ML20043H168

Advises That WT Russell to W Rasin on Station Blackout Reflects NRC Views on Issue Re 900425 Meeting Summary Not Expressed in Any Nrc/Numarc Meetings During Development of Reg Guide 1.155 or NUMARC-87-00

ML20043H168
Person / Time
Issue date:	06/19/1990
From:	Thadani A Office of Nuclear Reactor Regulation
To:	Marion A NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT &
References
RTR-REGGD-01.155, RTR-REGGD-1.155 TAC-40577, NUDOCS 9006220120
Download: ML20043H168 (4)

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A UNITED STATES NUCLEAR REGULATORY COMMISSION kleJ I.,pc o

wAssiworow. o. c. nosss June 19, 1990 t

Mr. Alex Marion Manager TechnicalDivisIon NuclearManagementandResourcesCouncil(NVMARC) j 1776 Eye Street, N.W., Suite 300 Washington, D.C.

20006-2496

Subject:

STATION BLACK 0UT l

References:

1.

Meeting Sumary dated April 27, 1990 - Meeting with NUMARC of A)ril 25, 1990 on Station Blackout (TAC 40577), F. losa (NRC) 2.

LetterfromW.T. Russell (NRC) tow.Rasin(NUMARC) dated June 6, 1990,

Subject:

Station Blackout

Dear Mr. Marion:

I The purpose of this letter is (1) to respond to your letter (Enclosure) of May 7,1990, and (2) to document our answer to the question you raised some weeks ago regarding battery capacity as related to the requirement for field flashing of emergency diesel generators (EDGs) on a plant exit from a station blackout (SBO) event.

The Enclosure provides your coments on the meeting sumary (Reference 1) of the NRC/NUMARC meeting of April 25, 1990. Specifically, you state that "The staff. position referred to (sic) the subject meeting sumary was not expressed in any of the NRC/NUMARC meetings during the development of the SB0 Rule R.G.

1.155 or NUMARC 87-00." You also state that "The statement as written in the third paragraph of the meeting sumary is inaccurate and misrepresents the efforts NUMARC has taken in working with the NRC in understanding and developing a resolution to the station blackout issue."

We disagree totally with both of these statements and, without belaboring the point simply reaffirm the accuracy of the meeting summary.

Reference 2 reflects ourVIewsonthisissue.

Reference 2 also )rovides the NRC position on use of EDGs as AAC sources on the basis of " excess EDG capacity" and describes how the staff will review licensee responses to the SB0 rule which propose using EDGs in this manner, In regard to your battery-capacity / field-flashing question, the previously i

agreed upon position that momentary loads such as field flashing should be 3

considered (ReferenceNUMARC87-00,Pg.7-9)inthedeterminationofrequired battery capacity remains unchanged. The means of exit from an SB0 condition wy2 g

v NRC FILE CEES COPY 90062D0120 900619 Y g /ut PDR' REVCP EHONUMRC 4ejean w enu

A. Marion

-2 June 19, 1990 l

cannot be predicted, i.e., whether this results from recovery of offsite power or from restored operability of an EDG. Therefore, the possible prior restora-tion of EDG operability should not be preemptively discounted by lack of battery capacity for field flashing.

Sincerely, ORIGINAL SIGN ~ED BY A. C.THADAN; L

Ashok C. Thadani, Director Division of Systems Technology Office of Nuclear Reactor Regulation'

Enclosure:

LetterfromA.Marion(NUMARC)to A. Thadani (NRC) dated May 7, 1990,

Subject:

Meeting Summary - NUMARC/

L NRC Meeting of April 25, 1990, on StationBlackout(TAC 40577)

Distribution:

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N results from recovery of offsite power or fro restored operability of an EDG.

Therefore, the possible arior restoration of DG operability should not be preemptively discounted y lack of battery c acity for field flashing.

Sincerel,

Ashok. Thadani, Director Divis n of Systems Technology Offic of liuclear Reactor Regulation

Enclosure:

Letter from A. Marion (NUMARC) to A.

hdani(NRC) j dated May 7, 1990,

Subject:

Meeting Su ary - HUMARC/

NRC Meeting of April 25, 1990, on Stati Blackout (TAC 40577)

Distribution:

PDR Central Files OGC SELB R/F JSniezek TMurley/Thiraglia WRussell FRosa(PF)(2)

JPartlow SYarga EJordan BGrimes JEKnight PGill 4

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io cannot be pred 5ted, i.e., whether this results from recovery of offsite power or from restored %perability of an EDG. = Therefore, the possible prior restora.

tion of EDG operaklity should not be preemptively discounted by lack of battery capacity for field Tlashing.

Sincerely, Ashok C. Thedani, Director Division of Systems Technology Office of Huclear Reactor Regulation

Enclosure:

LetterfromA.Marion(NUMARC)toA.TAadani(NRC) dated May 7, 1990,

Subject:

Meeting Su g ron Station \\y - NUMARC/

'1 NRC Heetin of April 25, 1990, Blackout (TAC 40577 Distribution:

PDR Central Files i

OGC SELB R/F JSniezek TMurley/FMiraglia WRussell FRosa(PF)(2)

JPartlow SVarga EJordan BGrimes JEKnight PGill BBoger PTan JRaval CMcCracken RArchitzel

SEE PREVIOUS CONCURRENCE DTC :BC/SELB/ DST *:SELB/ DST *

SC/SELB/ DST *:ADT/NRR*

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NAME :FRosa:cn

PGill

JEKnight

WRussell

ACThadani DATE :6/11 /90

6/11 /90

6/11 /90

6/14 /90

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/90 OFFICIAL RECORD COPY Document Name:

F. ROSA

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ENCLOSURE' NUCLEAR MANAGEMENT AND RESOURCES COUNCIL 17M Eye st*eet N W e sJ e 300 + Washe909. DC 2D3424%

t (202) S724260 May 7, 1990 Mr. Ashok C. Thadani, Director Division of Systems Technology Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Code 8 E2 Washington, DC 20555

SUBJECT:

Meeting Summary - NUMARC/NRC Meeting of April 25, 1990, on Station Blackout (TAC 40577)

We have received the published summary for the subject meeting and believe a clarification is warranted. At this meeting we acknowledged that the recent concerns expressed by members of your staff relative to load management were not previously addressed to a comparable level of detail.

Also, we stated our concern that the current staff position appeared to

. represent a change in previous understandings relative to single failure and safe shutdown at the non-blacked-out unit. These understandings are represented in the NUMARC 87 00 guidance document, seminar questions / answers s and more recently in the suppleraental clarifications developed last December.

The Staff position referred to the subject meeting summary was not expressed in any of the NRC/NUMARC meetings during the development of the SB0 During the meetings last year that led to the Rule, RG 1.155 or NUMARC 87-00.

supplemental guidance, your staff requested utilities identify variations in This was delineated in the assumptions for loss of offsite power loads.

supplemental guidance questions / answers 3.4 and B.3.

The supplemental 4

responses provide the requested information from those utilities proposing load management or request further dialogue with the Staff due to the perceived change in position regarding use of the alternate AC option to achieve an acceptable safe shutdown condition for both the blacked out and non-blacked out units.. The statement as written in the third paragraph of the meeting summary is inaccurate and misrepresents the efforts NUMARC has taken in working with the NRC in understanding and developing a resolution to the station blackout issue.

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.y Mr. Ashok C. Thadani May 7, 1990 Page 2 i

Our fundamental purpose at the April 25th meeting was to fully understand your concerns and those of your staff relative to the load management proposed in the supplemental responses.

To this end, we agreed to review the NRC Staff's draft position and provide you with comments that address a process for achieving a safe shutdown condition.

I thank you for your support in ensuring that published meeting summaries accurately represent the discussions between the NRC and NUMARC.

t Sincerely, AS4 MA Alex Marion Manager, Technical Division AM/1jw cc:

J. H. Sniezek T. E. Murley F. J. Miraglia, Jr.

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