ML20062F559
| ML20062F559 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 12/12/1978 |
| From: | Grotenhuis M Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7812190154 | |
| Download: ML20062F559 (8) | |
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.wo.G 31 DOCKET NO. 50-232 and 50-506 DATE: Decer.ber 12, 1978 LICEilSEE: florthern States Power Company (flSP)
FACILITY: Prairie Island f:uclear Generating Plant Unit flos. I and 2 (PItiGP)
SUMMARY
OF MEETIflG HELO ON OCTOBER 26, 1978, TO O!SCUSS TECHilICAL SPECIFICATIONS FOR SECCTIDARY WATER CHEMISTRY, REACTOR COOLA:iT ACTIVITY AND SECONDARY C00LAfti ACTIVITY I,gthedqrfio'n On October 26, 1978, respresentatives of flSP met with the Regulatory Staff (staff) to discuss the model Technical Specifications attached to the Septemoer 7,1978, letter from A. Scnwencer to f45P. Tne letter requested that !!SP prooose Technical Specifications related to Secondary Water Chemistry monitoring, Reactor Coolant Activity, and Secondary Coolant Activity and enclosed model Technical Specifications for gu' dance.
A list of attendees is given in Attachment 1, and references in Attachment 2.
Background
On April 2,1974, an initial decision was issued (LBP-74-17) on PINGP for tne Operating license hearing. On September 25, 1974, a memorandum anci Order was issued (ALAB-230) remanding the proceeding back to the Muing board for further consideraticn of the issue of steam generator tube integrity.
On September 2.1976, the Atcmic Safety and Licensing Acpeal 30ard (ALA8) issued a decision (ALAB-3a3) pertaining to the integriv/ of the tubes in the Prairie Island Nuclear Generating Plant's (P'!!GP) steam gene ra to rs. On October 9,1976, before the time for Ccemission review of ALAB-343 (as extended) had exof red,the NRC staff sent a letter to tne Carmission in which it called attention to a "r'.oid" generator tute failure (evidenced by an 80 gom reactor coolant leak) which had occurred at Unit 2 of Surry six weeks earlier. The staff concluced that the PI!!GP proceeding need not te reccened because the Surry develcoments cresented "no pressing safety issue relevant to Prairie Island" for the reason tnat no tuce denting at PINGP had been cbserved.
73 9 190154 C
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On November 11, 1976, the Commission entered an order remanding the proceeding to the ALAB so they might "have the opportunity to consider the denting questions raised by the staff letter."
On August 15, 1977, after consideration of the denting issue, Memorandum ALAB-427 was issued by the ALAB which stated:
"In sum total, what has been placed before us reflects that both the staff and the industry have the denting phenomenon under intensive investigation. Although definitive conclusions may not as yet have been reached on each phase of the inves-tigation, what has been ascertained to date gives us reasonable cause to adhere to the belief expressed in ALAB-343 that Prairie Island is not likely to experience denting."
The conclusions reached in ALAB-343 are related to the following areas:
1.
Secondary water treatment, 2.
Technical specifications related to secondary water quality, 3.
Detectable leakage before tube failure, 4.
The efficacy of eddy current surveillance, b.
Tube plugging criteria, and 6.
Loss of coolant accident or steam line break with concurrent steam generator tube failure.
Upon reviewing the conclusions by the ALAB in the above six areas, the staff determined that action was required on the conclusions in areas 2, S and 6.
Action regarding the conclusions in areas 2 and 6 was taken by the staff in the SepteToer 7,1978 letter from A. Schwencer to NSP which included model Technical Scecifications. The NSP application for amendment dated May 25, 1978, and the staff review and approval in amendments 31 and 25 dated August 24, 1978, completed action required by the conclusion in area 5.
In resocnse to the September 7,1978, letter frca the staff, NSP requested a meeting with the staff in its letter dated Sectember 19, 1978, to discuss the model Technical Scecifications.
In its letter, NSP stated j
the following reason for requesting the meeting:
. "NSP has an adequate basis and understanding for preparation of a secondary water chemistry monitoring technical specifi-cation. There are questions which require discussion on the proposed reactor coolant / secondary coolant activity limits in the areas of (1) bases for the Standard Technical Specifi-cation (STS); (2) derivation of the STS parameters; (3) applicability of the STS to specific plants; (4) evaluation of data collected to date by the NRC through reporting of iodine spiking information; and (4) differences between STS 3.4.8/4.4.8, dated November 15, 1977, and the proposed technical specification contained in Reference (a)*".
The October 26, 1978 meeting was convened to discuss the above questions.
Summa rv Mr. Mayer reiterated the statement in his September 19, 1978 letter, that NSP had an understanding of the secondary water chemistry requirements, and added that NSP was prepared to submit proposed Technical Specifications in that area. However, he stated the NSP position is that there is no basis in the hearing record nor in any generic staff activity for the reactor coolant / secondary coolant activity Technical Specifications that the staff proposed as a model for PINGP.
The staff responded that the coolant activity licits in the model Technical Specifications, which are considered reasonable and achievable by the staff, are the limits used as a basis for the calcualtions made by H. Fontecilla. These calculations were in turn used as the basis for the testimony given by D. Ross in his affidavit da ted March 9,1976. This testimony is a significant part of the basis for the staff conclusion that the operation of the PINGP steam generators will not endanger the health and safet/ of the public.
Since the ALA3 nad tnis staff af#idavit as part of the information that it used to conclude (ALA3-343, p.202) that,
'Peference a is the SepteTuer 7,1978 letter from NRC
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i "there is present reasonable assurance that the public health and safety will not be endangered as a consequence of tube failure during operation of the Prairie Island facility.43 Notwithstanding this determination, in the interest of reinforcing the assurance of safety, we assume that the staff and the applicant will give effect to the several recomendations in this opinion bearing upon the various areas of concern discussed herein."
it is the staff position that the PINGP should be required to aperate within those coolant activity levels in the proposed Technical Specifications.
NSP offered several arguments in support.of its position. They are:
1.
The record shows that the calculations involved in the loss of coolant accident, or steam line break, with concurrent steam generator tube failure (ALAB-343 No. 6, p. 201) were based on very conservative assumptions (Ross affidavit, p. 8).
2.
The record shows that the calculations (see "1" above) identswere for accidents are not considered by the staff to be design basis acc (Ross affidavit, p. 1).
3.
The ALAB did not draw a conclusion regarding whether the accidents considered (see "1" above) should be classed as design basis accidents, but rather indicated that the additional generic analysis by the staff should be expedited (ALAB-343, p.172, p.198, footnote 41, p. 201).
J.
The calculations that formed the bt. sis for the accident conclusions (see "1" above) are not on the record, therefore PINr.D (Northe rn States Power Co.) nas had no opportunity to cross examine or rebut them.
5.
Technical Specifications pertaining to coolant activit; were not explicitly oroposed by the staff such as those for steam generator tube inspection and secondary water chemistry.
6.
The Technical Scecifications pertaining to coolant activity are not being generically applied to all PWRs by the staff.
. The above positions of NSP and the staff were discussed at length and it was agreed by the attendees that this subject be elevated for consideration by NRC management.
In addition, H. Fontecilla 3 greed to try to locate the calculations which were used to provide the dose values in the Ross affidavit (pp. 8 & 9).
Following the above discussion detailed technical questions frem N5P regarding the proposed coolant activity Technical Specifications were discussed.
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' P.arih'a'll Grotenhuis, Project Manager Operating Reactors Branch #1 Division of Operating Reactors Attachmen t:
List of Attendees References cc w/ encl:
See next page 4
Meeting Summary for tortnern States Power Company Docket File NRC POR Local POR ORBI Reading fiRR Reading H. Denton E. Case V. Stello D. Eisenhut B. Grimes D. Davis D. Ziemann P. Check G. Lainas A. Schwencer R. Reid T. Ippolito V. Noonan J. McGough Project Manager OELD Ol&E(3)
ACRS (16)
C. Parrish NRC Participants TERA J. R. Buchanan Licensee Northern States Power Co. (Lee Mayer)
l LIST OF ATTEtl0EES i
i flRC M. Grotenhuis E. Adensam H. Fontecilla M.'Kaczmarsky l
NSP L. Mayer 3
J. Gonyeau J. Hayes t
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REFERENCES 1.
LBP-74-17 April 2,1974, RAI-74-4, 487 (1974) 2.
ALAB-230 September 25, 1974, RAI-74-9, 458 (1974) 3.
Affidavit of Denwood F. Ross, Jr., Supplemental Testimony of Denwood F. Ross, Jr. dated March 9,1976 4.
ALAB-373, September 2, 1976 NRC 1-76/9, 169 (1969) 5.
ALAB-427, Augus t 15, 1977, 6 NRC No. 2 212 (1977) 6.
Letter from A. Schwencer, NRC, to L. O. Mayer, NSP, dated September 7, 1978.
7.
Letter, L. O. Mayer, NSP to Director, NRR, dated September 19, 1978.
8.
Arendment request from L. O. Mayer, NSP, to Director, NRR, dated May 26, 1978 9.
Letter frem A. Schwencer, NRC, to L. O. Mayer, NSP, transmitting Arendment Nos. 31 and 25 dated August 24, 1978 l
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