ML20042G675

Forwards Comments on Final Rept for Closeout of IE Bulletin 84-03.Rept Accepted & Recommended for Publication

ML20042G675
Person / Time
Issue date:	05/08/1990
From:	Berlinger C Office of Nuclear Reactor Regulation
To:	Lofy R PARAMETER, INC.
References
CON-NRC-05-85-157-02, CON-NRC-5-85-157-2 IEB-84-03, IEB-84-3, NUDOCS 9005150264
Download: ML20042G675 (12)

Text

.

May 8 1990

-Mr. Richard A. Lofy Project Director Parameter, Inc.

13380 Watertown Plank Rd Elm Grove, WI 53122 g

Re:

NRC Contract No. 05-85-157-02 PAR:

NRC-157-02 Sir:

SUBJECT:

Acceptance of Final Report for Closecut of IE Bulletin 84-03 We have reviewed the draf t final report on this subject that you submitted with Walter J. Foley's letter dated April 27, 1990. Except for minor I

editorial coments that are enclosed on marked-up copies, we accept this '

document for a final report. You may release the originals to our project manager, Mr. K. Steven West, for publication.

Sincerely, (b.Mb A

kCarlH.Berlinger, Chief I

Generic Communications Branch Division of Operational Events Assessment Office of Nuclear Reactor Regulation e

Enclosure:

Marked-up Copies of Editorial Comments DISTRIBUTION-w/ enclosure WTRussell, NRR CERossi, NRR CHBerlinger, NRR CVHodge, NRR-PBaranowsky, NRR JAcalvo, NRR KSWest, NRR POR

-ec666affilestar

.DCB i

DOEA R/F i

OGCB R/F i

VHodge R/F g

Qh i\\

l' (gC/0GCB:D0EA:NRR p]';['

OGCB:DOEA:NRR CVHod CHBerlinger

.05/0$ge

/90 05/ /90

1. 8 P 82s " Ul= $

NRC FILE CENTER COPY PDC

. - -. ~ -.

Enclosure cdlain W8

'^

6trefIMc"k E

YdO7i /b" ABSTRACT 943 SVe*I C'p3 Document tio provi in this report to close IE Bulletin 84-03 o th s bject f refueling cavity water seals.

The bulleti w

ssued n August 24 1984, to all power reactor facili les 3 cept ort St. Vrain,.

Because the excluded plant is gas-co le f rap te-moderated, the subject of the bulletin does seals _,.g., J,sa y concern was failure of the pneumatic,

not a 1

_ _ _ -- - _. _ _. ~

a v v e i.i u n --. - -.... v y.......,

..vws d;rr. te the rer:t:r

1 'In.de;d in preparation forat Haddam Neck on August 21, 1984.

The cavity had been floo refueling.

n May 17, 1988, another refu ing cavity seal leakage bout three feet in water level occurred at Surry 1, 8 5l W'T i

in the mi d a of a refueling and maintena ce outage.

Evaluation with a specific cr/ Region inspection reports in of utilit responses and NRC iterion shows that the bulletin is accordanc i

closed for 114 (97%) of the 118 affected facilities.

It is l;

concluded that the concerns of the bulletin have been resolved through de ign and procedure reviews and corrective actions

't taken by 1 consees.

Follow-up items are proposed for use by NRC Region II n closing the bulletin for the four (4) remaining tscilities ith open bulletin status.

NRC Region II verifies t e t the bu letin will not be closed for these four TVA 1

facilities ntil construction is completed.

Background

l l

information ia supplied in the Introduction and Appendix A.

j 4 6e suk (adek O b EN g})% All lewl pt bek i-

f flow k kik h*\\*f0*

,,4.,c v.ul fle*y l

(

l i

+

i

,4 lii

i H

j i

TABLE OF CONTENTS P,,,,ag,e Abstract lii Introduction 1

Summary-2 Conclusions 3

Appendix A Background Information

[ Chronology A-1 I7k8'E7' significant Documents IE Bulletin (IEB) 84-03 A-6 5

Temporary Instruction 2515/66 A-9 Encloses IE Information Notice IN)'84-93)

Comments on Significant Documents IEIN 93 Infomation Items A-21 no cluded @ ecifically.in 84-03 L

outline of TI 2515/66 for A-22 Inspection of Non-metallic Seals Related Documents Issue 82 Beyond Design' Basis A-23 Accidents in Spent Fuel Pools IE Information Notice IN) 87-13 A-29 (Agi.

. [NRC Information Notic(e 88-92 A-31 Engineering =Information on Seal Designs Functions of the Refueling Cavity A-35 Water Seal Haddam Neck 1984 Failure

'A-36 s

1985 Modification A-38 1986 Permanent Installation A-40 Surry.

1988 Failure A-41 1988 Modification A-43 Appendix B Documentation of Bulletia closnout Tab,le B.1, Bulletin Closeout, Status B-1

$htic li A

• d*}J { '

I'1 '"',',' "'

Not vec88686 Eabie'B.2~ Type of Refueling Cavit B-50 fp+ ei T8h\\t }

• Water Seal Used at Each Facil ty

[

ik Appendix C Proposed Follow-up Items C-1 Appendix D Abbreviations D-1 v

f 1

L.

l l'.

1 I

CLOSEOUT OF IE BULLETIN 84-03:

l REFUELING CAVITY WATER SEAL l

i i

INTRODUCTION In accordance with'the Statement of Work in Task Order 008 under j

NRC Contract 05-85-157-02, this report provides documentation i

for the closeout of IE Bulletin (IEB) 84-03.

This task was 1

transferred to Task 037 for i

administrative purposes,under the same contract, only.

Documentation is based on the recordsobtainedfromtheNRCDocumentControlSbstem.

6 we*Ver i

IE Bulletin 84-03 was issued on Augu 24, 1984, because of failure of the refueling cavity wat seal at Haddam Neck.

At J

the time of failure, the cavity wa flooded in preparation for refueling.

Within 20 minutes of al failure, water level decreased 23 feet.to the level o the reactor vessel flange.

If fuel had been in transfer at th time, it could have been partially or completely. uncover d.

Possible results would have been high radiation levels, fu cladding failure, and release of radioactivity.

If the fue transfer tube had been open, the spent fuel pool could have dr ined enough to uncover the tops of the fuel assemblies but not active fuel.

Except for Fort St.

Vrain, all licensees, and construction permit holders of power reactors were required to evaluate the potential for and consequences of a refueling cavity water seal failure and to provide a summary r rt of these actions.

Because Fort St.

Vrain is gas-coole aphite-moderated, the subject of the bulletin does not app M

6 Nt pht IE Information Notice (IEIN) 84-93 was issued on December 17, 1984, to all recipients of the bulletin.

Discovery of two failed pneumatic seals during installation at San Onofre 2 and correction before flooding were reported.

Also discussed were results of the Electric Power Research Institute (EPRI) reactor cavity seal development testing and the possibilities of draining the refueling cavity accidentally through drains or through misaligned valvas of the residual heat removal (RHR) system.

Temporary Instruction (TI) 2515/66 was issued to the NRC regions on December 17 1984 to provide guidance for performing near-tcra inspe,ction, follow-up of utility responses to IEB 84-03.

This TI was to be used until permanent criteria for evaluating refueling cavity water seals were developed and issued by the Office of Nuclear Reactor Regulation (NRR).

On May 17, 1988, a refueling cavity water seal leak event occurred at Surry 1 in refueling shutdown with all fuel removed L

1 h

g 4 se Qq a

• '8

O

)

l from the reactor vessel and no fuel in transit.

The loss of water i

level was about three feet from the full level.

For background information, IE Bulletin 84-03, a chronol m, and sketches and descriptions of the Haddam Neck and Surry seals are included in Appendix A along with other pertinent items.

Sketches of the failed Haddam Neck and Surry seals are shown on pages A-37 and A-42.

Sketches of the modified Haddam Neck and Surry seals are shown on pages A-39 and A-44.

The permanent (welded) Haddam Neck i

modified seal is described on page A-40.

Evaluation of utility responses and NRC/ Region inspection reports is documented in Appendix B as the basis for bulletin closeout.

As an aid to evaluation, types of refueling cavity water seals at power facilities are grouped and described in Appendix B.

Follow-up items are S.*3cosed in Appendix C for use by NRC Region II in assuring l

satibrietory completion of required acti-r.

Abbreviations used in this zeport and associated-document are presented in Appendix D.

SUMMARY

1. The bulletin has been closed for the following 114 facilities for whichresponsesandNRC/Regionigpection p rts' indicate om n

with required action Mene.

same g W W 6 %

Arkansas 1 2 Grand Gulf 1 Quad Cities 1,2 Beaver Valkey 1,2

• Haddam Neck Rancho Seco 1 Big Rock Point i Harris 1 River Band 1

• Braidwood 1,2 Hatch 1,2

• Robinson 2 Browns Ferry 1,2,3 Hope Creek 1

• Salem 1,2 Brunswick 1,2

• Indian Point 2,3 San Onofra 1 l'

• Byron 1,2

• Kewaunee

• San Onofra 2,3 L

• Callaway 1 LaSalle 1,2 Seabrook 1 Calvert Cliffs 1,2

• Limerick 1,2

• Sequoyah 1,2

• Catawba 1,2 Maine Yankee Shoreham Clinton 1

• McGuire 1,2 South Texas 1,2 l

Comanche Peak 1,2 Millstone 1,2,3

• St. Lucia 1,2 i

• Cook 1,2 Monticello Summer 1 Cooper Station Nine Mile Point 1

• Surry 1,2 Crystal River 3

• Nine Mile Point 2

• Susquehanna 1,2 Davis-Besse 1 North Anna 1,2 TMI 1 Diablo Canyon 1,2 Oconee 1,2,3

• Trojan L

Dresden 2,3 Oyster Creek 1

• Turkey Point 3,4 E

Duane Arnold Palisades Vermont Yankee 1 l

Farley 1,2

• Palo Verde 1,2',3 Vogtle l',2 l

Fermi 2 Peach Botton 2,3 Waterford 3 l

FitzPatrick Perry 1 WNP 2 Fort Calhoun 1 Pilgrim 1

• Wolf Creek 1

• Ginna Point Beach 1,2

• Yankee-Rowe 1

• Prairie Island 1,2

• Zion 1,2 I

• Pneumatic seal (s)_at time of bulletin issuance.

2 1

7,,

y

-w-

,*--e

= - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

a I

2.

The bulletin is called open for the following four (4) l' facilities.

Follow-up items for these facilities are J

proposed in Appendix C for use by NRC/ Region II.-

+Bellefonte 1,2

+* Watts Bar 1,2

• Pneumatic seal at time of bulletin issuance.

+The bulletin will not be closed until construction of these facilities is completed.

2.

The following facilities which have been shut down indefinitely or permanentl or have had construction halted indefinitely (CHI) y (SDI), included in this evaluation are not of closeout status Dresden 1 - --------SDI Perry 2-----------CHI Humboldt Ba 3------SDI Seabrook 2--------CHI Indian Poin 1------SDI TMI 2------------~SDI-1 La Crosse ----------SDI WNP 1,3-----------CHI 4.

TI 2515/66 was issued to the NRC regions for guidance only in,,

performance of near-term inspection followup, even though its essential elements were considered to be in IEB 84-03.

Refer to Item 5,-page A-2.

i 5.

Permanent criteria for evaluating refueling cavity water seals were to be developed and issued by the NRC, within the scope of Generic Issue 82 (refer to Item 6, pa However, such acceptance criteria were ::t i;;ge A-2).

f (refer to Items 15f page A-7 L eiem.*ne1 $.

$ be wonanM J

6.

The various designs of refueling cavity seals: are categorized and tabulated in Appendix B There are 11 different basic categories., Table B.2.

These include pneumatic (active seals, plus metal bellows and welded )

seals, solid Cpassive) components, with various combinations of two or more of these types.

Of the 118 facilities either operating or under construction and required to respond to the bulletin, 47 used pneumatic seals alone or in combination with other types, 32 used metal bellows exclusively (BWRs), 32 used the passive solid seal types only, and 7 used the welded component type of seal arrangement.

CONCLUSIONS 1.

The concerns of the bulletin have been resolved through J

design and procedure reviews and corrective actions taken by licensees.

Verification has been established through inspection follow-up and review by the NRC.

l 4

3 M

VT M

1

)

)

CHRONOLOGY I

1.

August 24, 1984 (IEB 84-03) nuclear pow (er facilities in operation) was issued to allor under construction, IEB 84-03 see pages A-6 through A-8 except Fort St. Vrain which uses gas-cooling and graphite-moderation an,d has no refueling cavity water seal.

The utilities were required to " evaluate the potential for and consequences of a refueling cavity water 1 failure and provida a summary report of these action including consideration of the following six factors

{

Gross seal failure

~

Maximum leak rate due to failure of active components such as inflated seals Makeup capacity Time to cladding damage without operator action Potential effect on stored fuel and' fuel in transfer Emergency operating procedures l

Key Phrases Other Than the Above Six Factors:

l Interference between annular widths of seal and gap l

l Displacement of seal Uncovery of fuel l

Puel cladding failure Release of radioactivity Open fuel transfer tube Potential for and consequences of failure 2.

September 5, 1984 (TIA 84-72)

Task Interface Agreement (TIA) 84-72 was Issued to describe the actions assigned to IE, NRR, and the regions for IEB 84-03.

A Lead project Manager was designated by NRR to coordinate correspondence, meetings and reports.

L A-1

f "Beyond Design Basis Accidents in Spent Puel Pool

, and as such, it was to be included as part as that study -

r determining what if any additional criteria and actions are required in the long term.

The conclusion included the following sentence about inflatable seals, "Further, we believe that resident inspectors should continue to oversee installation of the seal at each refueling to insure proper integrity of the cavity seal until such time as specific future action, if any, is identified."

7.

March 6, 1985 LMemorandum)

E. L. Jordan (SE) issued a memorandum for regional personnel R. W. Starostecki, P. R. Bemis, C. E. Norelius, R. P.

Denise, and D. F. Kirsch on the subject of responses to IEB 84-03.

i Copies of INPO Significant Operating E gerience Report i

(SOER) 85-1 (proprietary), " Reactor Cavity Seal Failure,"

j were forwarded.

g 4kg mangamlum l

l Preparationofemergencypryceduresbasedonworstcase assumptions was recommended.

The procedure for closing the fuel element transfer tube gate valve and failure of the pneumatic seal of a spent fuel storage pool were given special mention.

Typical questions applicable to responses i

were presented.

8.

March 7, 1985 (Memorandum)

H. Bailey (IE issued a memorandum for D. Humenansky (Special Assis) tant for Commissioner Each) through C. E.

Rossi (IE) to summarize responses to IEB 84-03.

Copies of IEB 84-03, TI 2515/66 IEIN 84-93, several representative responses,andseveralpreliminaryregionalevaluationswere I

onclosed.

Emphasis had been placed on facilities with pneumatic seals scheduled for refueling in the near term.

For those d

facilities, additional data had been requested 44 eoedee and special procedures and precautions had been specified on a case by case basis to permit refueling.

Tests and/or analyses of pneumatic seals had been required to substantiate claims that gross failure of these seals was unlikely.

9.

April 4, 1985 CMemorandum)

P. R. Bemib (R;I) issued a memorandum for E. L. Jordan (IE) in reply to the latter's memorandum of March 6, 1985.

He questioned whether the new actions described per TI 2515/66 were meant to be required.

He recommended that gap widths and differential ledge elevations be confirmed by means of actual measurements.

4 A-3

10. Apr'il 11, 1985 (Memorandum)

T.

P. Spels (NRR) issued a memorandum for R. M. Bernero (NRR) on the relationship of TIA 84-92 and Generic Issue He concluded that he would proceed to prioritize the 82.

Haddam Neck event as a no issue.

11. April 12, 1985 (Mem[ndum)

A. ZwolinsK1 EDU) issues a memorandum to G. Holahan (NRR)

J.g on Generic Revi,ew of Refueling Cavity Water Seals."

The memorandum of March 5, 1985, from R. M. Bernero (Item 6, page A-2) was referenced and attached to establish that the Haddam Neck event falls within the scope of Generic Issue ond Design Basis Accidents in Spent Fuel Pools" (see 82 Accordingly, any additional criteria or age Aicensing). activities were to be determined on the basis of pe23 that generic issue.

12. April 30, 1985 (Memorandum)

Assuea a memorandum for P. R. Bemis (RII)

E.

L.

Jordan (IE) in reply to the latter's memorandum of April 4, 1985.

He stated that IEB 84-03 is the basis for the " Single Failure 2515/66.

He emphasized that the TI was to Criterion" of TI be used for guidance only, even though its escential elements were considered to be in IEB 84-03.

He concluded that issuance of IEIN 84-93 and INPO SOER 85-1 (proprietary) made issuance of a new (or revised) bulletin unnecessary.

Z E.

13. July 18, 1985 port) istme d a n S

1;d:d ci;h_ rh:tch;; cad ; d;t; ;h;;t Henry!= eara** Bailey emMR)"12: Refueling Cavity Pneumatic Seal concerng" in th

??.

dH p Nec ad roposed

.%u npart 4e describer the faile% adgw a*k metaga modificationsg w'n ui s he 4 a 48 14, April 01, 1986 (Memorendum) issued a memorandum for Karl Kniel Warren Minners (DSRO)

(DSRO) on the subject of prioritizing the refueling cavity His three references are water seal failure as a new issue.

listed here as items 3, 6, and 10.

15. September 29, 1988 LMemorandum).

E. Murley (NRR) hasued a memorandum regarding lessons T.learned from the surry refueling cavity seal leak.

The memorandum reviewed the Surry event in relationship to the bulletin status, and included background, chronology, ion findings, and conclusions.

It described remedial act being taken to resolve the remaining bulletin concerns and to complete the NRC efforts on the refueling cavity water seal issue.

In Attachment 3 of the memorandum, the NRR committed to determine whether revision of Regulatory Guide 1.13, " Spent Puel Facility Design Basis" and other documentation is necessary to include acceptance criteria for refueling cavity water seals.

A-4 m

.. y.,

% en m ir

o

16. April 24, 1989 (Memorandum)

Eric S. BecKjord (Director, Office f Nuclear Replatory Research) issued a memorandum to V ctor Stello, Jr.

(Executive Director for Operatio

) to state that the Generic Issue 82 on accidents in spent fuel pools had been resolved without further action, in accordance with Alternative Resolution No. 1 of NUREG-1353 (April 1989).

17. September 5, 1989 (Memorandual issued a memorandum for Charles Conrad E. McCracken (NRR) ject of long term follow-up of the Haughney (NRR) on the sub refueling cavity water seal leakage event at Surry 1.

Further follow-up of the Surry event and prioritization of i

Generic Issue 137 on refueling cavity water seal failures Establishment of acceptance were deemed unnecessary.

criteria for refueling cavity water seals was determined to not be warranted.

O O e

l 8

I A-5 4

a

~~

f;

p

- o:

kl

~.

a jl IEIN 84-93 INFORMATION ITEMS NOT INCLUDED SPECIFICALLY IN IE*l B4-03

,)

- Brief review of EPRI tests (completed in 1981) of reactor -

jj cavity seals

- Description of installation problems and manufacturing defects of. pneumatic seals at San Onofre 2 i

- Caution about susceptibility of some pneumatic / flexible na e from dropped objects after flooding

)

seals to

- Concer s about-pneumatic seals used in nozzle dams 'and spent / pool gates

- Reminder of possible draining of the refueling cavity per

' misalignments _of RHR system valves 4.n the shutdown cooling

+

mode

- Caution about slower rates of draining the refueling cavity through drain lines

- Recommendation of properly calibrated refueling cavity water level instrumentation

• This item is included in TI 2515/66.

l l-l 1

i I

i A-21 1-

^

l Notes (contd.)

l 11-21-84, 12-31-84, 01-18-85, 01-29-85, 02-18-85, l

Response dates for Catawba 1,2:

4.

03-22-85.

08-23-84, 08-31-84, 09-12-84, 09-20-84, 09-28-84, S.

Response dates for Haddam Neck:

10-02-84, 11-07-85, 02-19-86, 12-04-87.

11-21-84, 12-31-84, 01-18-85, 01-29-85, 02-18-85, 6.

Response dates for McGuire 1,2:

j 03-22-85, 04-26-85 (Unit 2, only).

10-02-84, 10-17-84, 10-26-84, 09-10-85, Response dates for Sequoyah 1,2:

7.

10-01-85.

The LER Surry personnel issued both a response and LER 88-030 on 10-03-88.and the response described corrective pla

• 9 8.

described the leak event of 05-17-88, f

CRITERION FOft CLOSEOUT OF BULLETIN A response for the facility complies with actions required by the bulletin and an 5

NRC/ Region inspection report indicates that required actions have been completed P

T satisfactorily.

e i

In addition, the following notes apply:

2515/66 items For pneumatic seals, the inspection report indicates that TISee pages A-9 through A-20 for the (a) were reviewed to some extent by the inspector.

r TI and page A-22 for ehegoutline ggg

(_

For non-pneumatic seals, the inspection report indicates that the utility and/or the inspector have considered the possibilities of some leakage (even ifand that there (b) gross failure.s deemed incredible) and mitigate such leakage.

[

yX P

=

.W T

_