Avenue Richmond, Virginia 23212 Jackson, liichigan 49201 halph Rosenberg
- 12. Peter W. Steketee, Esquire At to rney-at-Law Freinofer, Cook, liecht, Oos terhouse 1824 New Hampahire Avenue,13. W.
and De Boer Washington, D. C.
2003u Union Bani Euilding, Suite 950 Grand Kapids, liicnican 49502 Public Interest hescarch Group in !!1chigan i
lir. Charles F. Bayless 593 Hollister Building 1
Of Counsel Lansing,Ilichigan 4W)33 Consumers Power Company 212 West 111chigan Avenue Jackson,111chigan 49201 e.
- hy:
Mr. John D. Beck
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- . Division of Intergovernmental 7,
Eclations I
J [ Executive Office of the Governor 7 L Irwis Cass Building, 2nd Floor Lansing 111chigan 48913
--Peba 11. Diggu -
Operating Eeactors Branch #2 Division of Operating Reactors OR:ARB o,,..,
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gs.; ah.,,,
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Form AEC.)l3 (Rev. 9 53) AICM 0240 W v. e. novsanesent Paeavine orrects sere ese see