ML20127P081

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Summary of ACRS ECCS Subcommittee 850221 Meeting W/Util & Westinghouse in Washington,Dc Re Status of Rev to App K Rule & Util Proposal to Delete ECCS Upper Head Injection Sys from Ice Condenser Plants
ML20127P081
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 03/05/1985
From:
Advisory Committee on Reactor Safeguards
To:
Advisory Committee on Reactor Safeguards
References
ACRS-2285, NUDOCS 8505230692
Download: ML20127P081 (24)


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Date Issued: 3/5/85 i

ACRS ECCS SUBCCMMITTEE MEETING MINUTES FEBRUARY 21, 1985 WASHINGTON, DC PUPROSE: The purpose of the meeting is to:

(1) review the status of the Appendix K Rule revision; (2) discuss Duke Power's proposal to delete the ECCS Uper Head Injection (UHI) system from its ice condenser plants; (3) discuss C. Michelson's concern regarding the effects of fiberglass insulation on containment sump and recirculation pump performance-post LOCA; (4) discuss the status of the NRR Reactor System Ranch activities; and (5) hold a discussion to formulate recommendations and requests on the joint NRC/B&W Owners Group /EPRI/B8W Integral System Test Program.

ATTENDEES: Principal meeting attendees include:

ACRS NRC D. Ward, Chairman li-Sheron H. Etherington L. Shotkin C. Michelson A. Serkiz R. Reed R. Jones I. Catton W. Beckner V. Schrock H. Sullivan Duke Power T. Theofanous P. M. Abraham P. Boehnert, Staff Westinghouse B. McIntyre Meeting Highlights, Agreements, and Requests 1.

Dr. W. Beckner (RES) discussed with NRR the status of the effort to revise Appendiy K of 10 CFR 50.46. Key points noted by Dr. Beckner include:

Numerous comments and discussion with NRR have resulted in a significant change in the approach for Rule revision RES will be recommending to the Commission.

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I ECCS Meeting Hinutes February 21, 1985 L

RES had previously planned to formally present a proposed rule to ACRS for review at this. meeting. This has been delayed duc to the above change in approach.

The chief problem in revising Appendix K was that RES could not show they would always contain sufficient conservatism to cover uncertainty in the overall calculation for the revisions considered.

The approach favored by RES is to allow best estimate calculations with 95 percent certainty factor to be used in licensingpertheSECY83-472approachapprovedbyNRR(and reviewed by the ACRS). The 10 CFR 50.46 Criteria of 2200 F PCT and 17 percent oxidation would remain unchanged. RES believes that:

(1) this approach is the best technical approach to ensure safety without unnecessarily restricting the licensee; (2) industry has already made substantial investments in developing this approach; (3) the Staff has already done substantial work on the necessary methodology. A Reg Guide will be necessary to provide guidance. RES said that the "old" Appendix K would remain (with minor revisions) for use by licensees who elect to use it.

Figure 1 lists the revised reanalysis requirements that would accompany the new Rule.

There was extensive discussion regarding the degree, and quantification, of conservatism in the Appendix K criteria.

NRR noted that there is no consensus on the amount or reason for the margins in Appendix K.

Dr. Sullivan said NRC should

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I carefully determine how to address reduction of this margin in Appendix K.

Dr. Theofanous said NRC should be forthright and directly' address the issue of large-break LOCA probability and L

ECCS Meeting Minutes February 21, 1985 put an end to the issue if the probability is as low as people generally believe.

RES said a Commission paper will be sent to the ACRS for review in es/ 4-6 weeks, with a Rule to be published for public comment in the Spring 1985.

Dr. Catton cautioned against selective use of physical realities in the best estimate code models. Dr. Theofanous favors the RES approach noted above. He said the GE approach (per SECY 83-472) may not be as straight forward for PWR's.

He also said that there may be problems with licensees using BE codes without any prior experience with these models.

In repsonse to Dr. Sullivan, Dr. Beckner said the two objectives of this Rule change are to:

(1) give relief to industry; and (2) enhance safety with the use of BE calculations.

Dr. Sullivan said another objective should be to reduce manpower associated with LB LOCA.~and this approach may not do this. He believes RES should clearly state their objectives and how these objectives will be met.

Dr. Theofanous observed that NRC has held meetings fora 10 years to attempt to develop a BE code with a 95% uncertainty value for LOCA calculations. As far as he knows, this work was never completed.

Mr. Etherinaton asked if Appendix K's focus is on LB LOCA. RES replied affirmatively. Mr. Ward said the overall issue of LB LOCA probability has not been addressed, and RES should develop a position on this point in their SECY paper. The Chairman said that another point to be considered is the issue of the probability of successful LOCA accommodation by the ECC systems.

ECCS Meeting Minutes February 21, 1985 i.

Dr. Catton observed that the biggest problem with evaluation of this issue is that the codes, especially BE codes, are very " user dependent". RES said that they are now keying their code assessment work to using a 95% confidence value to address the issue of uncertainties in the codes.

In response to Mr. Ward, Dr. Sheron (NRR) said the BE calculation only has to account for 3 or 4 key parameters in the uncertainty calculation and these would probably be set at a conservative (Technical Specification) value.

In response to another question from Mr. Ward, Dr. Beckner'said RES is looking at the impact of overall risk contributors and how the regulations might be revised, based on PRA results.

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A Serkiz (NRR) addressed C. Michelson's concern re: the effects of fiberglass insulation on cortainment sump and recirculation pump performance-post LOCA. Key points of his presentation include:

(1) A LOCA jet can cause severe damage to fiberglass insulation in the vicinity of the break (German tests at the HDR facility have verified this).

(2) Material can be finely shredded (size distribution unknown at this time) and shredded fiberglass can be transported by water at low velocities, i.e., 0.2 ft/sec.

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(3) Sump debris screens (or BWR RHR suction strainers) entrap strands of fiberglass and a unifora coating is built up over a period of time (Finnish tests showed similar phenomena).

(4) Whether the material transports is a key question; recirculation flow velocities are the critical parameter.

_.__m ECCS_ Meeting Minutes February 21, 1985 (5)- Blocked screen head loss is a function of materials and

. disposition thickness, therefore, the problem becomes

- plant-specific.

(6) Effects of insulation debris generation an'd possible blockage can impact NPSH margins; plant-specific evaluations are warranted.

(7) RG 1.82 has been' revised to eliminate prior 50% blockage criteria and evaluation guidance has been provided in RG 1.82 Revision 1.

.(8) Effects of debris ingestion on pump perfonnance have been studied. The NRC conclusion is that the main bearing systems will not fail in a catasprophic fashion.

(9) Debris effects on pump seals is not fully understood at this time, a recommendation has been made for licensees and applicants to assess this question. For BWR ECCS multi-stage pumps, the interstage bushing systems should be evaluated for determining potential ' effects of ingestion of abrasive particulates or fibrous debris. RG 1.82, Revision 1 contains L-this guidance.-

Mr. Michelson asked if NRC looked at the effect of submergence on -

insulation integrity. Mr. Serkiz said the insulation will tend to stay in place unless disturbed by jet or flow forces. In regard to Item 9 and in response to Mr. Michelson, NRC said the overall question of pump seal failure needs to be addressed. Dr. Sheron indicated that this problem falls under equipment qualification.

He did say that pumps have been tested at Comanche Peak for functioning while ingesting paint chips. Further discussion

ECCS Meeting Minutes February 21, 1985 concluded that it is not clear what the effect would be of fiberous debris on pump bearings.

In response to Mr. Etherington, Mr. Serkiz said this entire issue is not a major concern if LB LOCA is dismissed as a low probability event.

After considerable discussion It was agreed that this issue deserves further discussion at a later meeting in order to more fully explore all relevant questions; in particular the Subcommittee indicated that the question of pump seal failure deserves further consideration.

3.

The Duke Power proposal to remove UHI from McGuire was reviewed by

' P. M. Abraham of Duke, and B. McIntyre of H. Mr. Abraham detailed the ECCS for McGuire (Figure 2) and the specific UHI subsysten (Figure 3). The purpose of the UHI system is to allow greater l

operating flexability (higher power peaking factors) without exceec'ing the 2200 F PCT limit, given a LOCA.

Duke Power has experienced a number of operational problems with the UHI system at McGuire (Figure 4). This has had an impact on plant operations (e.g. forced outages, increased radiation exposure to personnel, etc.). Duke argued that UHI removal results in a number of benefits (Figure 5). Duke will shubmit their ECCS analysis supporting UHI removal in June / July 1985. Mr. Reed felt that Duke was overstating the benefits of UHI removal and was skeptical of this proposal.

Mr. McIntyre discussed the technical justification for UHI removal.

In essence, the UHI phenomena was not predictable by the 1974 -

vintage ECCS codes. Given the later development of a UHI model and overall progress in ECCS code development and testing (Figure 6), y

ECCS Meeting Minutes February 21, 1985-argues that "we're alot smarter now than we were in 1974". yhas also developed new non-UHI codes (BART & BASH) that impact this issue.

E performed a "first out" scoping calculation to determine the effect of UHI removal on PCT (Figure 7). g was able to support a peaking factor of 2.20 with a corresponding PCT of 1960*F. E believes they can support full power, full load following operation (2.32 peaking factor) for McGuire with refinement of the ECCS analysis.

Figure 8 lists the work required to support the above goal for McGuire.

Drs. Catton and Schrock asked to see information on the BART & BASH codes. They also asked to see analyses that predicted choking flow for nitrogen saturated UHI water. Mr. Reed expressed skeptism that UHI can be done away with without adversely impacting ECCS performance. He also suggested E evaluate the potential for using the UHI equipment for other purposes, such as a primary blowdown system. Mr.McIntyresaidEhasasanactionitemperdiscussion with the NRC Staff consideration of alternate use(s) for the UHI.

Dr.CattonsuggestedErunaBEECCScalculationinorderto determine the amount of LOCA margin lost as a result of UHI deletion.

In response to Dr. Sullivan, Mr. McIntyre said deletion of UHI results in a reduction of LOCA margins in an absolute sense, Dr. Sullivan said he is reluctant to see loss of a system that can add water to the vessel, given a LOCA.

Dr. Sheron indicated that if Duke demonstrates that UHI removal is acceptable per the regulations, NRC will approve it. He also said NRR will bring BART/ BASH to the Connittee for its review. Mr. Ward agreed to this.

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ECCS Meeting Minutes February 21, 1985 4.

Dr. B. Sheron discussed the status of the on-going revision of the upper plenum injection (UPI) ECCS models for the }[ two-loop plants.

Figure 9 gives a chronology of the history of NRC's problems with these EM's. Basically, the early models did not appropriately account for UPI related phenomena. Figure 10 details the Staff's concerns with the UPI ECCS model. The affected licensees have solicited their respective vendors to develop new EM's that satisfy NRC's concerns.

Mr. Reed raised the question of whether the UPI isolation valves are open or closed during plant operation. After discussion, Mr.

Sheron said he would verify this point vis-a-vis credit for operator action to open these valves if needed.

5.

Mr. Ward asked the status of resolution of the pumps-on pumps-off issue. Mr. Jones said that the SERs resolving this issue should be out in March 1985.

6.

The Subcommittee discussed in round-table fashion the joint NRC/B&W Owners /EPRI/B&W IST and related programs. The goal was to attempt to develop a comprehensive Subcommittee position on recommendations and requests vis-a-vis this test program effort.

Dr. Catton provided the following comments on the overall Program effort based on his observations:

There are six key issues to be addressed for B&W plant thermal-hydraulic understanding. These are:

(1)

Interrupted natural circulation.

(2) Establishing boiler / condenser mode of natural circulation.

(3) Re-establishing natural circulation.

ECCS Meeting Minutes February 21, 1985 (4) long term cooling.

(5)

Interloop interactions and oscillations.

(6) Combined secondary side - primary system blowdown.

Dr. Catton considers Iten 5 to be the most import issue in need of experimental data.

Dr. Catton believes all of the key issues will be addressed via MIST or supporting facilities except for Issue 6 (Figure 11). Mr. Reed said he believes the phenomena of cold leg thermal block needs to be considered. Mr. Etherington said that the phenomena of thermal stress during natural circulation cooldown should be addressed. Mr. Jones said the latter is an outstanding issue for B&W plants and is under Staff review. He also said he didn't think the IST Program would directly address this issue.

Regarding Issue 6. Dr. Catton said he believes resolution of this concern was funneled into the IST Program by NRR and AE0D. His interpretation of the MIST Facility Specifications show that MIST cannot simulate the "AE00 transient" (Issue 6).

Mr. Carter (B&W) said the facility as now configured can partially address the transient parameters for Issue 6.

Other comments by Dr. Catton include:

TRAC-PF1 nodeling modeling of AFW cooling is lacking. We need to understand the physics involved and not just replicate 19-tube SG data by post-diction.

Codes cannot predict counter current single phase stratified flow in the cold leg.

ECCS Meeting Minutes February 21, 1985 The interaction between LANL and the B&W Alliance group seems to be very effective.

The MIST facility cannot address transients where multi-dimensional downcomer phenomena are important.

There is an urgent need for plant calculations to establish where the weaknesses in calculational ability lie and what data is needed.

More emphasis must be placed on the basic objective of the program - being able to predir.t the behavior of a full size plant.

Issues of scaling need early attention so that codes do not get " tuned" to small scale systems and later be used for full-size plant calculations.

A plant calculation for a transient causing strong loop to loop interactions should be run as a basis for simulation by all available facilities (MIST, SRI University of Maryland).

Mr. Jones cited NRC records that indicated an acceptable resolution path for the AE0D concern has been layed out and a MIST test will be run that NRR believes will fully address the Issue 6 concern.

Further discussion resulted in Dr. Sullivan stating that the proposed MIST test to address Issue 6 should be able to provide enough information to determine if the codes can extrapolate the results to a full scale plant.

Dr. Shotkin said that the AE00 position is that their concerns will be met by the currently planned MIST test in this area. He said

ECCS Meeting Minutes February 21, 1985 that if this does not satisfy the Subcommittee, the ACRS should request a more severe transient.

In response to Mr. Ward, Dr. Shotkin said NRR, AEOD and RES have agreed that if the codes can successfully predict single effect tests (SGTR, LOCA, etc.)

they should successfully address the AE00 concern. Mr. Jones said that the NRC suggested MIST follow-on tests would more directly address the AE0D issue.

Dr. Theofanous made the following points:

The conclusions of Dr. Catton are shared by Dr. Theofanous.

Recent meetings he has attended have clarified a number of issues in his mind.

The major issues listed by Dr. Catton end suggested'by Dr.

Sheron are the central issues of concern. He is satisfied with the overall direction of the program.

Scaling is still a concern. A more intense focusing of technical issues is needed in order to assure that the test data will address scaling concerns.

Issues 1 A and 6 can be addressed.

It is not clear that Item 5 is an Issue of concern. He doesn't know what is driving this item.

Mr. Young (RES) said Issue 5 (loop-to-loop oscillations) was of i

concern from the standpoint of code predictive capability. Dr.

Sullivan indicated that such oscillations may impact on operator.

actions given an emergency situation. Dr. Theofanous said this Issue has not be sufficiently defined to make for a useful f

resolution. Mr. Jones said loop oscillations could affect recovery

ECCS Meeting Minutes February 21, 1985 actions and thus NRC wants to assure the phenomena seen can be adequately described for emergency procedure development.

Dr. Sullivan listed the following questions for con-ideraiton:

Facility heat losses are important. Can the codes adequately model this phenomena?

DC and RVVV's - can the codes adequately model MIST design and will the MIST design impact other test data?

.HLUB - belfeves the current design is the best that can be done under MIST design constraints.

OTSG - Has condensation front vs height been properly modeled?

Can the codes model associated T/H phenomena?

2 x 4 configuration vs Loop-to-loop oscillations - need to await data for judgement on ability to model this phenomenon.

How are integral and SE programs integrated and how will they complenent each other?

How will integral test facilities data to be compared among each other?

How will codes and models to be as:;essed and how compared against data.

Mr. Ward observed that the ACRS has been supportive of this overall effort. He said the Subcommittee has had reservations on overall Program coordination and still continues to, to a certain extent.

In the past we haven't tried to put our technical

ECCS Meeting Minutes February 21, 1985 reservations into one package, as we tired to do here today, Mr.

Ward feels there is no overall gap in the technical effort.

In response to Mr. Michelson, Mr. Ward said the follow-on effort should address the AEOD (Issue 6) concern. Mr. Jones added that the follow-on tests should provide the capability to address this item. Mr. Michelson said the Subcommittee should continue to closely track this issue.

The meeting was adjourned at 5:01 p.m.

NOTE:

Additional meeting details can be obtained from a transcript of this meeting available in the NRC Public Document Room, 1717 H Street, M.W., Washington, D.C., or one can be purchased from ACE-Federal Reports, 444 North Capitol Street, Washington, DC 20001 (202) 347-3700.

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i BEANALYSIS REQUIREENTS L

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CLARIFY THAT ALL ERRORS DISCOVERED ARE REPORTABLE.

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RAISE THRESHOLD FOR REPORTING CHANGED FROM 20 F T0 [50 F1.

i IMMEDIATE REANALYSES ONLY IF 50.l46 CRITERIA EXCEEDED.

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MCGUIRE NUCLEAR STATION EMERGENCY CORE COOLING SYSTEM CENTRIFUGAL CHARGING NUMBER 2

PUMPS SHUT 0FF PRESSURE 2670 PSIG MAXIMUM FLOWRATE 550 GPM/ PUMP SAFETY INJECTION NUMBER 2

PUMPS SHUT 0FF PRESSURE 1520 PSIG MAXIMUM FLOWRATE 650 GPM/ PUMP RESIDUAL HEAT REMOVAL NUMBER 2

PUMPS SHUT 0FF PRESSURE 195 PSIG MAXIMUM FLOWRATE 4500 GPM/ PUMP COLD LEG ACCUMULATORS NUMBER 4

NOMINAL COVER PRESSURE 457 PSIG 3

NOMINAL WATER VOLUME 1078 FT /ACC UHI WATER ACCUMULATOR NUMBER 1

NOMINAL COVER PRESSURE 1235 PSIG DELIVERED WATER VOLUME 790-1011 FT3

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j MCGUIRE NUCLEAR STATION UHI OPERATIONAL PROBLEMS e

RUPTURE OR LEAKAGE OF MEMBRANE IN GAS CROSSOVER LINE BETWEEN WATER AND NITROGEN ACCUMULATORS e

LEVEL SWITCH / TRANSMITTER PROBLEMS INVOLVING VOLUME DELIVERY WITHIN TOLERANCES ACCURACY OF BARTON LEVEL SWITCHES INSTALLATION ERROR OF SENSING LINES CALIBRATION PROCEDURES VIOLATION OF CHEMISTRY REQUIREMENTS IN WATER ACCUMULATOR e

REGARDING NITROGEN AND BORON CONCENTRATIONS e

VIOLATION OF COVER PRESSURE REQUIREMENTS e

INADVERTENT CLOSING OF ISOLATION VALVES e

SIGHT GLASS FAILURE DURING UHI FILL & VENT M

J BENEFITS OF UHI REMOVAL REMOVAL OF UHI SYSTEM RESULTS IN:

a MANPOWER SAVINGS FROM TASKS ASSOCIATED WITH STUDY, CORRECTION, AND PREVENTION OF UHI RELATED PROBLEMS LOCA DYNAMICS BECOMES CONSISTENT WITH CON-VENTIONAL ANALYSIS TECHNIQUES 1

REDUCTION OF OVERALL PLANT COMPLEXITY, PROCEDURES, MAINTENANCE, ETC.

REDUCTION OF REQUIRED MODE CHANGES REDUCTION OF PERSONNEL RADIATION EXPOSURES IMPROVED PLANT RELIABILITY l

NOTE:

PROPOSED SCHEDULE IS TO SUBMIT ECCS EVALUATION IN JUNE / JULY 1985 AND IMPLEMENT UHI REMOVAL IN JANUARY /

FEBRUARY 1986 AT MCGUIRE NUCLEAR STATION I

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ECCS DEVELOPMENT SINCE 1974 3.

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SEMISCALE e

ANS 1979 DECAY HEAT STANDARD e

ORNL METAL WATER REACTION MODEL

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e BE CODES TRAC COBRA / TRAC (UHI BE CALCULATION PCT 1155'F) e SECY-83-472 f

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f-McGUIRE SCOPING STUDY

SUMMARY

o UHI REMOVED o

COLD LEG ACCUMULATOR RECONFIGURED 600 PSIA 6.9 FL/D o

BART EVALUATION MODEL UTILIZED o

0.6 DECLG BREAK ANALYZED o

RESULTS Fo = 2.20 S:

PCT = 1960*F 0

COMMENTS WORST BREAK MAY NOT HAVE BEEN ANALYZED-CREDIT TAKEN FOR THE UHI SUPPORT COLUMNS o

PROJECTED RESULTS UTILIZING BART/ BASH Fo = 2.32 o

CONCLUSIONS THE ECCS PERFORMANCE OF THE McGUIRE NUCLEAR UNITS WITH UHI REMOVED IS NOT SIGNIFICANTLY DIFFERENT THAN OTHER WESTINGHOUSE FOUR-LOOP PLANTS EITHER WITH OR WITHOUT UHI IF CURRENT ECCS ANALYSIS METHODOLOGY IS UTILIZED AND THE COLD LEG ACCUMULATORS ARE ADJUSTED.

THE McGUIRE NUCLEAR UNITS CAN BE OPERATED WITH UHI REMOVED AT A PEAKING FACTOR THAT WOULD ALLOW FULL POWER AND FULL LOAD FOLLOW OPERATION.

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SCOPE OF WORK REQUIRED o

NEW LARGE BREAK ECCS ANALYSIS (BASH) o NEW SMALL BREAK ECCS ANALYSIS (NOTRUMP) o EVALUATE IMPACT ON CONTAINMENT INTEGRITY (ECCS) o NEW STEAMLINE BREAK ANALYSIS j

f SUBMIT UHI/NON-UH1 SENSITIVITY STUDY USING " CURRENT"

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LOTIC MODEL WITH LICENSING SUBMITTAL.

A NEW STEAMLINE BREAK ANALYSIS WILL BE SUBMITTED FOLLOWING RESOLUTION l-_

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0F THE SUPERHEAT ISSUE (4TH QUARTER 1985) o REVISE TECHNICAL SPECIFICATIONS o

REVISE FSAR CHAPTERS 6 AND 15 o

PERFORM NEW COLD LEG ACCUMULATOR LOW PRESSURE BLOWDOWN TEST TO VERIFY THE PIPING FL/D l

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t CHRONOLOGY 1970-74 SIX W 2-LOOP UPI PLANTS WENT INTO COMERCIAL OPERATION IN THE U.S.

1977-78 STAFF SERs ON UPI PLANT ECCS EVALUATION MODELS CONCLUDED THAT WESTING-HOUSE AND EXXON LBLOCA MODELS DID NOT APPROPRIATELY ACCOUNT FOR THE EFFECTS OF UPI, DESCRIBED THE STAFF MODEL USED TO EVALUATE UPI EFFECTS, AND ALLOWED CONTINUED LICENSEE OPERATION USING INTERIM W AND E MODELS.

1979-83 W AND EXXON SUBMIT NEW UPI MODELS.

07/24/84 THE STAFF MET WITH LICENSEES AND W TO DISCUSS THE NEW 1979-83 LBLOCA MODELS THEN BEING EVALUATED BY THE STAFF FOR THE UPI PLANTS.

02/12/85 LICENSEES PROVIDED WITH STAFF'S EVALUATION OF THESE MODELS DOCUMENTING PROBLEMS AND PROVIDING GUIDANCE ON NRC REQUIREMENTS FOR A LBLOCA MODEL AND FOR A PLANT-SPECIFIC ECCS.

LICENSEES WERE ASKED TO RESPOND WITHIN 60 DAYS WITH PLANS, SCHEDULES, AND EFFORTS TO BE EXPENDED TO ADDRESS STAFF CONCERNS.

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STAFF FINDINGS

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I THE STAFF'S EVALUATION AND GUIDANCE DOCUMENTED THE WAYS THE SUB THE STAFF'S MAIN CONCERNS WERE:

THE REQUIREMENTS OF 10 CFR 50 APPENDIX K.

' INADEQUATE DOCUMENTATION 4

"AilSENCE OF SENSITIVITY STUDIES

  • ABSENCE OF A PHYSICALLY MEANINGFUL MODEL ADDRESSING UPPER PL
  • THEEFFECTSOFUPIONREFILL,REFLOOD,AhDHEATANDMASSTRANSFER
  • AN ABSENCE OF COMPARISON OF EM PREDICTIONS WITH EXPERIMENTS
  • LACK OF CONSIDERATION OF THE DIFFERENCES BETWEEN UPI AND HON-UPI PLANTS, AN
  • NON-COMPLIANCE WITH VARIOUS REQUIRED FEATURES OF APPENDIX X.

THE STAFF CONCERNS WERE DOCUMENTED FOR BOTH THE W AND EXXON L d

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