ML20002C229
| ML20002C229 | |
| Person / Time | |
|---|---|
| Issue date: | 10/23/1980 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-1788, NUDOCS 8101090705 | |
| Download: ML20002C229 (19) | |
Text
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D MINUTES OF THE ACRS SUBCOMMITTEE MEETING ON REACTOR OPERATIONS f[
iO WASHINGTON, DC OCTOBER 7, 1980 The ACRS Subcommittee on Reactor Operations held a meeting on October 7,1980 in Room 1046, 1717 H St., NW, Wasington, DC. The purpose of the meeting was to hear preliminary plans by the NRC Staff for responding to Section 110 of the FY-80 Authorization Bill which requires the NRC Staff to develop, submit to Congress, and implement, as soon as practicable after notice and opportunity for public comment, a comprehensive plan for the systematic safety evaluation of all currently operating nuclear power plants.
Section 110 includes a requirement for the NRC to identify each current rule and regulation which the Commission determines to be of particular significance to the protection of the public health and safety,- and the determination of the extent to which each currently operating plant complies with these identified rules and regula-tions.
A second area of Section 110 calls for the idatification of all the generic safety issues set forth in NUREG-0410, "NRC Program for the Resolution of Generic Issues Related to Nuclear Power Plants," for which technical solu-tions have been developed, the determination of which of these solutions should be incorporated into the Commission's rules and regulations; and the development of a schedule for reaching a technical solution for the remaining generic safety I
issues. A final requirement of Section 110 is to provide to Congress a report on the status of the NRC's efforts to satisfy the requirements stated above, not later than 90 days from the date of enactment.
(The 90-day Status Report was issued on September 30, and copies were made available to the Subcommittee.)
The Subcomittee also discussed with the NRC Staff the status of seven of the ACRS generic items it had been assigned to reevaluate. The meeting was entirely 8701ogggog
. October 7, 1980 Reactor Operations open to the public.
The Designated Federal Employee for this meeting was There were no written statements or requests for time to make Richard Major.
oral statements received from members of the public.
Mr. Ernst outlined the requirements of Section 110 of the NRC FY-80 Au-thorization Bill (Public Law 96-295 - June 30,1980).
Subsection 110(A) requires the NRC to develop, submit to Congress, and implement, after public comment, a comprehensive plan for the systematic safety evalua-tion of operating plants.
Subsection 110(B) notes the comprehensive plan must include:
(a)
Identification of rules and regulations of particular significance.
(b) Determination of Extent of Operating Plant Compliance with the rules of particular significance.
(c) Identification of Resolved Generic Issues in NUREG-0410.
Determination of Which Resolved Solutions Shculd be Incorporated (d)
Into Regulations.
(e) Schedule for resolving remaining generic issues.
Subsection 110(C) notes NRC must provide a 90-day report to Congress on the I
status of efforts to satisfy the requirements of Subsections 110(A) and (B).
l (Transmitted to Congress September 30,1980.)
As background information, Mr. Ernst noted that the House amendment; which
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was the so-called Bingham Amendment, in essence required the NRC to provide l
within 120 days, a compilation of regulations, Division I Regulatory Guides, and Staff Technical Positions required at the time of issuance of each OL.
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e October 7, 1980 Reactor Operations It also required a list of operating reactors where generic issues solutions have been implemented, and a schedule for resolving remaining generic issues.
The Senate Bill had no such language. The compromise, which is in Section I' also 110, did permit building upon current programs such as the SEP.
focused on those regulations of particular safety significance as opposed to all regulations, and required only a 90-day statLs report instead of a full report in 120 days.
Previous NRC actions that were underway at the time of passage of the Au-thorization Bill include the Systematic Evaluation Program which is an This program was assessment of the safety of the sleven oldest plants.
established several years ago, and the intent was to extend this to all operating plants based on the ex'perience gained in reviewing the eleven oldest plants.
The need for a-comprehensive plan to evaluate operating reactors and for other safety-related reviews is recognized in the NRC Action Plan (NUREG-
'resses that the development of a comprehensive 0660). The Action P1
'ts of the current SEP and IREP (Interim Re-plan must consider the liability Evaluation Program) Evaluations, as well as priorities and the The need to identify and methodology of making safety-cost tradeoffs.
The Generic resolve generic issues in recognized in the Action Plan.
l Issues Branch was established in NRR to manage resolution of Unresolved Safety Issues and coordinate and monitor work on designated generic issues.
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s October 7, 1980 Reactor Operations Mr. Ernst noted that in developing a comprehensive plan to implement Section 110, the Staff considered various objectives that should be The Staff would The plan would have to conform to Section 110.
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like to usefully integrate the SEP,1 REP, and NREP (National Reliability Evaluation Program) into the response to Section 110. The intent is to maximize the enhancement of safety and at the same time minimize resources.
The course of action decided upon should be to the extent possible to minimize the time to implement the plan and, hopefully, maxuinst public understanding of the plan.
The Staff must develop a list of particularly significant regulations.
The process of identification was characterized as complex and subjective.
Several possible sets of criteria were developed and two sets of criteria Lenient criteria (in the sense of allowing more regulations were tested.
to pass the screening process) identified 85% of the technical regulations and 50% of the administrative. regulations as being particularly significant.
More stringent criteria identified 60% of the technical regulations and 40%
The Staff-of the administrative regulations as being safety regulations.
recommends moderately stringent criteria; the Comission has this question Mr. Ernst said that the Staff under consideration at the present time.
would appreciate a letter from the Committee giving an opinion on how stringent the screening process should be.
After t' e Staff has identified the regulations of particular significance, h
the next step would be to request licensees to evaluate plants in accord-It is anticipated that in this request, the ance with these regulations.
October 7, 1980 Reactor Operations Staff would provide some guidance to licensees as to how to conduct the The Staff expects that licensees will be measuring plants evaluations.
against acceptance criteria in a revised SRP (Standard Review Plan) to be The Revised SRP will reference all applicable regu-issued in April 1981.
lations, regulatory guides, staff positions, and requirements resulting It is likely that licensees will be asked to pro-from the TMI accident.
vide technical bases for asserting equivalence and to provide judgments and a technical discussions as to the safety significance of noncompliance with regu'ations of particular significance and/or of deviations from related SRP a'cceptance criteria.
Mr. Ernst discus. sed a proposed plan for licensees and applicants to docu-The NRR audit review process ment and discuss deviations from-the SRP.
does not require a detailed Staff review of every system and subsystem Staff SERs have not sys-against all applicable acceptance criteria.
tematically and consistently documented the manner in which applicants Therefore, there complied with all regulations or acceptance criteria.
is no documentation of whether'or how all regulations and acceptance Proposed requirements of the Plan to document and criteria are met.
discuss deviations from the SRP for OLs and operating reactors include:
30, 1980 Nuclear Power Plants issued or licensed on or before June should identify and discuss all deviations from acceptance criteria of the revised SRP that relate to regulations of particular safety ee e
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Reactor Operations October 7, 1980 significance.
(The intent is that this requirements will be compat-ible with the final comprehensive plant for the systematic evaluation of operating plants, including the requirements of Subsection 110(B)1 and 2).
- Applicants issued an OL after June 30, 1980, for which an SER was issued on or before Jaunary 1,1982 should identify and discuss, after issuance of an OL, all deviations from acceptance criteria of the re-vised SRP that relate to regulations of particular safety significance.
Applicants for Ols, for which ti e SER is issued after January 1,1982 h
should identify and discuss, prior to issuance of an OL, all deviations from all acceptance criteria f.or the SRP revision.
A similar set of requirements is proposed for cps and manufacturing licenses:
Applicants for cps or MLs, for which the SER TMI supplement is issued before January 1,1982 should identify and discuss, prior to issuance of CP or ML, all deviations from all acceptance criteria of May 1980 SRP and NUREG-0718.
- Applicants for a CP or ML, for which an SER TMI supplement is issued after January 1,1982 should identify and discuss, prior to issuance of a CP or ML, all deviations from all acceptance criteria or revised SRP.
October 7, 1980 Reactor Operations There will be an additional question in the Federal Register notice which will ask if the requirements of the proposed rule should be implemented by Regulatory Guide, Specification of CP or OL condition, policy state-ment, or rulemaking.
Mr. Milstead from the Safety Program Evaluation Branch in the Division of Safety Technology explained how the Staff made preliminary screening attempts of the Commission's regulations to identify those items of particular significance to safety in order to comply with Section 110 of the FY-80 NRC Authorization Bill. An NRR task force was formed to Senior Staff personnel made up the task force, each having do this job.
a specific background which it was felt would span the spectrum of tech-nical review organizations. The review was carried out in two steps.
First an initial list was established of Commission regulations which
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The second step was to determine which of the were safety-related.
items from the first list are particularly significant to the ' protection of the public health and safety.
l The criteria used in picking the first list of safety-related regulations was to include technical or a6ninistrative regulations the absence of l
which might result in a change in plant designs or operation which could be judged to reduce the level of protection to either the public or' plant If a majority of the members of the task force felt a regula-employees.
tion satisfied Criterion I, then it was included in the list of safety regulations.
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October 7, 1980 Reactor Operations The initial list of safety-related regulations was screened using two additional sets of criteria, in the second phase of the task force effort.
The objective of the screening was to obtain two sample listings of 'those relevant safety-related regulations which were felt to satisfy the require-ments of Section 110 of the Authorization Bill which was to choose those items of particular significance to the protection of the public nealth Two screening processes were used; one used a lenient inter-and safety.
pretation of particular significance (lenient in the sense that the screening process passes more regulations) and the other was felt to be The Commission has not adopted either set of criteria, more stringent.
the efforts were characterized as trial sets to scope the magnitude of the task.
The criteria used to pick particularly significant regulations based on lenient criteria (Criterion II) included all technical and adminis-
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trative regulations the absence of which might result in a significant increase in the likelihood of:
Offsite consequences >10 CFR 100 for DBE and most limiting 1.
- failure, Loss of safety function by assuming single equipment failure, 2.
Major degradation of fuel integrity, primary coolant boundary, 3.
or primary containment boundary,'or Large onsite releases or staff personnel exposures:
4.
B.
Unrestricted Areas A.
Restricted Areas 0.5R/yr Whole Body 25R Whole Body 500x 10 CFR 20, App. B, 150R Whole Body Table II Release 375R Extremities (This criteria is based on NUREG-0900 abnormal occurrence report to A regulation which Congress - Appendix A criteria for reporting.) satisfied anyon Criteria II.
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October 7, 1980
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Criterion III, which was felt to be more stringent, is based on the assump-Cri-tion of a severe threat to the commission's defense-in-depth concept.
c' terion III included all technical or administrative requirements the absence of which might result in a significant increase in the likelihood of major degradation of two or more of the three barriers in the defense-in-depth concept, (i.e., Fuel Integrity, Reactor Coolant System Pressure Boundary, and Containment Boundary).
The list based on Criterion III was derived in the same manner as the other lists, i.e., each regulation was discussed by the task force, the members then noted to determine if a regulation met a particular criteria, a majority vote of the members present was required to add an item to the list.
Results of the three screening efforts were presented.
Mr. Ernst discussed the ACRS generic item on a periodic ten-year review of operating nuclear power plants.
He noted that the current review required by Section 110 of the FY-80 Authorization Bill nay go a long He mentioned that some way toward serving the need for this rereview.
thought ha.d been given to the possibility of comparing present regula-tions to the regulations of 10 years ago to highlight areas where sub-stantial changes may have occurred. These areas would then be investigated.
Mr. Ernst said that SECY-435 deals with upgrading the regulations in He did not view this effort as impacting on a disciplined manner.
the current effort of implementing Section 110 requirements.
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. October 7,1980 Reactor Operations Mr. Kniel, Chief of the Generic Issues Branch, noted that the NRC Staff's definition of resolution will be expanded to include not only the technical solution for an unresolved safety issue, but will also include the imple-mentation of the solution on plants.
ACRS Generic Item #18, " Criteria for Preoperational Testing," was dis-It was noted that this issue was originally resolved by issuance cussed.
of Regulatory Guide 1.68 in 1973.
A section of the Standard Review Plan is also devoted to preoperational testing. Both documents have been re-Task vised and the latest revisions are being used in performing reviews.
I.G.1 from the NRC Action Plan resulting from the TMI Accident addresses preoperational and low power test programs.
Specifically, I.G.1 addresses the training of plant operators during augmented low power test programs.
Mr. Kniel said there appears to be a training benefit from the tests.
Both the Regulatory Gide and Standard Review Plan section are scheduled for reassessment as part of section I.G.2 of the TMI Action Plan in FY-82.
Mr. Kniel discussed ACRS Generic Icem #69, " Locking Out of ECCS Power-Operated Valves." The Staff position on this issue is given in a branch This technical position found in Chapter 8 of the Standard Review Plan.
position provides that lockout is acceptable provided certain conditions No additional work is. currently underway. The Branch have been met.
technical position requires that electrical power can be restored to the valves fran the main control room, and that valve operation is not neces-It must sary for at least ten minutes following occurrence of an event.
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Reactor Operations October 7, 1980 be demonstrated that there is reasonable assurance that all necessary operator actions will be performed within the time shown to be adequate by anaysis. Valves must have redundant position indication in the main control room, and the position indication system should meet the single failure criterion.
Mr. Walter Haass of the Quality Assurance Branch, NRR, discussed ACRS Generic Item #11, " Quality Assurance During Design, Coi.struction, and Operation." Mr. Haass noted that this item had been previously con-sidered resol,ved, however, Quality Assurance (QA) programs are receiving additional attention as a result of the TMI-2 accident.
Improvements in QA programs a.re suggested in the NRC Action Plan as a Result of the TMI-2 Accident in Item I.F.
Among the new guidance given in the Action Plan is to expand the QA list to include all items that have some effect on safety.
Additional items in the new guidance include increasing the QA organizational indeoendence from the operations oriented utility staff, upgrading qua',1fication requirements for-QA/QC personnel, and increasing QA staffing levels.
Currently, a regulatory guide for expanding the QA list is scheduled to be issued by September j
l of 1983. Other items contained in the new guidance from the Action i
Plan will be addressed as resources permit.
Mr. Kreger discussed ACRS Generic Item #51, " Maintenance and Inspection of Plants." He noted the central issue of this item had been radiation exposure during maintenance and inspection. This item had been considered resolved in 1979 as a result of the implementation of much more effective e
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Reactor Operations October 7, 1980 and considerably more elaborate radiation protection programs in plants.
Mr. Kreger noted that as a result of TMI, the Staff is further addressing the issue of radiation exposure resulting from an accident. The NRC Actica Plan will require a written radiatior protection plan that covers both normal operation and accident conditions.
Mr. Cherny and Mr. Polk of the NRC Staff discussed ACRS Generic Item #48,
" Isolation of Low Pressure from n y Pressure Systems." The concern raised by this item relates to the possibility of an inadvertent connection or valve failures between a low pressure and high pressure system.
In such an instance, overpressurization of' the low pressure system could result, with consequences possibly leading to a LOCA.
In order to preclude such an event, the Staff requires inservice inspection and testing of valves that form the boundary between high and low pressure systems at regular intervals. Of particular concern to the Staff was the WASH-1400 Event V valve configuration (two check valves in series, or two check valves in series with a MOV.) This concern was the subject of a February 27, 1980 notice to all licensees concerning LWR Primary Coolant System Pressure Isolation Valves; in this letter acceptable methodr, to assure component integrity are given. The Staff noted it was possible to test two valves in series individually. Regarding monitoring the neutral space between valves, Mr. Cherny noted this is not now a requirement.
Mr. Serkiz of the NRC's Division of Research discussed efforts underway with regards to Unresolved Safety Issue A-43, which concerns contain-ment emergency sump perfomance.
ACRS Generic Item #1, "NPSH for ECCS
.p,
. October 7, 1980 Reactor Operations Pumps" has as a remaining concern sump design and partial blockage of the sump giving rise to the potential for vortexing problems. Mr. Serkiz described a program being conducted at the Alden Research Center in Massachusetts which addresses containment emergency sumps hydraulics and vortex suppression devices.
The program is being funded mainly by DOE, although the program will principally benefit NRR.
Sandia is analyzing The concern with vortex formation is that air from the vortex the data.
could become entrained in the recirculation piping and degraded pumping.
A small void fraction is not significant several percent wil1' not effect pump performance.
However, approximately 10% void fraction will cause d op in pumping head. The tests which are being carried out at Alden are full scale tests.
The program will be underway for two years and will be funded at the rate of $1.5 million per year.
s The meeting was adjourned at 2:30 p.m.
For additional details -a complete transcript of the meeting is avail-NOTE:
able in the NRC Public Document Room,1717 H St., NW, Washington, DC 20555 or from Alderson Reporters, 300 7th St., SW, Washington, DC, (202) 554-2345).
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REACTOR OPERATIONS SUBCOMMITTEE MEETING WASHINGTON, DC OCTOBER 7, 1980 LIST OF HANDOUTS AND SLIDES ACRS Briefing - October, 1980; Section 110 of NRC FY-80 Authorization 1.
Act, Public Law 96-295; Slides used by M. Ernst 2.
Additional Material from M. Ernst:
Public Law 96-295 a.
Status Report on the Commission's Efforts to Develop a Comprehensive i
Plan for the Systematic Safety Evaluation of Currently Operating b.
Nuclear Power Plants l
Plan to Require Licensees and Applicants to Document Deviations from i
c.
the Standard Review Plan l
Slides used to describe selection process for "Particularly Significant" 3.
Regulations - by W. Milstead Additional Material from W. Milstead - " Considerations Regarding i
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- Identification of Regulations of "Particular Significance" 4.
" Quality Assurance Program for Design, Construction, and l 5.
Slides for:
Action Plan (Item I.F) by W. Haass Operation TMI-2 Accident:
i USNRC Proposed Revision, Standard Review Plan PSRP-3.9,6 (Rev. 2)
Inservice Testing of Pumps and Valves - submitted by F. Cherny 6.
f LWR Primary Coolant USNRC Letter to All LWR Licensees,
Subject:
23, 1980 - submitted by P. Polk 7.
System Pressure Isolation Valves, February i
Generic Activity B-45, WASH-1400 Event V, " Primary Coolant System Press l
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Isolation Valves," - submitted by P. Polk j
Event V Valve Configurations - Slides by P. Polk 9.
Alden Research Program - Slides by A. Serkiz l
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September 30, 1980 TENTATIVE SCHEDULE ACRS SUCC0iWITTEE EETING ON REACTOR OPERATIONS 1717 H St., NW, WASHINGTON, DC OCTOBER 7, 1980 APPROXIMATE TIE DISCUSSION OF SECTION 110 0F THE NRC FY-80 I. AUTHJRllAT10N BILL, PUBLIC LAW 96-295_ 8:30 a.m. A. Chairman's Opening Remarks B. Presentation by NRC Staff 8:40 a.m. 1. Introduction content of Section 110 of the FY-80 i. Authorization Bill Staff & Commission action to date and ii. industry involvement 8:50 a.m. Current Overall Schedule 2 proposed plan for interaction with ACRS plan for incorporating publi: and Congressional i. ii. comments 9:00 a.m. NRC Staff Management Structure / Method of Organi-(Method of factoring SEP. IREP, NREP, and 3. Zation Will there be Generic Issues into one program.) an interface between the effort on the periodic and systematic reevaluation of existing rules (SECY 80-435)? 9:20 a.m. Plan Propcsed by the NRC Staff for Responding 4. to Section 110 Systematic Safety Evaluation of All Currently 1. Operating Nuclear Power Reactors Discussion of the Identification of All Generic Safety Issues in NUREG-0410 for which technical 11. solutions have been developed; the determination of which of these solutions should be incorporated into the Commission's rules and regulations; and a schedule for developing a technical solution l for the remaining generic safety issues. Discussion of 90-Day Status Report to Congress l iii. l L:3 O F
TENTATIVE SCHEDULE Septenber 30, 1980 ACRS SUBCOMMITTEE MEETINS ON RE ACTOR OPERATIONS APPROXIMATE TIME 10:00 a.m. Discussion of Plans by the NRC Staff for Requiring 5. Licensees to Document Deviations from the Standard Review Plan 10:30 a.m.
- BREAK 10:40 a.m.
Discussion of Alternatives for the Systematic Safety 6. Evaluation of All Currently Operating Nuclear Power Reactors determination of current regulations of 1. particular significance licensee determination of the extent to which ii. regulations are met NRC evaluation of safety significance of iii. equivalence and noncompliance 11:40 a.m. Resource Implications Both for the NRC and the Industry 7. 11:50 a.m. Future Course of Action / Conclusion of Part I of the 8. Meeting 12:00 noon
- LUNCH REEVALUATION OF GENERIC ITEMS ASSIGNED TO THE REACTOR II.
OPERATIONS SUBC0K;1TTEE 1:00 p.m. A. Chairman's Introduction 1:15 p.m. Items to be Discussed With NRC Staff B. NPSH for ECCS Pumps 1. Quality Assurance During Design, Construction, and 11. Operation Criteria for Preoperational Testing 18. Isolation of Low Pressure from High Pressure Systems 48. Maintenance and Inspection of Plants 51. ACRS/NRC Periodic Ten-Year Review of All Power Reactors 65. Locking Out of ECCS Power-0perated Valves 69. 3:00 p.m. CONCLUSION / ADJOURNMENT I 9
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