ML20098A089
| ML20098A089 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/06/1984 |
| From: | Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Arlotto G NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20098A079 | List: |
| References | |
| NUDOCS 8409240280 | |
| Download: ML20098A089 (4) | |
Text
'
2840815030 JUL 6 1964
- Ftr. Guy A. Arlotto, Director Division of fugineeriny. Technology U.S. NRC liashington, DC 20555 Snbj ect:
Froposed Revision to 10CFIGO, Appendix J Doar Afr. Arlotto:
We have reviewed those materials made available for ACRS review of the proposed revision to 10CFRSO, Appendix J via your letter to R. F. Fraley (ACRS) dated May 18, 1984 In general, we are supportive of your efforts "... to update the regulation and make it more effitient."
However, the proposed revision appears to go substantially beyond this type of an effort in severn! key areas.
The attachment to this Ictter suenarizes our major comments on the proposed Appendix.7 revision. These and other specific comments will be submitted during the formal public coniment period.
Our major consnents are being submitted at this time to facilita*,, your timely consideration.
Pleast: do not hesitate to contact us for further discussion of this topic.
Very truly yours, t'
~ g.
{h kl(i m -
N fn DiUl/cav/C0 Attachment bee:
.I.
S. Kemper I.. ii. l'y r i h l..
18.i l I rail'1
.l.
.\\l.2 s k.n.
I:
- 1. C. Kistner H. A. Slall'ord
.tl. J. Cooney l'.
A. Tutton li. T. Ullrich T. ii. Craig, Gl. (SI/C 855)
H. S. I'l e i s chma nn, il
- 1. R. li.syes, Gl. (kl!C (iS2)
G. St. I.eitch Is. L:. Stell.i n i e l, lie cht e l S..l. kowa 1 ski
- r. lirin n, ANS 5ti. 8 Cha i rman h
O A
l l
~
2840815030
$99"lgn,t,q,q 1,,11r39,@.M Jir.3 (; i o n to 10CFil50 Appendix J t
1.
The implementation of the existing Appendix J requirements at units which began operation prior to Appendix J promulgation
'has been a long drawn-out process.
This effor t has just recently been completed for our Peach Bottom units after seven years of deliberation.
The following is a chronology of significant milestones in this process:
8/13/76 PECo submits App. J exemption requests 11/18/76 PECo submits App. J license amendment request 1/22/81 NRC requests additional information 5/15/81 PECo updates 1976 submittals 9/12/83 NRC notification of Contractor SER.
results by telephone C
4/19/84 PECo submits revised amendment request It appears that our Appendix J compliance review will have to be repeated when the proposed revision is adopted.
Such reevaluation can not be considered as "... updating the regulation and taking it more efficient".
A somewhat similar " double jeopardy" situation exists for recently licensed units or those in the current licensing pipeline such as our Limerick station.
We have just completed a very thorough programmatic review of Appendix J compliance and would seeming.ly have to reopen this whole subject.
Appropriate words should be added to the proposed regulation and/or Regulatory Guide to reflect the status of completed Appendix J reviews.
The draf t Federal Register notice indicates that one of the major changes to Appendix J is to provide "... greater flexibility... for dealing with plants already built...".
However, provisions for such flexibility do not appear to be included in the actually proposed Appendix J revision.
The proposed change would seemingly invalidate exemptions and/or interpretations previously accepted by the staff by defining valves subject to test as "any valve defined in GDC 55, 56, or 57."
In fact, the draft Regulatory Analysis notes that modifications may be required for a number of plants...-...
2840815030 l
2.
One of the mont significant proposed chant n to A)pendtx involves the accounting for "as found" containment leakage.
The approach required by the proposed revision has not been generally employed throughout the industry based on a 1903 survey of DWR's.
The fact that this was a major issue under consideration in the Appendix J revision procesu did not, however, prevent the staff from imposing the new requirements on individual licensees (see BWR Owners' Group letter to D.
G. Eisenhutt (NRC) dated 3/4/83).
We can appreciate the staff's concern that current methods of
' test result reporting do not enable them to accurately determine the "as found" leakage rate of containments.
However, this. data repor ting problem does not appear to warrant the major program and acceptance criteria revisions being proposed.
It seems logical to improve data reporting, as required by the proposed revision, and evaluate the results for some reasonable period of time b'efore imposing revised acceptance criteria.
This seems to be a more prudent 4 -
course of action given the staff's own assessment that there is "... a low potential for reducing risk..." through the Appendix J revision process (see NUREG-0933 and W. Minners (NRC/SPEB) memo for G. W. Knighton (NRC/RSCB) dated 7/15/82).
3.
The proposed revision to Appendix J incorporates requirements for reassessment of leak rates every time a repair is made or a supplemental leak test performed in order to approximate "continous monitoring" of containment integrity.
While this might apear to be an attractive proposal from a regulatory point of viaw, it may actually have a negative impact on plant safety by providing a disincentive for normal monitoring and repairs between refueling outages.
If the proposed change was adopted, plants would be encouraged to live with certain levels of leakage which could be reduced rather than open up the issue of compliance with Appendix J acceptance criteria.
(
4.
The draf t Federal Register notice solicits comments on the concepts of " continuous containment leakage monitoring" and "relatively frequent gross containment integrity checks".
It should be noted that for BWR's with iner ted containments monitoring of containment oxygen concentration, nitrogen makeup, and/or venting frequency provides a fairly good indicator of containment integrity although precise quantification of leakage rate is difficult.
On at least one occasion such monitoring enabled us to detect a maintenance error which had violated. containment integrity at Peach Bottom..
- - - - - - - - -, - - - -, - - -,,,, -, - -. ~,,, -, - - - - - -
,-,--,,-,---,--,--n
i 2840815030
/ne proposed revision recogni/.ec toat ;.-.seceptance ertter:n for Type A tests is.75 La for "as le: t" conditions and La for "as found" conditions.
This logic has not been extended to the. acceptance criteria for Type a anr1 C Lests.
The proposed revision states that the acceptance criteria for Type D & C tests is.60 La for both "as found" and "as lef t" conditions.
If the proposed two-tiered acceptance criteria are to be retained, the criteria for "as found" Type B & C leakage should be relaxed to La.
- 6. -Proposed Regulatory Provision C.2.
states that "Following structural changes and repairs, a structural integrity test may be required prior to the Type A test" without describing the mechanism for making this determination.
More specific guidance should be provided to prevent confusion.
Prepared by:
D.
R. Helwig June 25, 1984 DRH/cmv/31-rev. to 10CFR50
-~
2840815030 y[.... %"'c, UNITE D sT ATEs g-
.,,j NUCLE AR REGUL ATORY COMMISSION wasmuctos o c rosss
%,...../
M I 61984 i
MEMORANDUM FOR:
Raymond F. Fraley, Executive Director Advisory Committee on Reactor Safeguards FROM*.
Guy A. Arlotto, Director Division of Engineering Technology Office of Nuclear Regulatory Research
SUBJECT:
ACRS SUBMITAL OF GENERAL REVISION TO 10 CFR PART 50, APPENDIX J " LEAK TESTS FOR PRIMARY AND SECONDARY i
CONTAINMENTS OF LIGHT-WATER-COOLED NUCLEAR POWER
Reference:
NRC/ACRS Memorandum of Understanding, June 15, 1983 In accordance with the above reference, enclosed for review and approval by the ACRS is a proposed general revision to 10 CFR Part 50,' Appendix J.
Background information - history, need and reason for the revision - are in the Proposed Rule and the draft FEDERAL REGISTER Notice (Enclosure A).
A regulatnry analysis is presented in a sumary format (Enclosure 8), also including:
(Attachment I to Enclosure B), a tabulation of the changes and whe they are " ratchets" or de-ratchets (Attachment 2 to Enclosure B), and applicable (Attachment 3 to Enclosure B). draft responses to the CRG
' The proposed revision is to be applied to all nuclear power plants that are, or will be, operating.
than does the current regulation for the NRC staff to accept reasona alternatives to its requirements, where justified.
Revision of Appendix J is being justified as a licensing improvement, F
rather than on a risk reduction / cost benefit basis.
That is because the-NRC staff, and also Itcensees, feel a strong need exists to update the
/
regulation and make it more efficient, even though a significant improve-ment in safety can not be demonstrated.
wide support and will help the regulatory process.This revision, as a whole, has Due to variables involved, it would be difficult to fairly quantify the costs of implementing this revision.
cost differential is not involved.
However, it is expected that a major fication would be minimal for this revision, and does not justify the NRC resources that would be needed.
In addition, explicit solicitation of costs and benefits is planned as part of the FEDERAL REGISTER publication for public coment.
m yu/ qw o
s
2840815C30 Rayrnond F. Fraley 2
W 1 8 1954 For further information, contact Gunter Arndt, Task Leader, i
Mechanical / Structural Engineering Branch (443-7860).
~'
(D 1 1
ve Gwy4.;Arlotto, Dire (tor Division of Engineering Technology Office of Nuclear Regulatory Research W. J. Dircks Z. R. Rosztoczy M. Sparks CRGR (7) i l
.. - -...