ML20054D787

Responds to ASLB 820401 Request for ACRS Info Re Emergency Feedwater Sua Sponte Issue.Acrs Conclusion Is Consistent W/ Applicant Position That Issue Be Resolved Generically.Issue Is Not Serious Safety Matter.Related Correspondence

ML20054D787
Person / Time
Site:	Waterford
Issue date:	04/08/1982
From:	Churchill B LOUISIANA POWER & LIGHT CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Foreman H, Jordan W, Wolfe S Atomic Safety and Licensing Board Panel
References
NUDOCS 8204230385
Download: ML20054D787 (3)

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SHAW, PITTMAN, PoTTs & TROWBRIDGE 1800 M STRE ET. N. W.

WASHINGTON. O. C. 20036 EAMSAY D POTTS MARM AUGENSUCK ROBERT 3. ROSSINS BONNIE S GOTTute STE UART L. PITTM AN E RNEST L slant. JR. 12O28 822-tOOO STEVEN M. LUCAS MOWARD M. SMAFFERM AN CEORGE F. TROW 3 RIDGE CARLETON S JONES DAVID M. RUBENST[lN DEBORAM S BtUSER CTEPHEN O POTTS TMOMAS A. eAxTER - LYNN WHITTLESEY WILSON SCOTT A. ANENBERG CCLtAD CHARNOFF JAMES M. SURGER MATeas F. TRAviESO-DsAZ SETH M. MOOGASI AN FMILLIN D SOSTWiCK SMELDON J. WEISEL TELECOptER VICTORI A J. PERKINS SMEILA McC. MARVgy R TsMOTMY HANLON JOMN A. McCULLOUGH JOHN M. O'NEILL. JR. DEUS $A A. RfDGwAY CEORGE M ROGERS.JR. J. PATRICK MsCKEY 82021 822-1099 & S22-6199 J AY A. EPSTIEN RENNETM J MAUTMAN FIED A UTTLE GEORGE P MICM AELY. JR. - MAND L ALLEN DAVID LAWRENCE MILLER JOMN5 RMtN E LANDE R JAMES TMOMAS LENHART TIMOTHY B McBAsDE ANNE M. MRAUSMDpr  !

OrTUCC W CMURCHILL STEVEN L MELTZER TELEX ELISABETH M. PENDLETON FREDERICM L. MLEIN LEILit A N6CMOLSON JR. DEAN D AUuCM PAUL A. KAPLAN - GORDON R. KANDFSKY MAttlN D MRALL JOMN ENGEL 89-2693 ISMAWLAW WSM) MARRY M.. GLASSpeEGEL r SALLY C. ANDREWS StsCHARD J. MENDALL CMARLES 9. TEMusN cAggg gganggwo TMOM AS M. McCORMeCM , JEFFREY S. GaANCOLA JAY E. SiLBERG STEWMEN B MUTTLE R WILLI AM P. BARR MANNAM E. M LIE BERM AN CAMARA M. ROSSOTTI WINTMROP N. BROWN - SUSAN M. FREUND SANDRA E. FOLSOM CEO3GE V ALLEN JR JAMESB M AM LIN JCMN L CARR. JR. M ARCI A R NIRENSTEIN KELL WRITER S DeRECT DIAL NUMBER PMium J. MARVEY JUDITH A. SANDLER FRED R ME~Lv DRASN.ER wE ST E R RAN.DAL8 RO - E . 2 '"" " " " " ' " "

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Y Sheldon J. Wolfe, Esquire Dr. Harry Forem q & &. ,'&,c.-qQy Administrative Judge Administrative J Tfg Chairman, Atomic Safety and Director, Center for Licensing Board Population Studies U.S. Nuclear Regulatory Box 395, Mayo Commission University of Minnesota Washington, D.C. 20555 Minneapolis, MN 55455 Dr. Walter H. Jordan Administrative Judge 881 West Outer Drive Oak Ridge, TN 37830 In the Matter of Louisiana Power & Light Company (Waterford Steam Electric Station, Unit 3)

Docket No. 50-382

Dear Administrative Judges:

During the hearing session on April 1, 1982, the Board asked to be provided with copies of any ACRS action taken as a result of the April 2, 1982 ACRS meeting which was related to the Emergency Feedwater System sua sponte issue. Tr. 1815-16. )

Applicant has just received a copy of the ACRS letter dated April 5, 1982 which reports on its meeting held April 1-2, 1982.

A copy is attached for the Board's information.

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• l SHAW, PITTMAN, POTTS & TROWBRIDGE Administrative Judges Page Two April 8, 1982 The ACRS concurred in the Staff's proposal to address the question of the need for rapid depressurization, but con-cluded that resolution "should not now be a condition for operation of System 80 plants at full power, or of plants having similar features." This conclusion of the ACRS is consistent with the Applicant's position that the issue is appropriate for generic resolution, rather than determination in an individual licensing proceeding, and that it is not a

" serious safety matter" requiring urgent resolution via sua sponte consideration in the Waterford 3 proceeding.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By /

W W. N ill

- Counsel for Applicant Enclosure cc: Service List 1

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,, UNITED STATES f 7 n NUCLEAR REGULATORY COMMISSION

! 3 .. E ADVISORY COMMITTEE ON REACTOR SAFEGUARDS -

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April 5, 1982 q Mr. Willian J. Dircks ...

Executive Director for Operations. .

f; U. S. Nuclear Regulatory Commission.'. , g Washington, DC 20555 , ,

Subject:

RELIABILITY OF THE SHUTDOWN HEAT REMOYAL SYSTEM ON THE SYSTEM 80 DESIGN ,

The ACRS in its December 15, 1981 report to Chainnan Palladino on the 5 Combustion Engineering, Inc. Standard Reference System 80 commented on the reliability of the decay heat removal system. These comments addressed the lack of a capability for rapid, direct depressurization of the primary sys-tem to allow feed and bleed operations and the reliance placed upon the secondary system for heat removal capability. The ACRS Subcommittee on Decay Heat Removal Systems met with representatives of Combustion Engineer-ing Inc. and the NRC Staff on March 16, 1982 to discuss these issues. The ACRS discussed these issues further during its 264th meeting, April 1-2, -

1982. .

Representatives of Combustion Engineering have defended their design, stat-ing that: .

1. The System -80 NSSS will be coupled with highly reliable emergency ,

feedwater systems (EFWS) by addition of an interface reguirement that the EFWS have an unavailability in the range of 10 4 to 10-5 ~

per demand.

2. The System 80 NSSS is capable of achieving cold shutdown conditions

, using only safety grade systems even without offsite power and with an added single failure.

3. The System 80 steam generator design includes many features that I

will assure adequate tube integrity, minimizing concerns associated with operating reactors.

4. Even if all auxiliary feedwater supply were somehow lost, the secon-dary side of the. steam generators could be depressurized to allow use of low head pumps which might be aligned to provide water to the steam generators from a number of sources.

! 5. Probabilistic analyses have not shown that installing PORVs will result in a significant improvement in safety. The added costs l are not justified.

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.. , l William J. Dircks April 5,1982 e

Combustion Engineering has proposed that the issues associated with the E Committee's comments on the.Systeth 80 design be resolved in a continu- -

ing dialogue among the ACRS, the NRC Staff, and Combustion Engineering. .

It is the NRC Staff's intention to ' address these issues on an expedi-

• tious schedule with all applicantis request'ing licenses for Combustion Engineering NSSS designs which do not have capability for rapid depres- -~

'suri~zation independent of the steam generator. We concur with this ap- ~

proach and wish to be kept informed. ~

The Combustion Engineering response to the Committee's comments on the System 80 design emphasizes the expected very high reliability of the feedwater systems and the integrity of the steam generators. We believe that..these are necessary goals but note that past operating experience indicates that these goals are difficult to achieve. We believe that for this reason Combustion Engineering and the NRC Staff should consider fur-ther the' addition of valves of a size to facilitate rapid depressuriza-tion of the System 80 primary coolant system as stated in the Committee's December 15, 1981 letter on the System 80 design. We believe that a plan for addressing this issue should be fomulated in the near future. We wish to be kept informed and to discuss this further with Combus' tion Engineering-and the NRC Staff.

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We believe that, while this evaluation should be conducted expeditiously, its resolution should not now be a condition for operation of System 80  :

plants at full., power, or of plants having similar features. The need for  :

future hardware or procedural changes should be contingent upon results of this evaluation.

Sincerely,

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l P. Shewmon Chaiman l

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UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION I l

4 Before the Atomic Safety and Licensing Board ,

In the.. Matter of )

LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382

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(Waterford Steam Electric

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Station, Unit 3) )

'is SERVICE LIST Sheldon J. Wolfe, Esquire .Lyman L. Jones, Jr., Esquire Administrative Judge Post Office Box 9216 ~

Chairman, Atomic Safety and Metairie, LA 70055

, Licensing Board U.S. Nuclear Regulatory Luke B. Fontana, Esquire Commission 824 Esplanade Avenue Washington, D.C. 20555 New Orleans, LA 70116 Dr. Harry Foreman Atomic Safety and Licensing Administrative Judge Board Panel Director, Center for U.S. Nuclear Regdlatory Population Studies Commission Box 395, Mayo Washington, D.C. 20555 University of Minnesota Minneapolis, MN 55455 Atomic Safety and Licensing Appeal Board Panel Dr. Walter H. Jordan U.S. Nuclear Regulatory Administrative Judge Commission '

881 West Outer Drive Washington, D.C. 20555 Oak Ridge, TN 37830 Docketing & Service Section (3)

Sherwin E. Turk, Esquire (4) Office of the Secretary Office of the Executive U.S. Nuclear Regulatory Legal Director Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission  :

Washington, D.C. 20555

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Chairman Nunzio Palladino )

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

Commissioner Victor Gilinsky U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Commissioner Thomas Roberts U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Commissioner John Ahearne U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Office of The General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555