ML20077M807
| ML20077M807 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 01/03/1995 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-59FR52707, RULE-PR-50 59FR52707-00017, 59FR52707-17, NUDOCS 9501130177 | |
| Download: ML20077M807 (9) | |
Text
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DOCKET NUMBER
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ROCHESTER GAS AND ELECTRIC CORPORATION
- 89 EASTAVENUE, ROCHESTER, N Y 14649 0001 4 AREA CODE 716 546-2700 N N 5-Q ROBERT C. MECREDY 35 JAN # P-2-n"f
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q v,ce Pm, dent Nuclear opero ;ons s
0FFl[L OF W M l ARY January 3, 1995 DOCKE TihG.. 1 E M.:
- hR MR Secretary U.S. Nuclear Regulatory Commission Washington,-
D.C.
20555-0001 ATTN:
Docketing and Services Branch
Subject:
Comments on the Proposed Rule for Shutdown and Low-Power Operations R.E. Ginna Nuclear Power Plant Dock 3t No.30-244
Dear Mr. Secretary:
The following are Rochester Gas and Electric (RG&E) comments to the proposed rule,." Shutdown and Low-Power Operations for Nuclear Power Reactors", noticed in the Federal Register dated October 19, 1994 (Ref. 59 Fed. Reg. 52707).
We have reviewed the Nuclear Energy Institute (NEI) correspondence from Mr. William Rasin to the NRC dated January 3, 1995, and the Westinghouse owners Group correspondence (OG-94-103) from Mr. Roger A. Newton to the NRC dated December 27, 1994, which provide NEI and industry comments to the proposed rule.
We have also reviewed the correspondence submitted on our behalf by NUBARG (Nuclear Utility Backfitting and Reform Group) to the NRC, dated January 3, 1995.
RG&E supports the NEI and NUBARG comments, and we also acknowledge and generally support the WOG comments.
RG&E has participated in industry, Owner's Group, and Nuclear Energy Institute (NEI) efforts for many years concerning the safety of operations during shutdown and at low RCS loop levels.
RG&E has made considerable improvements in outage safety through planning and implementation of defense in depth provisions as a result of the actions taken in response to Generic Letter 88-17.
Those provisions included installation of additional instrumentation, procedures, equipment availability to support water level inventory and RHR operation, technical analyses, and containment closure requirements.
We have also utilized the guidelines of NUMARC 91-06, " Guidelines for Industry Actions to Address Shutdown Management", in our outage planning process.
The planning, management, and conduct of safe and efficient refueling outages is essential to the overall success of RG&Es nuclear business.
We are very concerned that the direction and 9501130177 950103 PDR PR 50 59FRE2707 PDR yo
2 content of the proposed rule has discounted the efforts made in achieving the goals of GL 88-17 and the industry self-initiatives provided in NUMARC 91-06.
We believe that the efforts we have taken in response to GL 88-17 ensure the protection of the health and safety of the public and have consistently improved the overall safety of shutdown operations.
A number of regional inspections have been conducted which have focused on operation during reduced inventory and reviewed RG&Es implementation of GL 88-17.
Inspection Report (IR) 89-05 (5/23/89) reviewed RG&Es " expeditious actions" and Inspection Report 91-10 (6/5/91) reviewed Ginna Station's 1991 outage operations and concluded that "RG&E exercised rigid control of plant activities to assure that the draindown (to reduced inventory) was performed in a safe and conservative manner".
IR ned enhancements" and examined 91-18 (11/4/91) reviewed our " prog :
o midloop operating procedures, a
esentative calculations, and completed modifications.
The inspection concluded that the programmed enhancements were adequately implemented, and no unresolved items were identified.
It was documented that "RG&E had implemented visible and audible indications of temperature, level, and RHR system performance, and verified that RG&E had implemented procedures and administrative controls to preclude operation that would lead to perturbation of the RCS".
Midloop operation was again examined during the 1992 outage and reported in IR 92-003 (5/11/92).
The inspection utilized TI 2515/113.
It was noted that in addition to previous GL 88-17
- actions, RG&E restricts operations at the power distribution substation, which provides offsite power during midloop operations.
It was stated that Ginna Station " demonstrated an excellent effort to maintain uninterrupted core cooling and that the procedure used to establish midloop level was accomplished in a deliberate and generally well controlled manner".
It was concluded that
" preparations for midloop operations were thorough and effectively implemented".
Similar statements were also provided in the Inspection Report 94-07 (5/24/94) representing our 1994 outage.
1 These inspections clearly communicated to RG&E that our conservative actions taken in response to GL 88-17 and applied to reduced inventory operation were both effective and in the best interest of safety, while continuing to preserve the short length of our outages.
1 Based upon the Regulatory Analysis presented as part of the rulemaking process (Enclosure 1 to SECY 94-176), we do not believe l
the proposed rule has been shown to be a cost-justified safety improvement, and will have the immediate effect of causing a substantial increase in outage duration and cost.
The regulatory analysis assumed that the proposed requirements will not lead to an j
increase in the duration of outages on an industry-wide basis, therefore, zero cost was assumed.
The analysis states that poor planning is usually the reason outages are not completed on i
l
e 3
schedule and concludes that improved planning and controls over the outage as a result of the rule will help to eliminate any delays caused by the increased requirements.
In addition, the analysis was based on an average length of an outage being 50 days for PWRs.
RG&E disagrees that these estimates are representative for Ginna Station or the PWR plants in the irsdustry as a whole.
Our estimates indicate that outage duration will increase by a minimum of 6 days, primarily as a result of two provisions:
1) the requirement that containment integrity be maintained at times when little safety benefit would be provided; and, 2) the requirement that no credit may be taken for offsite power in establishing redundancy in electric power systems.
At Ginna Station, we have carried out carefully planned annual refueling outages for many years, such that our average outage duration is only about 45 days per year.
We expect to be able to reduce this to 35 days per 18-month refueling cycle following our 1996 Steam Generator Replacement Project.
We do not believe that improved planning and controls, as suggested in the regulatory analysis, can eliminate the need to add at least 6 days to each refueling outage.
The proposed rule also codifies the requirement for a formal outage planning and control program for shutdown operations.
We believe this will create a tendency to undermine plant self-initiatives that would take place in a performance-based regulatory environment and shift emphasis solely toward a compliance-based one.
We appreciate the intent to maintain a balance in this area, however, the proposed rule exemplifies strict and prescriptive requirements, with no credit given for previous improvements, and without adequate rationale (as admitted by the NRC itself when noting these regulatory provisions could not be quantitatively cost justified).
The NRC has recently, and rationally, espoused new regulations and guidance which is performance based, such as the Maintenance Rule.
This performance based methodology appears to have been discontinued in the promulgation of the proposed shutdown rule.
We believe that efforts to impose strict requirements as proposed for the entire industry for the purpose of establishing a
consistent implementation (a so-called " regulatory footprint") of the safety improvements and benefits achieved as a result of GL 88-17 and NUM7RC 91-06 is inappropriate.
We believe that if the NRC
)
has concerns related to implementation of requirements and commitments while operating at reduced inventory, those concerns should be, and probably have been, discussed with those individual licensees.
Our review of the regulatory analysis involving the i
calculations of core damage frequencies showed that the WRC i
estimate for the probability of the loss of offsite power (LOOP) are an order of magnitude high and several assumptions made with respect to mitigation of the loss of DHR are not reasonable for 1
1
l l
4 Ginna Station.
Applying more reasonable values and assumptions results in core damage frequencies for the existing plant configuration (base case) less than those estimated to result from the NRC improvements in Technical Specifications, outage planning, and instrumentation.
Therefore, based on the risk assessment the
- proposed improvements are not justified.
Based on the
- above, and specific comments provided in Attachment A, we do not believe the rulemaking has demonstrated a representative and cost-justified benefit to the health and safety of the public, that it will result in unnecessary delays and costs associated with refueling outages, and should not be promulgated as currently proposed.
Comments involving specific sections of the proposed rule are included in Attachment A.
We appreciate the opportunity to comment on this important rulemaking.
Ver ruly Your,
^1th Robert C. Mecr dy GAH/
(
3:
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ATTACHMENT A
-f
-i Comments to Soecific Sections of the Proposed Shutdown Rule e-RGGE' endorses-the industry comments provided as Enclosure 1 of the NEI letter from Mr. William Rasin to the NRC, dated January 3,
1995.-
In addition,.we offer the following' comments to specific sections of the proposed rule.
j i
(c) General Reauirements (c)(1) Reactivity and Inventory Chanaes and Subcoolina Loss Inclusion of Low Power requirements within the rule in addition to Shutdown operation adds confusion and creates conflicts with Technical Specifications which already include requirements for low power. operation.
t The requirement to provide assurance that uncontrolled changes never occur, is one that seems to serve solely to provide the basis for enforcement of a violation, when safety may never-
'have been compromised.
There is no distinction nde with i
regard to what a " change" in these parameters is limited to.
j We believe that, if the intent of the paragraph is to demonstrate that a loss of decay heat removal (DNR) that could i
lead to a release.in excess of the guidelines of 10CFR Part 100, then this should be the focus of the paragraph.
The loss i
of subcooling requirement is too restrictive in that, in and l
of itself, the temporary loss of a subcooled state is not necessarily a safety issue, given that mitigative methods and equipment such as gravity feed, safety injection and charging.
l pumps, would be available (GL 88-17 programmed enhancement).
In addition, maintaining reactivity less than Kaff of 0.95 is-j already required by Technical Specifications.
It is overly i
restrictive to require that no changes in reactivity may occur without causing a violation of'the rule.
(c) (2) Maintenance and Reestablishment of Containment Intearity l
We believe that containment closure as defined under GL 88-17 already protects the public from a release in excess of_the i
Part 100 guidelines.
The new proposed containment intearity i
requirement will result in the ancillary requirement to either offload the entire core during refueling outages or maintain containment integrity until the refueling cavity is filled.
The increase in requirements between containment closure and containment integrity is not justified in view of the extensive modifications, procedural controls, and technical analyses which were performed under GL 88-17, establishing that containment could be closed within the time commensurate with analyses, thereby protecting public health and safety.
This additional requirement, beyond what was required under GL f
--5---
l
'[
t 6-l ATTACHMENT A I
Cc==ents to Soecific Sections of the Proposed Shutdown Rule 88-17, goes beyond what NRC has identified as the need to set a regulatory standard, and to ensure-that improvements already i
'made are not eroded in the future.
l
-i The proposed requirement dictates establishing containment j
integrity in a timely manner as needed to prevent releases in i
excess of the guidelines of 10 CFR Part-100..However, there is no guidance in the rule or draft regulatory guide that defines what " timely" is.
If timely is meant to imply the time c.t which core uncovery could occur due to the loss of j
DHR, then the times established for containment closure under GL 88-17 would be implied.
If the time to boil is intended, then timely would imply perhaps 10 minutes during the'early
.I stages of an outage. This would certainly dictate maintaining containment integrity until the cavity is filled or the fuel is offloaded to the spent fuel pool.
The current practice of using the equipment hatch for loading and unloading outage equipment prior to the cavity flooding would have to be 1
discontinued.
With the hatch in place loads would have to be l
reconfigured to fit through the personnel doors or movement
[
delayed until the cavity is flooded. Clearly, additional time would be required in either case, and no costs or increased j
time has been included in the regulatory analysis to cover ~
'i' this modified evolution.
(c)(3) Identification and Control of Safety Eauipment (i) (A)
The equipment and systems necessary to make the reactor critical in a controlled manner are already included in the Technical Specifications and proceduras.
We fail to see the need for this requirement.
(ii)
It is unclear whether the controls for the equipment identified in (c) (3) (i) are intended to allow use of non-safety related systems or components. Use of the phrase,
... perform their safety function... " would seem to imply only those that are safety related.
In addition, non-l safety related equipment is not generally required to be surveilled and assured operable in the same manner as safety related equipment.
Such equipment is often not i
powered by the onsite electric power system, therefore, it would appear that no credit could be taken for such equipment.
The draft regulatory guide states that the I
equipment that is " capable" and "connectable" to protect the safety related functions, should be tested and maintained in a way that provides high confidence that it would perform as required, implying safety related.
The wording and guidance is not consistent with the l
i l
1 7
ATTACHMENT A Comments to Specific Sections of the Proposed Shutdown Rule performance based guidance provided under the draft regulatory guide for section (c) (4) of the proposed rule, which covers fire protection.
That auidance clearly states that use of non-safety related systems may be applied.
The requirement to assume the single failure of any of the equipment or systems identified as part of (c) (3) (1),
without taking credit for availability of the offsite power system has not been adequately justified in the regulatory analysis.
We believe that if the concern deals with providing suitable redundancy, assuming a single failure, flexibility should be given to satisfy the safety objectives during shutdown periods and while critical safety equipment is unavailable due to maintenance.
This is already a
key part of the Maintenance Rule.
In order to comply with this proposed new requirement, both ehrgent:y diesel generators (EDGs) would have to remain operable unless the refueling cavity is flooded to a level of 23 feet.
The normal time during which the cavity is flooded is typically 5 days.
Redundancy is now maintained for active components when the cavity is not flooded; however, redundancy cannot be maintained for certain passive components such as heat exchangers or flow paths.
By extending this flooded window in order to encompass the EDG maintenance, the new requirement will add 6 days to the length of the outage, equal to the normal time to' perform annual inspections, maintenance, and tests required on the EDGs.
The regulatory analysis assumed no increase in outage duration as a result of this requirement, and did not provide an adequate basis for the rationale that offsite power sources may not be assumed functional.
Given the reliability of these offsite systems as compared to the unquantified functionality of connecting and using a portable onsite source of backup power (as suggested by the NRC staff),
disallowance of offsite sources is not understood.
It also appears that should a forced shutdown be required in order to repair an inoperable diesel generator or other identified equipment, the plant may be out of compliance with the rule with few available options.
The loss of offsite power (LOOP) probability utilized in the regulatory analysis is far greater than that developed as part of the Ginna PRA.
The LOOP event is
}
not a dominant contributor to CDF for Ginna Station.
We
1 4
8 ATTACHMENT A Comments to Soecific Sections of the Proposed Shutdewn Rule estimate that it contributes only 3.5% to the Level 2 PRA core damage frequency. The value of 0.25 was used in the regulatory analysis (ENCLOSURE 2,
Appendix 2).
A realistic value of 2.5 E-2 is consistent with the results, tabulated in NSAC-182 and NSAC-111 and is an order of magnitude less than that used in the regulatory analysis.
Further, the analysis states that the value of 0.25 was based on 30% of the nuclear power plant switchyards and was assumed to apply across the entire industry.
We question the validity of that assumption, given the data already available in the cited NSAC documents.
Additional factors applicable to Ginna result in the l
regulatory analysis being overly conservative.
When the RCS is open, a large vent (pressurizer manway) is always open as a result of commitments made to GL 88-17.
This large vent is also adequate to handle pressurizer surge line flooding issues.
Therefore, the Large Vent Path event trees in the risk assessment (Figures 7 and 10, ENCLOSURE 2, Appendix 2) are not applicable for Ginna.
In addition to gravity feed, our GL 88-17 commitments require one charging pump to be operable during reduced inventory conditions.
Therefore, at least two means of providing water already exist, making the NRC values for failure to provide water addition overly conservative.
In summary, from a risk assessment standpoint the effect of utilizing realistic assumptions based upon plant-specific features for Ginna Station results in CDF values which already are less than those that have been calculated by NRC after including the improvements of Technical Specifications, outage planning, and level instrumentation.
These factors, combined with outage durations that are typically shorter than the 50 days assumed in the regulatory analysis, will result in a substantial decrease in the calculated CDF as compared to that utilized in the regulatory analysis and therefore show the proposed rulemaking not justified.
Finally, the proposed section includes requirements for single failure criteria.
Since many plants including Ginna Station were constructed and licensed prior to the l
completion of the General Design
- Criteria, strict l
compliance with the single failure criteria was not required.
Except in certain specific cases, passive failures were not required to be assumed.
Under the proposed rule, it is unclear whether strict compliance must'be assumed for the single failure criteria when it
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7 m.
9 t
l ATTACHMENT A s
.t Comments to Soecific Sections of the Proposed Shutd@n Rule
'l l
would' conflict with the current licensing basis.- As-an:
~
example, the RHR system contains a single drop suction-l line from the RCS loop
'A' hot-leg leading to. redundant i
RHR pumps.
There is no-guidance, or additional - cost-~
associated with issues such as this in the analysis..An upgrade to the single drop.line design could. cost ~ an 1
order of magnitude $10 million dollars.
2 (d) Reauir===nts for Licensees of PWRs This requirement dictates installation of additional water level monitoring instrumentation.
Section (c) (3) requires identification.of equipment necessary to monitor water level in the raactor vessel, and redundancy in such components j
without assuming offsite power available.
It isn't clear whether any credit can be taken for the instrumentation installed under GL 88-17.
Instrumentation at Ginna Station t
installed under GL 88-17 is redundant and not affected by the j
loss.of offsite power.
The focus of the new instrumentation j
appears to be the same as intended under GL 88-17, to provide reliable level instrumentation for the purpose of preventing the loss of RHR due to loop levels below the level.at which RHR can operate satisfactorily.
Many plants, including Ginna-Station installed other monitoring /as well, such as NPSH'and motor current indicators.
Additional level instrumentation, i
that essentially meets the same purpose and function and unilaterally discounts that already installed under GL 88-17, l
has not been justified in the proposed rulemaking.
Draft Reaulatory Guide l
RGEE endorses the industry comments provided as Enclosure (1) of 1
the NEI letter fror. Mr. William Rasin to NRC, dated January 3,
1995.
The regulatory guide, for the most part, with the exception of Section (c) (4 ) Fire Protection, is a restatement of the rule.
- However, the sections covering outage planning are worded as required actions as opposed to guidance.
Item (c), in particular, which requires a " controlled information system to be present to provide critical safety parameters and equipment status on a real-time basis during the outage", is unclear as to its expectation.
We do not believe there is a need for Item (f), which rsquires administrative controls to ensure that
" staffing needs and personnel capabilities are considered, with emphasis on control room staff", since the level of operator training and qualification and staffing levels are already adequate.
,