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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20100M3571996-02-26026 February 1996 Forwards Proprietary Documentation of Algebraic for of GE Critical Power Correlation.Ge Requests Concurrence Recognizing Attachment as Legal Documentation of GEXL & GEXL-PLUS Critical Quality Correlations ML20099F5851992-08-0404 August 1992 Clarifies Statement Made in NRC Safety Evaluation of Rept NEDE-31758P-A, GE Marathon Control Rod Assembly, W/ Regards to Stress Limit Used by Ge.Nrc Concurrence W/ Clarification Requested by 920930 ML20055E0691990-06-29029 June 1990 Forwards Synopsis of NRC Investigation Rept 03-87-011 Re Investigation Performed at Facility,For Info ML20235S9511989-02-25025 February 1989 Responds to NRC Bulletin 88-010, Test Program. Recommends That Temp Test Be Permitted as Alternate to Millivolt Drop/ Pole Resistance ML20235L1561989-01-17017 January 1989 Forwards Endorsements 141 & 142 to Nelia Policy NF-1, Endorsements 44 & 45 to Maelu Policy MF-95 & Endorsements 5 to Nelia Policy NW-1 & Maelu Policy MW-66 ML20155E1331988-06-0606 June 1988 Partial Response to FOIA Request for Documents.Forwards App B Documents.App a & B Documents Available in PDR ML20153B1541988-03-15015 March 1988 Informs of Relocation of NRR to Stated Address in Rockville, MD ML20235L6161987-09-25025 September 1987 Extends Invitation to Attend Region V 871110 Meeting in South San Francisco,Ca to Discuss NRC Reactor Operator Licensing Program.W/O Stated Encl ML20235M4251987-07-13013 July 1987 Partial Response to FOIA Request for Documents Re Acrs. Forwards Documents for Categories One & Three of FOIA Request.Review of 21 Addl ACRS Documents Continuing ML20234E4571987-06-23023 June 1987 Partial Response to FOIA Request for 771026 Minutes of ACRS Subcommittee on Fluid/Hydraulic Dynamic Effects Meeting in Portland,Or & Addl ACRS Documentation.Documents Identified on App H & Addl ACRS Documents Encl ML20207S5001987-03-0606 March 1987 Forwards Technical Evaluation Repts for Domestic Mark III Plants (Grand Gulf,Clinton,River Bend & Perry) & Gessar Ii. Inserts to Be Included in Section 6.2.1.8 of Draft Sser 2 for Clinton,River Bend & Perry Plants Also Encl IA-86-821, Final Response to FOIA Request Re GESSAR-II.App a Document Available in Pdr.App B Document Partially Withheld (Ref FOIA Exemption 4)1987-01-0909 January 1987 Final Response to FOIA Request Re GESSAR-II.App a Document Available in Pdr.App B Document Partially Withheld (Ref FOIA Exemption 4) ML20207M6941987-01-0909 January 1987 Final Response to FOIA Request Re GESSAR-II.App a Document Available in Pdr.App B Document Partially Withheld (Ref FOIA Exemption 4) ML20207M6741986-11-17017 November 1986 FOIA Request for GESSAR-II Chapters on Human Factors & Engineering & GESSAR-II Probabilistic Safety Study ML20210J3961986-09-22022 September 1986 Forwards Amend 2 to Final Design Approval FDA-1 for BWR/6 Nuclear Island Design (GESSAR-II) & Notice of Issuance of Amend.Amend Removes Constraints on Issuing CPs & OLs to Applicants Ref GESSAR-II Design NUREG-0979, Forwards Sser 5,(NUREG-0979).W/o Encl1986-06-25025 June 1986 Forwards Sser 5,(NUREG-0979).W/o Encl ML20211K8171986-06-17017 June 1986 Proposes Final Design Approval (Fda) Conditions 3-6 Be Treated as Interface Items & Removed from Amend 2 to FDA-1. Action on Condition 1 Should Be Taken by Nrc,Not GE ML20199D5321986-06-11011 June 1986 Forwards Proposed Amend 2 to Final Design Approval-1 for BWR/6 Nuclear Island Design,Gessar Ii,Documenting Staff & ACRS Review of Gessar II for Severe Accident Concerns,For Comment.Amend Removes Constraints on Issuance of CPs & OLs ML20155G0971986-04-25025 April 1986 Forwards Nonproprietary & Proprietery Amend 21 to Gessar II,238 Nuclear Island. Amend Responds to NRC Proposed Severe Accident Policy Statement.Proprietary Amend Withheld (Ref 10CFR2.790) ML20137L4871986-01-22022 January 1986 Forwards,For Info & Comment,Acrs Rept Re Review of GESSAR-II for Concerns Addressed in Commission Severe Accident Policy Statement.Comments Requested by 860204 ML20137H8641986-01-14014 January 1986 Disagrees W/Nrc Re Final Design Approval of Gessar II BWR/6 Nuclear Island Design Applicable to Future Plants.Design Does Not Satisfy All Concerns of Commission Severe Accident Policy Statement.W/Addl Comments by ACRS Members ML20140F3691986-01-14014 January 1986 Further Response to FOIA Request for Several Categories of Documents Re Pressure Suppression Containment.Fsar & SER for Limerick Only Documentation Re 4x4 Tests.Encl Apps D-G Documents Responsive to Item 4 Also Available in PDR ML20154A6611986-01-13013 January 1986 Responds to FOIA Request for Specified Documents to Be Placed in Pdr.Encl App a Documents & Listed App B Document Placed in Pdr.Portions of Document 2 on App a Withheld (Ref FOIA Exemption 4) IA-85-804, Responds to FOIA Request for Specified Documents to Be Placed in Pdr.Encl App a Documents & Listed App B Document Placed in Pdr.Portions of Document 2 on App a Withheld (Ref FOIA Exemption 4)1986-01-13013 January 1986 Responds to FOIA Request for Specified Documents to Be Placed in Pdr.Encl App a Documents & Listed App B Document Placed in Pdr.Portions of Document 2 on App a Withheld (Ref FOIA Exemption 4) ML20209H4261985-10-30030 October 1985 Forwards marked-up Proprietary Review of BWR/6 Std Plant Pra:Vol 2:Seismic Events...Analysis in Response to 851009 Request.Technical Error Identified on Encl Pages 6/3 & 6/4. Review Withheld IA-84-175, Responds to Appeal Re Denial of FOIA Request for GE PRA for GESSAR-II Standardized Plant Design.Forwards 11 Pages from PRA Due to Court Approved Stipulation of 850718 Settlement. Info Also Available in PDR1985-10-11011 October 1985 Responds to Appeal Re Denial of FOIA Request for GE PRA for GESSAR-II Standardized Plant Design.Forwards 11 Pages from PRA Due to Court Approved Stipulation of 850718 Settlement. Info Also Available in PDR ML20133J3821985-10-11011 October 1985 Responds to Appeal Re Denial of FOIA Request for GE PRA for GESSAR-II Standardized Plant Design.Forwards 11 Pages from PRA Due to Court Approved Stipulation of 850718 Settlement. Info Also Available in PDR ML20135B7601985-09-0505 September 1985 Ack Receipt of 850806 Memo Re ACRS Severe Accident Review. NRR Ltr to ACRS Endorsed.Acrs Review Completion Expected by Sept or Oct 1985 Meeting ML20133N9891985-08-12012 August 1985 Forwards Proprietary Suppl 1 to Draft Gessar II Amend Supporting Leak-Before-Break. Submittal Based on Recommendations of NUREG-1061,Vol 3 for leak-before-break Mechanistic Methodology.Suppl Withheld (Ref 10CFR2.790) ML20134A5511985-08-0909 August 1985 Forwards Amend 1 to Final Design Approval FDA-1 & Fr Notice of Issuance.Amend Removes Constraint on Forward Referenceability of GESSAR-II Design & Permits Ref in New CP & OL Applications ML20133L5951985-08-0606 August 1985 Expresses Concern Over Progress of Severe Accident Review of Design.Requests That Steps Be Taken to Complete Review on Schedule That Would Result in Ltr to Commission in Sept 1985 ML20128H3171985-06-28028 June 1985 Forwards NRR Sser 4 Re Severe Accident Design.Severe Chatter Issue Will Be Resolved Prior to Publishing Final Suppl.W/O Encl ML20129B7391985-06-25025 June 1985 Advises of Review of Proposed SERs for Proprietary Info,Per 850618 Request.Page 3 of Ref 3, Table 2:Conditional Consequences Predicted by GE for Internally Initiated Events... Classified as Proprietary ML20128Q6981985-06-19019 June 1985 Responds to FOIA Request for from GG Sherwood to Hl Thompson on Review of Leak-Before-Break Approach on Gessar II Docket. Forwards Document IA-85-412, Responds to FOIA Request for 850404 Ltr from GG Sherwood to Hl Thompson on Review of Leak-Before-Break Approach on Gessar II Docket. Forwards Document1985-06-19019 June 1985 Responds to FOIA Request for 850404 Ltr from GG Sherwood to Hl Thompson on Review of Leak-Before-Break Approach on Gessar II Docket. Forwards Document ML20126B8981985-06-10010 June 1985 Forwards Info Re Resolution of Open Item Concerning Clutter on GE Emergency Response Info Sys.Ge Will Display Changes Recommended by Human Factors Consultant,Anacapa Sciences,Inc & NRC ML20126F4911985-06-0707 June 1985 Forwards Proposed Amend 1 to FDA-1 for GESSAR-II BWR/6 Nuclear Island Design,For Review.Amend Prepared in Anticipation of Final Commission Action on Severe Accident Policy Statement.Comments Requested by 850614 ML20128Q6731985-06-0606 June 1985 FOIA Request for GG Sherwood to Hl Thompson on Review of Leak-Before-Break on Gessar II Docket ML20117K0761985-05-0909 May 1985 Forwards Anacapa Technical Rept TR-550-1, Human Factors & Performance Evaluations of Emergency Response Info Sys. Rept Should Resolve Questions Raised by NRC Re Amount of Info Contained in Gessar Displays.W/O Encl ML20117H5241985-05-0707 May 1985 Permits NRC to Reproduce,Furnish to Third Parties & Make Public Rept NEDC-30885, Generic Emergency Response Info Sys (Basic Rtad) Software Validation ML20133A2391985-05-0303 May 1985 Further Response to FOIA Appeal & Ucs Motion for Summary Judgement That 10 Categories of Info in GESSAR-II PRA Could Be Released.No Basis Found to Recommend Reversal of Determination.Documents Released by GE Encl ML20154A6791985-05-0202 May 1985 Forwards NUREG/CR-4135 P, Review of BWR/6 Std Plant PRA: Vol-1 Internal Events,Core Damage Frequency. Task 12 of GESSAR-II Review Project Complete ML20116M0941985-05-0101 May 1985 Submits Supplemental Info Re Concerning Addendum 1 to NEDO-10466, Power Generation Control Complex (Pgcc) Fire Suppression Licensing Topical Rept. Establishment of Halon Concentration Requirement for Control Room Discussed ML20116E5961985-04-26026 April 1985 Forwards Proprietary Updated Draft Gessar II Amend Supporting Leak-Before-Break. Submittal for Carbon Steel Piping Scheduled for 850618.Rept Withheld (Ref 10CFR2.790) ML20126J0841985-04-19019 April 1985 Responds to Appeal Re Denial of FOIA Request for GESSAR-II Pra.Forwards Pages 2-7 - 2-16 of Document 5 on App A. Portions Withheld (Ref FOIA Exemption 4) ML20117J5801985-04-17017 April 1985 Forwards NEDC-30885, Generic Emergency Response Info Sys (Basic Rtad) Software Validation, Re Program to Evaluate & Test Integrated Software,Data Bases & Command Files Associated W/Emergency Response Info Sys NUREG-0770, Partial Response to FOIA Request for Four Categories of Documents Re APS Source Term Review.Forwards Documents in App A.App B Documents Available in Pdr.App a Documents Being Placed in PDR1985-04-15015 April 1985 Partial Response to FOIA Request for Four Categories of Documents Re APS Source Term Review.Forwards Documents in App A.App B Documents Available in Pdr.App a Documents Being Placed in PDR ML20128M6211985-04-15015 April 1985 Partial Response to FOIA Request for Four Categories of Documents Re APS Source Term Review.Forwards Documents in App A.App B Documents Available in Pdr.App a Documents Being Placed in PDR ML20126C4481985-04-0404 April 1985 Advises of Preparations to Update & Resubmit Draft Amend Supporting leak-before-break Approach to Achieve Consistency W/Vol 3 of NUREG-1061 ML20126E0031985-04-0404 April 1985 Further Response to Appeal Re Partial Denial of FOIA Request for Documents Re GE PRA for GESSAR-II Standardized Plant Design.App Lists Documents Responsive to Request 1996-02-26
[Table view] Category:INTERNAL OR EXTERNAL MEMORANDUM
MONTHYEARML20235S6271989-02-28028 February 1989 Notification of 890307 Meeting W/Bwr Owners Group in Rockville,Md to Discuss Items of Current Interest.Agenda Encl ML20236P5511987-11-13013 November 1987 Notification of 871201 Meeting W/Ge & BNL at GE Ofcs to Discuss Amend 18 to Gestar II ML20209G0841987-02-13013 February 1987 Notification of 870324 Meeting W/Ge in Bethesda,Md to Discuss Gestar Amend 18 Submittal for GE8x8N Fuel Design & Status of Other Licensing Issues.Portions of Meeting Will Be Closed to Public.Proposed Agenda Encl ML20214D2431986-11-17017 November 1986 Advises That GE Will Be Filing Application for Design Approval & Certification of Advanced BWR Design in Near Future.Assignment of Ofc of General Counsel Case Atty to Project to Assist Review Requested ML20214D3231986-11-17017 November 1986 Requests Assignment of Div of BWR Personnel as Contact for Discussions on Security,Safeguards & Sabotage Aspects of GE Advanced BWR Design ML20137H8641986-01-14014 January 1986 Disagrees W/Nrc Re Final Design Approval of Gessar II BWR/6 Nuclear Island Design Applicable to Future Plants.Design Does Not Satisfy All Concerns of Commission Severe Accident Policy Statement.W/Addl Comments by ACRS Members ML20133L5951985-08-0606 August 1985 Expresses Concern Over Progress of Severe Accident Review of Design.Requests That Steps Be Taken to Complete Review on Schedule That Would Result in Ltr to Commission in Sept 1985 ML20128H3171985-06-28028 June 1985 Forwards NRR Sser 4 Re Severe Accident Design.Severe Chatter Issue Will Be Resolved Prior to Publishing Final Suppl.W/O Encl ML20128H2521985-06-26026 June 1985 Responds to 850522 Memo Re Compliance of GESSAR-II Design W/ Provisions of 10CFR50.44(c)(3)(iv) & Technical Resolution of Unresolved Safety Issues A-17,A-44,A-45,A-46 & A-47. GESSAR-II Provided W/Ultimate Plant Protection Sys ML20128H2741985-05-22022 May 1985 Requests Brief Description of How GESSAR-II Has Demonstrated Compliance w/10CFR50.44(c)(3)(iv) & Technical Resolution of Unresolved Safety Issues A-17,A-47,A-46,A-45 & A-44 ML20128N3521985-05-22022 May 1985 Notification of 850529 Meeting W/Ge in Bethesda,Md to Discuss GE Draft Amend to GESSAR-II Supporting leak-before-break.Meeting Agenda Encl ML20127B5391984-04-16016 April 1984 Provides List of Proposed Solutions to Accident Evaluation Branch Review Concerns,Per 840410 Memo.Advantageous to Have Series of ACRS Subcommittee Meetings on Number of Technical Subjs,Excluding Source Terms ML20091D8621984-04-0202 April 1984 Forwards Draft Evaluation of GE Info on Pool Scrubbing Re Facility,For Review & Comments ML20084R6281984-01-23023 January 1984 Discusses Status of GESSAR-II Review Re Probabilistic Fire Analysis.Related Info Encl ML20128M6701983-11-15015 November 1983 Advises That Div of Sys Integration Cannot Concur in Recommended Schedule for GESSAR-II Provided by 831104 Concurrence Sheet ML20128M6841983-11-0707 November 1983 Requests Approval of Encl Schedule for GESSAR-II Severe Accident Review.Proposed Schedule Would Delay Issuance of SER from 840301 to 840615.W/o Encl ML20128M8901983-01-24024 January 1983 Discusses Proposed Commission Policy Statement on Severe Accidents & Impact on GESSAR-II PRA Review Schedule. Substantive Bases Can Be Developed for Making Decisions on GESSAR-II W/Modest Rev to Schedule ML20140F5121976-12-28028 December 1976 Forwards Containment Sys Branch Input to Draft Sser 2 & Request for Addl Info.Areas of Concern from Review of Unsteady Drag on Submerged Structures Listed.Meetings W/ GE Planned to Discuss Impact Load Profiles ML20140G1751975-04-10010 April 1975 Forwards Draft Generic Ltr Requesting Applicants of Plants W/Mark III Type Containments to Describe Design Provisions to Accommodate Loads in Suppression Pool ML20155E9481973-11-15015 November 1973 Forwards Requests for Addl Info Re Gessar & Submits Comments Re Application.Approval of Containment Design Presented in Gessar Must Be Predicated on Successful Completion of Sufficient Amount of Large Scale Testing 1989-02-28
[Table view] Category:MEMORANDUMS-CORRESPONDENCE
MONTHYEARML20235S6271989-02-28028 February 1989 Notification of 890307 Meeting W/Bwr Owners Group in Rockville,Md to Discuss Items of Current Interest.Agenda Encl ML20236P5511987-11-13013 November 1987 Notification of 871201 Meeting W/Ge & BNL at GE Ofcs to Discuss Amend 18 to Gestar II ML20209G0841987-02-13013 February 1987 Notification of 870324 Meeting W/Ge in Bethesda,Md to Discuss Gestar Amend 18 Submittal for GE8x8N Fuel Design & Status of Other Licensing Issues.Portions of Meeting Will Be Closed to Public.Proposed Agenda Encl ML20214D2431986-11-17017 November 1986 Advises That GE Will Be Filing Application for Design Approval & Certification of Advanced BWR Design in Near Future.Assignment of Ofc of General Counsel Case Atty to Project to Assist Review Requested ML20214D3231986-11-17017 November 1986 Requests Assignment of Div of BWR Personnel as Contact for Discussions on Security,Safeguards & Sabotage Aspects of GE Advanced BWR Design ML20206H4231986-06-24024 June 1986 Staff Requirements Memo Re 860605 Meeting W/Acrs in Washington,Dc to Discuss to Commission on GESSAR-II BWR/6 Nuclear Island Design for Future Plants ML20137H8641986-01-14014 January 1986 Disagrees W/Nrc Re Final Design Approval of Gessar II BWR/6 Nuclear Island Design Applicable to Future Plants.Design Does Not Satisfy All Concerns of Commission Severe Accident Policy Statement.W/Addl Comments by ACRS Members ML20133L5951985-08-0606 August 1985 Expresses Concern Over Progress of Severe Accident Review of Design.Requests That Steps Be Taken to Complete Review on Schedule That Would Result in Ltr to Commission in Sept 1985 ML20128H3171985-06-28028 June 1985 Forwards NRR Sser 4 Re Severe Accident Design.Severe Chatter Issue Will Be Resolved Prior to Publishing Final Suppl.W/O Encl ML20128H2521985-06-26026 June 1985 Responds to 850522 Memo Re Compliance of GESSAR-II Design W/ Provisions of 10CFR50.44(c)(3)(iv) & Technical Resolution of Unresolved Safety Issues A-17,A-44,A-45,A-46 & A-47. GESSAR-II Provided W/Ultimate Plant Protection Sys ML20128H2741985-05-22022 May 1985 Requests Brief Description of How GESSAR-II Has Demonstrated Compliance w/10CFR50.44(c)(3)(iv) & Technical Resolution of Unresolved Safety Issues A-17,A-47,A-46,A-45 & A-44 ML20128N3521985-05-22022 May 1985 Notification of 850529 Meeting W/Ge in Bethesda,Md to Discuss GE Draft Amend to GESSAR-II Supporting leak-before-break.Meeting Agenda Encl ML20127B5391984-04-16016 April 1984 Provides List of Proposed Solutions to Accident Evaluation Branch Review Concerns,Per 840410 Memo.Advantageous to Have Series of ACRS Subcommittee Meetings on Number of Technical Subjs,Excluding Source Terms ML20091D8621984-04-0202 April 1984 Forwards Draft Evaluation of GE Info on Pool Scrubbing Re Facility,For Review & Comments ML20084R6281984-01-23023 January 1984 Discusses Status of GESSAR-II Review Re Probabilistic Fire Analysis.Related Info Encl ML20128M6701983-11-15015 November 1983 Advises That Div of Sys Integration Cannot Concur in Recommended Schedule for GESSAR-II Provided by 831104 Concurrence Sheet ML20128M6841983-11-0707 November 1983 Requests Approval of Encl Schedule for GESSAR-II Severe Accident Review.Proposed Schedule Would Delay Issuance of SER from 840301 to 840615.W/o Encl ML20128M8901983-01-24024 January 1983 Discusses Proposed Commission Policy Statement on Severe Accidents & Impact on GESSAR-II PRA Review Schedule. Substantive Bases Can Be Developed for Making Decisions on GESSAR-II W/Modest Rev to Schedule ML20140F5121976-12-28028 December 1976 Forwards Containment Sys Branch Input to Draft Sser 2 & Request for Addl Info.Areas of Concern from Review of Unsteady Drag on Submerged Structures Listed.Meetings W/ GE Planned to Discuss Impact Load Profiles ML20140G1751975-04-10010 April 1975 Forwards Draft Generic Ltr Requesting Applicants of Plants W/Mark III Type Containments to Describe Design Provisions to Accommodate Loads in Suppression Pool ML20155E9481973-11-15015 November 1973 Forwards Requests for Addl Info Re Gessar & Submits Comments Re Application.Approval of Containment Design Presented in Gessar Must Be Predicated on Successful Completion of Sufficient Amount of Large Scale Testing 1989-02-28
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[hmig*o, UNITED STATES NUCLEAR REGULATORY COMMISSION 5 }' )"g 'j c ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
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January 14, 1986 Honorable Nunzio J. Palladino Chairman U. S. Nuclear Regulatory Commission Washington, D. C. 20555
Dear Dr. Palladino:
SUBJECT:
ACRS REPORT RELATED TO THE FINAL DESIGN APPROVAL OF THE GESSAR II BWR/6 NUCLEAR ISLAND DESIGN APPLICABLE TO FUTURE PLANTS During its 309th meeting, January 9-11, 1986, the Advisory Committee on Reactor Safeguards completed a review of the reference design described in the General Electric Standard Safety Analysis Report (GESSAR II) for a Final Design Approval (FDA). GESSAR II provides the safety information for a reference system consisting of a single BWR/6 Mark III nuclear steam supply system, with a design power level of 3730 MWt, and associated systems and structures, including the reactor building (the
\ shield building and containment), fuel building, diesel generator
) buildings, control building, auxiliary building, and radwaste building.
Subcommittee meetings were held with representatives of the General Electric Company (the Applicant) and the Nuclear Regulatory Commission (NRC) Staff on October 18-19, December 4-5, 1984, and February 14-15, 1985 in Los Angeles, Calif.; on March 27-29, 1985, in Albuquerque, New Mexico; and on August 7 and September 11, 1985 in Washington, D. C. The full Committee considered this matter during its 299th through 309th meetings held monthly from March 1985 through January 1986.
We believe that the GESSAR II design includes features that provide a significant improvement in safety over current SWR designs. If this wer6 an application for a construction permit for one or more plants of this design, we would have no hesitation in recommending its approval.
However, we are unable to agree with the Staff, for reasons discussed below, that the design satisfactorily or completely addresses all of the concerns described in the Commission's Severe Accident Policy.
While there is no doubt that, in the future, new plants should be consistent with the Severe Accident Policy, we see no harm in the approval of the GESSAR II design, provided that this approval is for a limited time (say five years), and provided that this procedure not be viewed in any way as a precedent for the handling of future applica-tions. In particular, the information provided to us in connection with GESSAR II would not be sufficient to support an application for a one-step license.
Our concerns about the review and the review process are elaborated in the following paragraphs.
8 6 + L 2 2.(D 9 EN u
Honorable Nunzio J. Palladino January 14, 1986 We believe that reviewing the GESSAR II design under the Severe Accident Policy was premature and incomplete. We do not see how the Severe Accident Policy can ba implemented for an FDA while the policy on safety goals is still in the process of being developed. The NRC ' Staff's severe accident review of the GESSAP II design was based on the accept-ance of values of core-damage probability and the use of cost / benefit analyses that may turn out to be quite different from those adopted by the Commission for implementation of the safety goals. These and other concerns are discussed in the following items:
. In its policy statement on severe accidents, the Commission did not provide detailed guidance to the Staff concerning the safet.y philosophy the Commission desires for future plants. The require-ment for completion of a PRA and of a Staff conclusion of safety acceptability leaves the matter of desired safety level undefined and something to be decided ad hoc for each future plant or stan-dard plant design application.
. The Applicant and the Staff both evaluated the cost / benefit ratio of a large number of potential safety improvements. However, the approach used by the Staff is that which has been used in the past and may or may not be that which the Commissien will adopt in its continuing consideration of its Safety Goal Polt y.
. We believe that further evaluation is needed regarding the likeli-hood of loss of containment integrity, given an accident leading to melt-through of the reactor pressure vessel. Should this likeli-hood be large, as the Staff says it is, the acceptability of such a characteristic of containment behavior for a future plant should have the benefit of a deliberate evaluation, even if the failure is delayed.
. The Staff proposes to leave the question of seismic risk, including the fragility of equipment within the GESSAR II scope, to the construction permit stage. The Staff is confident that some, as yet unspecified, criteria for the seismic contribution to risk of severe accidents can be met at that stage without significant changes in the approved design. We do not share that confidence in the absence of a decision on a safety goal.
. The Staff consultants were provided only limited resources to review the internal flooding portion of the PRA. Because of the limited effort and the unavailability of design details vital to an evaluation of various flooding scenarios, the consultants were not able to estimate adequately the flooding contribution to core melt, which the Applicant calculates to be small. Thus, while some effort was made, the Staff's evaluation of the PRA was limited in this respect.
i Our concerns about the FDA process include chiefly two areas: (1) the amount of detail and completeness required for approval of a " final
Honorable Nunzio J. Palladino January 14, 1986 design" and (2) the nature and definition of the interfaces between the nuclear island and the balance of plant, especially those that must be expressed in terms of reliability to meet the intent of the Severe Accident Policy. These concerns are generic to the standard plant concept and have arisen in our deeper examination of GESSAR II in terms of the Severe Accident Policy. Their resolution necessarily will be evolutionary; but, in our opinion they have not been adequately resolved in the GESSAR II application and review. Some of our concern: are described more fully in the following:
. The Applicant has committed to incorporate an ultimate plant protection system (UPPS) in the GESSAR II design, which could reduce the incidence of core melt accidents. However, the detailed design of this system has not been provided; it is to be provided at the time of a specific plant application. As a result, the Staff has not been able to evaluate this proposed system, nor have we.
. We are concerned that the scope of the FDA is not defined and documented with sufficient comprehensiveness and detail. We
- believe that this is necessary in order to make clear what changes in the design or in the plant can subsequently be required by the Staff without their being justified under the backfitting rule.
. The interface requirements are not sufficiently well specified in terms of minimum, quantitative performance requirements for systems and components of importance to an evaluation of core melt frequen-cy and risk. Hence, there is no real assurance that a plant built in accordance with the GESSAR II design will meet or better the Staff's estimates of accident frequency and consequences. Also, there is no interface requirement aimed at limiting the number of a challenges arising from the balance of plant to those assumed in the PRA.
Over and above the questions relating to the severe accident review and adequacy of the FSAR for an operating license stage document, the ACRS thinks that the following matters warrant consideration for the GESSAR II.
. We believe that the design of the scram discharge system has basic deficiencies in concept in the form of a preclosed dump volume.
Consideration should be given to means, which may be relatively simple, to avoid continuing problems with this design.
We believe that there should be requirements for a study of the effects of seismically induced failures of nonseismically designed components and structures on systems important to safety, for both GESSAR II and the balance of plant.
Honorable Nunzio J. Palladino January 14, 1986
. General Electric maintains that with their choice of materials and proper attention to water quality, GESSAR II should be essentially free of stress corrosion cracking. We do not believe that this can be assumed in view of the long prior history of surprises in regard to stress corrosion cracking. We recommend that any FDA should include provisions for monitoring and for replacement of deficient material.
Our findings and recomendations are as follows:
We believe that the GESSAR II design includes features that have the potential to provide a significant improvement in safety over current BWR designs.
We are unable to agree with the Staff, for reasons discussed previously, that the design satisfactorily or completely addresses all of the concerns described in the Comission's Severe Accident Policy Statement.
We see no harm in the approval of the GESSAR II design, provided that this approval is for a limited time (say five years), and provided that this procedure not be viewed in any way as a prece-dent for the handling of future applications. In particular, the information provided to us in connection with GESSAR II would not be sufficient to support an application for a one-step license.
Additional coments by ACRS members Max W. Carbon and Charle: J. Wylie and by ACRS Member David Okrent are presented below.
Sincerely, David A. Ward Chairman Additional Coments by ACRS Members Max W. Carbon and Charles J. Wylie It is our belief that the GESSAR II design represents an improvement in safety over BWR designs approved in the past and that the Applicant has met all NRC requirements. Many items remain open to final resolution, but considerable additional review will be performed by both the Staff '
and the ACRS for either one- or two-step licensing. Therefore, we j support the Staff's plan to issue an FDA applicable to one-step licens-ing. ;
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l Honorable Nunzio J. Palladino January 14, 1986 Additional Coments by ACRS Member David Okrent i
I agree with the ACRS that the GESSAR II design (and NRC Staff review) ,
4 does not satisfactorily or completely address all of the concerns described in the Commission's Severe Accident Policy Statement. I also agree with those specific concerns about the review and review process described in the ACRS report.
I do not concur with the Staff that the design and review are adequate for issuance of an FDA that has met the Severe Accident Policy State-ment, one which, according to the EDO recommended position, would be eligible for a five-year extension after a five-year initial award (and one for which the AIF proposes a ten-year approval period). I would have preferred rather that this be an interim report and that the entire
- matter, including the status of the GESSAR II review, be discussed by the ACRS with the Comissioners prior to further action on the GESSAR II i FDA. In view of the multiple problems of inadequate design detail, incomplete Staff review, and potential conflicts with safety goal i policy, among others, I do not think that GESSAR II should receive the
" qualified" FDA recommended by the ACRS at this time.
I would like to elaborate on some of the concerns raised in the ACRS letter and introduce others that are not mentioned in the ACRS letter,
- as follows
- 1. The seismic design and seismic PRA are inadequately defined. In SSER No. 3, the Staff determined that the GESSAR II seismic risk study did not model well the risk likely to be contributed by seismic initiators for an actual GESSAR II plant at a typical site.
4 The Staff now reports that the point estimate seismic-induced core melt frequency might be as high as one-in-a-thousand per year for
! " worst case" fragility values and unfavorable siting locations.
, The Staff gives a point estimate of about 4-5 x 10-5 per year as
- the seismic contribution to core melt frequency, perhaps half of which is attributed to seismically induced relay chatter. The Staff's estimate of the seismic contribution to core melt frequency is not a mean value, and it is not practical to ascertain a mean from their reported results.
I am currently not able to ascribe a numerical value to the seismic contribution to rigk. However, I believe that the Staff estimate of about 4-5 x 10-3 is too large to be accepted for the contribu-tion to core melt frequency from a single source or kind of acci-dent initiator. I believe this value is too large an overall core melt frequency to be accepted for a future plant or FDA. I recom-mend that an overall total large-scale core melt frequency with a mean value of 10-5 per year be taken as the objective for future plants, and that about one-fifth of this objective should be a i
- somewhat flexible objective for any principal contributor, such as
- an earthquake. Limitations on the contribution from individual sources will help reduce the impact of large uncertainties.
I
Honorable Nunzio J. Palladino January 14, 1986 The Staff proposes to leave the question of seismic risk, including the fragility of components and equipment within the GESSAR II scope, to the construction permit stage. The Staff lists condi-tions to be met which could be interpreted as accepting a ' seismic core melt frequency such as the Staff estimates. The Staff further concludes that, if these conditions are not met, the utility applicant must demonstrate that this does not result in any significant increment in risk. But what is significant for a PRA?
Is it a factor of two? A factor of ten? The Staff provides no basis for judging what might be acceptable in this regard. The Staff also states that the site hazard curve must be bounded by the GESSAR II hazard curve, without explaining how unce.'tainties are to enter into such a bounding exercise.
Although GESSAR II is well into the design stage, I believe that the merits of probabilistic seismic design bases should receive consideration in trying to achieve a smaller contribution to overall risk.
- 2. I believe that the FDA should not be approved with such incomplete and sketchy information available for the proposed ultimate plant orotection system (UPPS).
- 3. For future plants, I believe that a dedicated, safety-grade, independent system for removal of decay heat from the core and
' containment should be included, in consequence of the matters entering into the resolution of USI A-45, Shutdown Decay Heat Removal, unless a case can be made that all of its merits have been met in other ways. I favor hardening this system. This issue is discu! sed further in the next item.
- 4. 4 In its review of GESSAR II, the Staff did notInlook a beyond the letter to you current requirements for sabotage protection.
dated July 17, 1985 concerning sabotage protection, the ACRS recomended that the Comission reconsider its design basis threat definition for sabotage protection and decide if the present definition should be reconfirmed or modified. The Comittee also recomended that the Comission consider whether the NRC Staff, in the course of reviews of new designs, should take account of design options, and possible combinations of measures, which might have the effect of reducing or inhibiting sabotage or terrorist threats.
This matter should be dealt with before issuance of future FDAs, rather than as a possible backfit item. Specifically, I recomend that the following be factored into the design of GESSAR II (and its balance of plant):
. a protected, independent, safety-grade shutdown heat removal system
i January 14, 1986 Honorable Nunzio J. Palladino
. protection of the control room and other vital areas or functions against a vehicle bomb at the edge of the guarded site periphery by proper location, building strength, or other measures
. geographical separation of redundant systems, including the ultimate heat removal system
. special monitoring and access control of especially sensitive protection systems
. roof design to limit helicopter landing access In sumary, I believe that neither the state of the design nor the Staff's review process is adequate for issuance of a forward-looking FDA which has taken Severe Accident and Safety Goal Policy properly into account. This is particularly so in view of the Commission's own test in applying backfitting policy.
References:
- 1. General Electric Company Standard Safety Analysis Report, "GESSAR II, BWR/6 Nuclear Island Design," with Amendments 1 through 20
- 2. U. S. Nuclear Regulatory Commission, " Safety Evaluation Report Related to the Final Design Approval of the GESSAR II BWR/6 Nuclear i Island Desien" NUREG-0979, dated April 1983
- 3. Supplement I to the Safety Evaluation Report, dated July 1983
/ Supplement 2 to the Safety Evaluation Report, dated November 1984 4.
3
- 5. Supplement 3 to the Safety Evaluation Report, dated January 1985
- 6. Suppler.ent 4 to the Safety Evaluation Report, dated July 1985 I