ML20154J804

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Forwards Rev 2 to Proposed Reg Guide 1.99, Radiation Damage to Reactor Vessel Matls & Proposed Reg Guide 1.XXX, Guide for Licensee Preparation & NRC Staff Review Of.... Guides Will Be on CRGR 850925 Meeting 81 Agenda
ML20154J804
Person / Time
Issue date: 09/06/1985
From: Stello V
Committee To Review Generic Requirements
To: Bernero R, Cunningham R, Jordan E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), Office of Nuclear Reactor Regulation
Shared Package
ML20151L097 List:
References
REF-GTECI-A-49, REF-GTECI-RV, RTR-REGGD-01.099, RTR-REGGD-01.XXX, RTR-REGGD-1.099, RTR-REGGD-1.XXX, TASK-A-49, TASK-OR NUDOCS 8603110055
Download: ML20154J804 (3)
v • d • e


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MEMORANDUM FOR:

Robert Bernero, NRR Edward L. Jordan, IE Richard E. Cunningham, NMSS Denwood F. Ross, RES Clemens J. Heltemes, Jr., AE0D Joseph Scinto, ELD FROM:

Victor Stello, Jr., Chairman Comittee to Review Generic Requirements

SUBJECT:

TRANSMITTAL OF CANDIDATE REVIEW ITEMS FOR CRGR MEETING NO. 81, SEPTEMBER 25, 1985

Reference:

1.

Proposed Regulatory Guide 1.99, Revision 2, " Radiation Damage to Reactor Vessel Materials."

(Memo from R. Minogue to V. Stello, Jr., dtd August 27,19G5.)

2.

Proposed Regulatory Guide 1.xxx, " Guide for Licensee Preparation and NRC Staff Review cf Plant-Specific Analyses Required by the Pressurized Thermal Shock Rule, 10 CFR 50.61 (USI A-49 Resolution).

(Memo from H. Denton to V. Stello dtd August 5, 1985.)

The reference Regulatory Guides are being transmitted for your information and review.

It is expected that these two items will be considered as part of the agenda at CRGR Meeting No. 81 tentatively scheduled for September 25, 1985.

The total agenda for Meeting No. 81 is now being firmed up and will be forwarded soon.

1.

The proposed Regulatory Guide (RG) 1.99, Revision 2, was considered by the CRGR at Meeting No. 79 on July 24, 1985.

It was subsequently withdrawn by RES request pending further clarification of its relationship to and the effects on the recently published final rule on Pressurized Thermal Shock (PTS) (10 CFN 50.61). A reinstatement of the CRGR review is now being requested by RES. The modified RG 1.99, Revision 2 is enclosed along with various memoranda largely reflecting results of ED0 actions subsequent to CRGR Meeting No. 79.

I see no need for an update of the RUGR staff sumary and issues sheet provided to you on July 19, 1985 concerning this matter.

2.

Submittal of detailed plant-specific PTS risk analyses is a requirement set forth by the final PTS rule applying to those plants that reach the rule specified RT based screening criteria for the reactor vessel materialduringt$Tterm of the operating license. The enclosed RG 1.xxx proposed on this matter presents an amalgam of PRA requirements and guidance as to how the detailed plant-specific PTS risk analyses should be performed by affected licensees and how the staff should review such analyses.

Because this proposed RG has a technical relationship to the

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RT correlations and guidance being set forth by proposed RG 1.99, ReDk[ ion 2, we will review both of these related proposals on the same CRGR agenda, cricic~- s;5 2ud by

.[ictor stc11o Victor Stello, Jr., Chairman Committee to Review Generic Requirements

Enclosures:

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orrelations and guidance being set forth by proposed RG 1.99, ReUk[ ion 2,wewillreviewbothoftheserelatedproposalsonthesame CRGR agenda.

Origir.al sic. led by

,2ictor Stcllo Victor Stello, Jr., Chainnan Committee to Review Generic Requirements

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NOV 4 1335 MEMORANDUM FOR:

William J. Dircks Executive Director for Operations Victor Stello, Jr., Chaiman FROM:

Comittee to Review Generic Requirements

SUBJECT:

MINUTES OF CRGR MEETING NUMBER 81 The Conunittee to Review Generic Requirements (CRGR) met on Wednesday, 2

September 25, 1985 from 12:30-5:00 p.m.

A list of attendeec for this meeting is enclosed (Enclosure 1).

G. Arlotto (RESf briefed the CRGR regarding existing and forthcoming sununarizes 1.

guidance associated with the Decomissioning Rule.

thismatter(Category 2 item)

G. Arlotto (RES) presented for CRGR review proposed Revision 2 to Regulatory Guide 1.99, Radiation Damage to Reactor Vessel Materials.

2. sununarizes this matter (Category 2 item).

T. Speis (NRR) presented for CRGR review the proposed Regulatory Guide, entitled " Guide for Licensee Preparation and NRC Staff Review of 3.

Plant-Specific Analysis Required by the Pressurized Thennel Shock Rule, 10 CFR 50.61 (US! A-49 Resolution). Enclosure 4 sununarizes this matte (Category 2 item).

D.Allison(IE)presentedforCRGRreview,theproposedIEBulletin, 4.

entitled Steam finding of Auxiliary Feedwater Pumps.

sumarizes this matter (Category 2 item).

Enclosures 2, 3, 4 and 5 contain predecisional info w tio public forum) or decided the matters addressed by the information.

In accordance with the ED0's July 18, 1983 directive concerning " Feedback and Closure on CRGR Reviews," items 2, 3, and 4 above require written responses from cognizant offices to report agreement or disagreement with CRGR mandations in these minutes.

days after receipt of these meeting minutes, are to be forwarded to the CRGR Chainnan and if there is disagreement with the CRGR recomendations, to the i

E00 for decisionmaking.

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335 Questions concerning these meeting minutes should be referred to Walt Schwink (492-8639).

Original signed by V. stelle Victor Stello, Jr., Chainnan Comittee to Review Generic Requirements

Enclosures:

As Stated cc: Comission (5)

SECY Office Directors Regional Administrators CRGR Members G. Cunningham G. Arlotto T. Spets R. Baer Distribution:

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~ to the Minutes of CRGR Meeting No. 81 CRGR Review of Proposed IE Bulletin, " Steam Binding of Auxiliary Feedwater Pumps D. Allison (IE) presented for CRGR review, the subject proposed bulletin.

Issuance of the bulletin was proposed by IE in response to a number of incidents over the last several year at operating reactors in which steam binding of AFW pumps occurred as a result of leakage of hot water or steam past isolation valves. Actions specified in the proposed bulletin, intended to prevent or minimize recurrence of similar problems in the future, included development of procedures by licensees (and training of operating personnel regarding implementation of those procedures) for detecting and interpreting conditions of steam binding (or conditions that could lead to steam binding) and for correcting such conditions when detected.

The proposed bulletin' package was transmitted to CRGR by memo dated September 6,1985, J. M. Taylor to V. Stello, Jr.; that memo included the following enclosures:

1.

Proposed IE Bulletin 85-XX, dated August 1985, " Steam Binding of Auxiliary Feedwater Purps."

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2.

Memo, dated July 7, 1985. E. L. Jordan to J. M. Taylor, " Steam Binding of Auxiliary Feedwater Pumps."

i 3.

Enclosure, undated, entitled "Information for CRGR Review on Proposed IE Bulletin 85-XX..." (Submitted in accordance with the provisions of CRGR Charter,Section IV.8).

4.

IE Information Notice 84-06, dated January 25, 1985, " Steam Binding of Auxiliary Feedwater Pumps."

5.

INPO Significant Event Report 5-84, "Back Leakage Disabled Auxiliary Feedwater Pump."

6.

INPO Significant Operating Experience Report No. 84-3, dated April 17,.

1984, " Auxiliary Feedwater Pumps Disabled by Backleakage."

7.

AE00 Report C404, dated July 1984, " Steam Binding of Auxiliary Feedwater Pumps."

8.

Memo, dated November 21, 1983, C. J. Heltemes to R. C. DeYoung, " Vapor j

Binding of Auxiliary Feedwater Pumps."

9.

Memo, dated June 25, 1985, R. M. Bernero to Knight /Speis, etal, " Generic Issue No. 93, Steam Binding of Auxiliary Feedwater Pumps."

Copies of the briefing slides used by IE for presentation to the CRGR at this meeting are attached (see Attachment 1 to Enclosure 5).

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The proposed Bulletin was aimed principally at licensees /permittees who have failed to respond effectively to previous notifications of steam binding events, and the need for action to prevent their occurrence in the future, including specifically analyses and recommendations by INPO.

(See listing of affected licensees /permittees in Attachment 1 to this Enclosure). The main objective of the bulletin was to cause licensees /permittees who have not yet done so to develop and implement procedures for monitoring and interpreting plant conditions conducive to or symptomatic of steam binding. A collateral objective was to cause licensees /permittees who have not yet done so to formalize the procedures they have developed, and to provide training to plant personnel, to ensure continued consistency in the performance of those procedures (regarded as " interim" measures by.the NRC staff, until a long term fix for this problem can be identified and implemented in the context of GenericIssueNo.93).

The staff estimated that the benefit to be obtained from implementing the proposed t 11etin was in the range of 30-96K person-rem. NRC estimates of the costs involved were $1100K (total industry cost) and $100K (total NRC cost).

1 The principal points of discussion at this meeting in connection with the proposed bulletin were as follows:

1.

The staff had indicated in the proposed bulletin that monitoring of AFW piping temperature by simply touching with the hand was an acceptable method of monitoring for conditions of steam binding, or for conditions that could lead to steam binding, of AFW pumps.

The Committee noted that leakage past isolation or check valves into AFW piping could produce temperatures well above ambient, but still not so uncomfortable to the touch as to unambiguously indicate the need for corrective action to plant operators, if some acceptance criteria were not specified in this regard.

The Connittee suggested, therefore, (and the staff agreed) that wording should be added to the bulletin to specify that plant personnel monitoring AFW piping temperature should assure that the temperature remain close to ambient.

2.

The staff emphasized in the package provided for CRGR review and in presentations at this meeting, that the bulletin was directed principally at those licensees who had failed to respond adequately to earlier evaluations and recommendations by INPO regarding the steam binding problem. The Connittee acknowledged that such followup by the staff was appropriate, but suggested that the emphasis in the bulletin itself be focused on the potential safety problem involved, and the need for action based purely on the safety concern involved, not on licensees' failure to respond to INP0 recommendations. The staff agreed to reexamine the specific wording of the bulletin to assure that the proper emphasis was reflected in the bulletin finally issued.

3.

The Committee noted that " Limited Distribution" INPO documents had been provided by IE as part of the package submitted for CRGR review, and that in the normal course of events all CRGR review package material was i

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released to the PDR after final action was taken by the agency on any item reviewed by the CRGR. The staff was requested to inquire specifically, therefore, (if they had not already done so explicitly) whether INPO had any objections to public release of their documents in this case to assure that some provision of the INP0/NRC agreement was not inadvertently violated by handling the review package material in the usual way. The staff agreed to do so, and to inform CRGR of INP0's position on this matter in timely fashion before the projected release date for the CRGR package relating to this meeting, i

As a result of discussions at this meeting of the proposed bulletin, the Comittee recomended issuance of the bulletin with wording revised in accordance with the preceding.

IE will coordinate revisions to the bulletin wording with the ROGR staff prior to final issuance of the bulletin.

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ATTACHMENT 1 TO ENCLOSURE 5 Atjt{h0 January 25, 1984 Page 1 of I h

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WITH STEAM SINDING 1.9 X 10-4 2.9 X 10-4 6.1 X 10-4 f

CORE MELT PROBASILITY, PER REACTOR YEAR l

DOMINANT SEQUENCE WITHOUT STEAM BINDING 2.8 X 10-6 3 X 10-6 3 X 10-6

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DOMINANT SEQUENCE WITH j

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PLANT ACTION PROCEDURES FOR TRAINING FOR (JUSTIFY /

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JUSTIFY SALEM i JUSTIFY BOTH BOTH SALEM 2 JUSTIFY BOTH BOTH OCONEE 1 JUSTIFY BOTH BOTH l

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OCONEE 3 JUSTIFY BOTH BOTH l

CALVERT CLIFFS 1 J8JSTIFY BOTH NEITHER l

CALVERT CLIFFS 2 JUSTIFY BOTH NEITHER YANKEE-ROWE JUSTIFY CORRECT CORRECT BYRON 1 JUSTIFY CORRECT NEITHER CRYSTAL RIVER 3 JUSTIFDf NEITHER BOTH INDIAN POINT 3

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MILLSTONE 2 JUSTIFY NEITHER NEITHER l

TURKEY POINT 3 JUSTIFY NEITHER NEITHER TURKEY POINT 4 JUSTIFY NEITHER NEITHER PALISADES JUSTIFY NEITHER NEITHER DAVIS-BESSE JUSTIFY NEITHER NEITHER l

WATERFORD 3 JUSTIFY NEITHER NEITHER MONITOR BEAVER VALLEY 1 MONITOR BOTH BOTH INDIAN POINT 2 MONITOR BOTH BOTH CATAWBA 1 MONITOR BOTH BOTH FARLEY 1 MONITOR BOTH BOTH FARLEY 2 MONITOR BOTH BOTH MCGUIRE 1 MONITOR BOTH BOTH MCGUIRE 2 MONITOR BOTH BOTH ROBINSON 2 MONITOR BOTH BOTH SEQUOYAH 1 MONITOR BOTH BOTH SEQUOYAH 2 MONITOR BOTH BOTH SURRY 1 MONITOR BOTH BOTH SURRY 2 MONITOR BOTH BOTH ZION 1 MONITOR BOTH BOTH ZION 2 MONITOR BOTH BOTH FT CALHOUN MONITOR BOTH BOTH AND 1 MONITOR BOTH BOTH ANO 2 MONITOR BOTH BOTH SAN ONOFRE 2 MONITOR BOTH BOTH SAN ONOFRE 3 MONITOR BOTH BOTH PALO VERDE 1 MONITOR BOTH BOTH

TABLE 1 TABULAR

SUMMARY

PLANT ACTION PROCEDURES FOR TRAINING FOR (JUSTIFY /

IDENTIFICATION /

IDENTIFICATION /

MONITOR)

CORRECTION CORRECTION HADDAM ECK MONITOR BOTH NEITHER D C COOK 1 MONITOR BOTH NEITHER D C COOK 2 teNITOR BOTH NEITHER NORTN ANNA 1 MONITOR IDENTIFY IDENTIFY NORTN ANNA 2 MONITOR IDENTIFY IDENTIFY SAN ONOFRE 1 MONITOR IDENTIFY IDENTIFY ST LUCIE 1 MONITOR NEITER BOTH ST LUCIE 2 MONITOR EITER BOTH SLMMER MONITOR NEITHER BOTH DIABLO CANYON 1 MONITOR NEITHER BOTH PRAIRIE ISLAND 1 MONITOR NEITHER IDENTIFY PRAIRIE ISLAND 2 MONITOR NEITHER IDENTIFY

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4G31AUEE MONITOR-NEITHER IDENTIFY POINT BEACH 1 MONITOR NEITHER IDENTIFY POINT BEACH 2 MONITOR EITHER IDENTIFY GINNA MONITOR NEIT M NEITHER l

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ESTIMATED COSTS NRC COST

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$800,000 CONTINUING INDUSTRY COST

$300,000 PER YEAR TOTAL PRESENT VALUE

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MEMORANDUM FOR:

William J. Dircks Executive Director for Operations Victor Stello, Jr., Chainnan FROM:

Comittee to Review Generic Requirements MINUTES OF CRGR MEETING NUMBER 81

SUBJECT:

The Comittee to Review Generic Requirements (CRGR) met on Wednesday,A September 25, 1985 from 12:30-5:00 p.m.

meeting is enclosed (Enclosure 1).

G. Arlotto (RESIbriefed the CRGR regarding existing and forthcomingEnclosure 1.

guidance associated with the Decomissioning Rule.

this matter (Category 2 item).

G. Arlotto (RES) presented for CRGR review proposed Revision 2 to Regulatory Guide 1.99, Radiation Damage to Reactor Vessel Materials.

2. sumarizes this matter (Category 2 item).

T. Speis (NRR) presented for CRGR review the proposed Regulatory Guide entitled " Guide for Licensee Preparation and NRC Sta 3.

10 CFR 50.61 (USI A-49 Resolution). Enclosure 4 sumarizes this (Category 2 item).

D. Allison (IE) presented for CRGR review, the proposed IE Bulletin, 4.

entitled Steam Binding of Auxiliary Feedwater Pumps.

sumarizes this matter (Category 2 item).

Enclosures 2, 3, 4 and 5 contain predecisional inform public forum) or decided the matters addressed by the infonnation.

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directive concerning " Feedback and In accordance with the ED0's July 18, 1983 Closure on CRGR Reviews," items 2, 3, and 4 above require written responses from cognizant offices to report agreement or disagreement with CRG days after receipt of these meeting minutes, are to be forwarded to the mendations in these minutes.

Chairman and if there is disagreement with the CRGR recomendations, to th EDO for decisionmaking, t

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Questions concerning these meeting minutes should be referred to Walt Schwink

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Original S%ned by V. Stello Victor Stello, Jr., Chairman Committee to Review Generic Requirements

Enclosures:

As Stated cc: Commission (5)

SECY Office Directors Regional Administrators CRGR Members G. Cunningham G. Arlotto T. Speis R. Baer Distribution:

VStello JRoe JHSniezek WLittle RHernan EFox JHenry RErickson JZwetzig FHebden JPhilips ETriner DEDROGR cf Central File PDR(NRG/CRGR).

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9 to the Minutes of CRGR Meeting No. 81 Briefing Concerning Existing and Forthcoming Guidance Associated with Decommissioning G. Arlotto and K. Steyer (RES) briefed the CRGR concerning the existing and forthcoming guidance associated with the decomissioning rulemaking. The attachment lists and generically describes the evolving new Regulatory Guides (RGs) and identifies those that RES plans to forward for CRGR consideration.

In addition to the 12 new RGs, conforming modifications to existing guidance will be developed. RES intends that appropriate existing and evolving guidance developed by contractors and industry will be included in thc NRC guidance.

The schedule in the Attachment indicates that the guidance will be completed within the next 2 years utilizing 4 man years of effort.

The CRGR offered the following coments concerning the guidance for decomissioning:

1.

Decomissioning guidance must not be inconsistent with evolving NRC/ EPA radiation standards.

2.

Since final EPA /NRC determination of residual radioactivity standards is not likely to occur within the next 2 years, the staff may want to recon-sider the current 12-24 month schedule for developing decomissioning guidance that could be affected by the evolving standards. Prudent scheduling of guidance development would avoid issuing guidance that is either premature or late with respect to issuance of final NRC/ EPA stancards.

3.

Decomissioning facilitation guidance appears to be like the ALARA required in 10 CFR Part 20, Standards for Protection Against Radiation.

Since there are existing requirements and guidance for ALARA is there a need for additional ALARA guidance for decomissioning?

4.

As a legal matter, if a utility's Part 50 and Part 70 (SNM) license is tenninated, can the utility obtain a by product license from NRC or an

" Agreement State" and thereby be exempt from the "Decomissioning Rule and Guidance?"

5.

Since there are existing NRC rep? ting and recordkeeping requirements and guidance that prescribe form, fonnat, number of copies and retention, is there a need for additional reporting and recordkeeping requirements and guidance for decomissioning?

i 6.

In general, is there a need for so much new guidance considering the existence of both NRC and industry documents containing extensive and diverse guidance for decomissioning?

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2-Mr. Arlotto asked the CRGR whether or not Committee review was required for all new decomissioning guidance which applied only in part to power reactor licensees. In response, the Comittee requested that all new decommissioning guidance be forwarded to the CRGR Chairmsn for his detemination of whether or not CRGR review was necessary.

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PUBLISHED FEBRUARY 11, 1985 MAJOR ISSUES 1.

ALTERNATIVES / TIMING 2.

PLANNING 3.

FINANCIAL ASSURANCE 4.

RESIDUAL RADI0 ACTIVITY LIMITS (fart 4 to W f"i20 E"'5' 5.

ENVIRONMENTAL REVIEW REQUIREMENTS ISSUE 4. TO BE DEALT WITH IN SEPARATE RULEMAXING

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MAJOR PROPOSED REQUIREMENTS INCLUDE:

1.

FINANCIAL ASSURANCE PLANS OR CERTIFICATION TO BE SUBMITTED BY APPLICANTS AND EXISTING LICENSEES (ALL PART 50 AND CERTAIN MATERIALS LICENSEES) 2.

RECORDS IMPORTANT TO DECOMISSIONING TO BE KEPT BY ALL LICENSEES UNTIL TERMINATION OF LICENSE 3.

DECOMISSIONING PLANS TO BE SUBMITTED AT THE END OF OPERATION (ALL PART 50 AND SOME MATERIALS LICENSEES) o we

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DECOMISSIONING REGULATORY GUIDES CE-224-4

  • FORMAT AND CONTENT OF NUCLEAR REACTOR DECOMISSIONING PLANS CE 304-4 FORMAT AND CONTENT OF NUCLEAR FUELS AND MATERIALS FACILITIES DECOMMISSIONING PLANS CE-025-4
  • ASSURANCE OF FUNDING FOR NUCLEAR REACTOR DECOMISSIONING CE-305-4 ASSURANCE OF FUNDING FOR NUCLEAR FUELS AND MATERIALS FACILITIES DECOMISSIONING REVISION OF R.G. 1.86, " TERMINATION OF NUCLEAR REACTOR CE-Oll-4 OPERATING LICENSES" CE-110-4 TERMINATION OF LICENSES FOR FUELS AND MATERIALS FACILITY LICENSES RECORDS IMPORTANT TO DEComISSIONING NUCLEAR REACTORS CE-408-4 RECORDS IMPORTANT TO DECOMISSIONING OF FUELS AND MATERIALS FACILITIES
  • FACILITATION OF DEC0mISSIONING OF NUCLEAR REACTOR FOR DOSE AND WASTE MINIMIZATION CE-413-4 FACILITATION OF DECOMMISSIONING OF FUELS AND MATERIALS FACILITIES FOR DOSE AND WASTE MINIMIZATION
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DECOP9tISSIONING GUIDES (CONTINUED)

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  • TERMINATION SURVEY PROCEDURES - INSTRUMENTATION, SAMPLING, (AVERAGING, HIGH CONFIDENCE TECHNIQUES *
  • PRIMARY RULE BASIS: PART 20 ON RESIDUAL RADI0 ACTIVITY LIMITS M

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I FORMAT AND CONTENT OF DECOMISSIONING PLANS P-PRIMARY RULE BASES:

o 50.82 AND 30.36 CONTAIN REQUIREMENT FOR DECOMISSIONING PLANS AND MAJOR ELEMENTS OF THE PLANS OBJECTIVE: TO PROVIDE GUIDANCE ON THE CONTENT AND TO PRESENT A FORMAT FOR DECOMISSIONING PLANS TO ASSIST THEIR PREPARATION AND REVIEW i

ASSURING THE AVAILABILITY OF FUNDS. FOR DECOMISSIONING PRIMARY RULE BASES:

o 50.33(k) AND 30.35(a) REQUIRE THAT A FUNDING METHOD BE SELECTED.

i o 50.33(k). AND 30.35(d) REQUIRE A LICENSEE AS ONE OF TWO OPTIONS. TO SUBMIT A COST ESTIMATE AS PART OF HIS FUNDING PLAN AND TO ADJUST IT PERIODICALLY; AND 50.54(cc) REQUIRES A LICENSEE TO SUBMIT AN UPDATED COST ESTIMATE 5 YEARS BEFORE END OF OPERATIONS.

4 OBJECTIVE: TO PROVIDE GUIDANCE ON FUNDING METHODS AND DECOMISSIONING COST ESTIMATES FOR COMPLYING WITH THE SPECIFIED RULE SECTIONS.

TERMINATION OF LICENSES 2

PRIMARY RULE BASES:

o 50.90 AND 30.38 PERTAIN TO LICENSE AMENDMENTS 1

o 50.82 AND 30.36 CONTAIN LICENSE TERMINATION PROCEDURES AND i

CRITERIA REQUIREMENT FOR DEC0mISSIONING' PLANS AND CRITERIA FOR APPRO/AL

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OBJECTIVE:

TO PROVIDE GUIDANCE ON LICENSE TERMINATION PROCEDURES AND DECOMISSIONING ALTERNATIVES.

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RECORDS IMPORTANT TO DECOMMISSIONING PRIMARY RULE BASIS o 50.54(dd) AND 30.34(1) REQUIRE LICENSEES TO KEEP RECORDS IMPORTANT TO SAFE AND EFFECTIVE DECOMMISSIONING IN A FILE EXPLICITLY FOR THIS PURPOSE UNTIL THE LICENSE IS TERMINATED OBJECTIVE: TO PROVIDE GUIDANCE ON RECORD FILE CONTENTS AND RETENTION FOR COMPLYING WITH THE SPECIFIED RULC SECTIONS FACILITATION OF DECOMMISSIONING FOR DOSE AND WASTE MINIMIZATION i

PRIMARY RULE BASIS o EXISTING 30.33(a) AND 50.54(a) AND PROPOSED 30.36(c) AND 50.82(b) REQUIRE THAT EQUIPMENT AND PROCEDURES HAVE DESIGNS AND CONTROLS AND LIMITS ON THEM DURING DECOMMISSIONING TO PROTECT OCCUPATIONAL AND PUBLIC HEALTH AND SAFETY. THE FEDERAL REGISTER NOTICE INDICATES THAT FACILITATION OF DECOMMISSIONING SHOULD BE CONSIDERED UNDER THESE PROVISIONS OBJECTIVE: TO PROVIDE GUIDANCE ON AREAS FOR FACILITATION WHICH SHOULD BE CONSIDERED IN COMPLYING WITH THE SPECIFIED RULE SECTIONS FOR DECOMMISSIONING i

NEED/ BENEFIT NRC FACILITATES IMPLEMENTATION OF DECOMMISSIONING AMENDMENTS BY IDENTIFYING CRITERIA FOR CONSISTENT AND EFFICIENT REVIEW BY LICENSING AND INSPECTION STAFFS OF FUNDING METHODS DECOM-MISSIONING PLANS, RECORDKEEPING PROVISIONS, AND LICENSE TERMINATION PROCEDURES PREPARED IN RESPONSE TO THE RULE REQUIREMENTS. THIS AIDS STAFF REVIEW AND MINIMIZES STAFF TIME AND CORRESPONDENCE BETWEEN NRC AND LICENSEES TO THE EXTENT PRACTICAL.

INDUSTRY STANDARDIZATION OF LICENSING AND INSPECTION REVIEW IN THESE AREAS FACILITATES PREPARATION AND SUBMITTAL OF FUNDING PLANS AND DECOPHISSIONING PLANS, LICENSE TERMINATION PROCEDURES AND DEVELOPMENT OF RECORDKEEPING PROVISIONS. THE GUIDE ILLUSTRATES MEANS OF DEETING NEW RULE REQUIREMENTS, REDUCES UNCERTAINTY AND UNNECESSARY COPEUNICATION WITH NRC, EXPEDITES IMPLEMENTATION OF THE REQUIREMENTS AND MINIMIZES COST AND IMPACT OF THE RULE ON INDUSTRY TO THE EXTENT PRACTICAL.

PUBLIC 4

MORE EFFECTIVE IMPLEMENTATION OF RULE AMENDMENTS IN ASSURANCE OF FUNDS. DECOP911SSIONING PLANNING RECORDKEEPING, AND LICENSE TERMINATION WILL REDUCE RISK OF WORKER AND PUBLIC EXPOSURE TO RADIATION.

3.

IMPACT NRC

- WITH RESPECT TO USE OF THE GUIDE BY LICENSING AND INSPECTION STAFF REVIEWERS, NO SIGNIFICANT ADDITIONAL RESOURCE IMPACT IS ANTICIPATED AS A RESULT OF THIS ACTION SINCE IT MERELY PROVIDES GUIDANCE FOR SUBMITTALS AND OTHER PROVISIONS REQUIRED BY THE RULE, AND IN FACT SHOULD MINIMIZE STAFF TIME INVOLVED IN REVIEW.

THE MANPOWER NEEDED TO PREPARE THE GUIDES IS THE ONLY ADDITIONAL IMPACT ON NRC AND IS 4 MANYEARS TO COMPLETE DEVELOPMENT AND ISSUE OF GUIDES.

Ly 086 INDUSTRY NO SIGNIFICANT ADDITIONAL ECONOMIC IMPACT IS ANTICIPATED AS A RESULT OF THIS ACTION SINCE IT MERELY PROVIDES GUIDANCE FOR SUBMITTALS AND OTHER PROVISIONS REQUIRED BY THE RULE AND IN FACT SHOULD MINIMIZE INDUSTRY STAFF TIME INVOLVED IN COMPLYING WITH RULE REQUIREMENTS.

PUBLIC NONE.

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l UUASHt900 TON. D. C. 30665 NOV 4 1535 PN 4

,t MEMORANDUM FOR:

William J. Dircks Executive Director for Operations

~

FROM:

Victor Stello, Jr., Chaiman Comittee to Review Generic Requirements

SUBJECT:

MINUTES OF CRGR MEETING NUMBER 81 The Comittee to Review Generic Requirements (CRGR) met on Wednesday, September 25, 1985 from 12:30-5:00 p.m.

A list of attendees for this meetingisenclosed(Enclosure 1).

G. Arlotto (RESIbriefed the CRGR regarding existing and forthcoming

1. sununarizes guidance associated with the Decomissioning Rule.

this matter (Category 2 item).

4 G. Arlotto (RES) presented "or CRGR review proposed Revision 2 to 2.

Regulatory Guide 1.99, Radiation Damage to Reactor Vessel Materials. sumarizes this matter (Category 2 item).

T. Speis (NRR) presented for CRGR review the proposed Regulatory Guide, 3.

entitled " Guide for Licensee Preparation and NRC Staff Review of Plant-Specific Analysis Required by the Pressurized Thermal Shock Rule, 10 CFR 50.61 (USI A-49 Resolution). Enclosure 4 sununarizes this amtter i

(Category 2 item).

D. Allison (IE) presented for CRGR review, the proposed IE Bulletin,

4.

entitled Steam Binding of Auxiliary Feedwater Pumps.

sununarizes this matter (Category 2 item).

Enclosures 2, 3, 4 and 5 contain predecisional information and therefore will not be released to the Public Document Room until the NRC has consid public forum) or decided the matters addressed by the information.

j In accordance with the E00's July 18, 1983 directive concerning " Feedback and f

Closure on CRGR Reviews," items 2, 3, and 4 above require written responses from cognizant offices to report agreement or disagreement with CRGR i

mendations in these minutes.

days after receipt of these meeting minutes, are to be fomarded to the CRGR i

Chairman and if there is disagreement with the CRGR recomendations, to the i

EDO for decisionmaking.

F

%) ;! ! 9'/&

W,6

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33 Questions concerning these meeting minutes should be referred to Walt Schwink (492 8639).

Original Signed by V. Stello Victor Stello, Jr., Chairman Comittee to Review Generic Requirements

Enclosures:

As Stated cc: Comission (5)

SECY Office Directors Regional Administrators CRGR Members G. Cunningham G. Arlotto T. Speis R. Baer Distribution:

VStello JRoe JHSniezek WLittle RHernan EFox JHenry RErickson JZwetzig FHebdon JPhilips ETriner DEDROGR cf Central File PDR(NRG/CRGR)

ROGR Staff

^

0FC :RO R

DEDROGR NAME:JHin ek
VStello

~

m

}

i to the Minutes of CRGR Meeting No. 81 Proposed Draft of Revision 2 to Regulatory Guide 1.99 l

" Radiation Damage to Reactor Vessel Materials" G. Arlotto and N. Randall (RES)(presented for CRGR review, a proposed draf t of Revision 2 to Regulatory Guide RG) 1.99 now entitled " Radiation Damage to Reactor Vessel Materials." The proposed Revision 2 to RG 1.99 was initially considered by CRGR at Meeting No. 79 on July 24, 1985. The reader is referred to those minutes for a more complete discussion of the proposed RG 1.99 Rev. 2, its content, its guidance and the pmposed staff implementation plans. At Meeting No. 79, CRGR concluded there was a need for further information and a better understanding about the relationship to and the integration of the proposed RG 1.99, Rev. 2 guidance with the requirements of the recently issued rule on Pressurized Thermal Shock (PTS), 10 CFR 50.61. CRGR recommended that the EDO request a priority effort by NRR and RES to address this matter. RES subsequently withdrew the proposed RG pending such further clarifications. The specific CRGR concern was that the proposed RG set forth procedures for calculating the extent of radiation damage to reactor vessel materials that differed from the correlations used for the same purpose in the PTS rule.

By its memorandum dated August 27, 1985, RES requested a reinstatement of the CRGR review of proposed RG 1.99, Rev. 2.

At Meeting No. 81, G. Arlotto described those actions that had taken place pursuant to the concerns expressed by CRGR at Meeting No. 79, including the EDO followup actions recomended by CRGR and the RG revisions made as a result. By memorandum dated August 12, 1985 to the EDO, NRR and RES provided infonnation as to the relationship between the RG'and the PTS rule.

A plan was recomended for coordinating with the PTS rule requirements.

In essence, this plan recomended the issuance of proposed RG 1.99, Rev. 2 for public coment during which time the PTS rule would remain in place for regulatory use. During the coment period, licensees and the technical comunity would consider the technical merits of the proposed RG including effect of the RT correlations on their plants for non-PTS purposes; chiefly as a basis b the pressure-temperature operating limits pursuant to requirements of Appendix G,10 CFR Part 50. As the resubmitted CRGR package indicated, the staff would make it clear by the RG language and in applicable forwarding letters, the expected relationship to the PTS rule.

Licensees would be invited to consider and comment on the effect of the RG proposal to the calculated PTS risk at their plant assuming that the proposed RT correlation and calculational procedures in the RG could in the future (ikDIound justified) replace the RT correlation in the PTS rule. During the RG coment resolution period, tNbexisting PTS rule requirements would be bringing forth additional information to the staff on the actual PWR plant-specific materials and fluence. values. This additional plant-specific information, together with public coments on the proposed RG, would allow the staff to reevaluate the overall conservatism of the PTS rule and to assess whether a rule amendment would be desirable.

Following a satisfactory discussion by the staff as to the degree of conservatism to be included for the low fluence region of the proposed RTNDT

~

2-correlation (most applicable to BWR vessels), the CRGR endorsed the coordinated course of resolution advanced by the staff. Without further coment, CRGR recomended in favor of the prompt issuance of proposed Revision 2 to RG 1.99 for public coment.

O I

i

PTS Proposed Regulatory Guide CRGR Review - 9/25/85

Background

Final PTS Rule is Fed. Reg. 7/23/85.

Rule requires licensees to:

Report RTPTS(6mos.).

Report flux. reduction plans (9 mos.).

Analyze PTS risk (3 yrs, before RTSC)

NRC obligated to publish this guidance and acceptance criteria for those PTS risk analyses.

0 4

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. Guidance Perform PRA type analysis similar to ORNL prototype analyses Assemble plant systems information, including proposed corrective actions.

use event tree techniques to identify PTS sequences group sequences, select representative for each group g

calculate thermal-hydraulic response, including mixing, for g

representative sequences

/

, calculate total frequency for each group 4

perform ~ fracture mechanics calculation for rep. seqs.

~

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perform failure mode calculation for rep, seqs.

9AI' calculate risk for rep. seqs. (core melt, person-rem, fatalities) ve4 integrate total PTS risk

$ gun evaluate uncertainties in calculations

_ gr compare with acceptance criteria justify continued operation 0

o Acceptance Criteria - (Dual)

Thru-wall crack (TWC) freq:

less than 5 x 10'0/ Reactor year basically a core melt (CM) criterion (CMori TWC) set low to allow for uncertainties precedent

~ Risk,(person-rem, fatalities)

~

compare results to criteria in use at time

~

included to insure TWC criteria results in acceptable risk for all vessel and containment types, locations.

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NUCLEAR RECULATORY COMMISSION WASHINGTON, D. C. 30585

\\

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NOV 4 1355 t

1 MEMORANDUM FOR:

William J. Dircks Executive Director for Operations FROM:

Victor Stello, Jr., Chainnan i

Comittee to Review Generic Requirements

SUBJECT:

MINUTES OF CRGR MEETING NUMBER 81 The Co mittee to Review Generic Requirements (CRGR) met on Wednesday, September 25, 1985 from 12:30-5:00 p.m.

A list of attendees for this meeting is enclosed (Enclosure 1).

i G. Arlotto (REST briefed the CRGR regarding existing and forthcoming

1. sumarizes guidance associated with the Decomissioning Rule.

thismatter(Category 2 item)

G. Arlotto (RES) presented for CRGR review proposed Revision 2 to 2.

Regulatory Guide 1.99, Radiation Damage to Reactor Vessel Materials.

- sumarizes this matter (Category 2 item).

T. Spets (NRR) presented for CRGR review the proposed Regulatory Guide, 3.

entitled " Guide for Licensee Preparation and NRC Staff Review of l

Plant-Specific Analysis Required by the Pressurized Thennal Shock Rule, 10 CFR 50.61 (USI A-49 Resolution). Enclosure 4 sumarizes this matter (Category 2 item).

D.Allison(IE)presentedforCRGRreview,theproposedIEBulletin,

4.

entitled Steam Binding of Auxiliary Feedwater Pumps.

sumarizes this matter (Category 2 item).

Enclosures 2, 3, 4 and 5 contain predecisional information and therefore will not be released to the Public Document Room until the NRC has consid public forum) or decided'the matters addressed by the information.

4 In accordance with the ED0's July 18, 1983 directive concerning " Feedback and Closure on CRGR Reviews," items 2, 3, and 4 above require written responses from cognizant offices to report agreement or disagreement with CRGR l mandations in these minutes.

days after receipt of these meeting minutes, are to be forwarded to the CRGR Chairman and if there is disagreement with the CRGR recomendations, to the 4

EDO for decisionmaking.

l r

.,t'e _

33 Questions concerning these meeting minutes should be referred to Walt Schwink (492_8639).

Original Signed by V. Stello Victor Stello, Jr., Chairman Committee to Review Generic Requirements

Enclosures:

As Stated cc: Commission (5)

SECY Office Directors Regional Administrators CRGR Members G. Cunningham G. Arlotto T. Speis R. Baer Distribution:

VStello JRoe JHSniezek WLittle RHernan EFox JHenry RErickson JZwetzig FHebdon JPhilips ETriner DEDROGR cf Central File PDR(NRG/CRGR)

R0GR Staff 1

^

OFC :RO R

DEDROGR NAME :JH3n ek
VStello um e.

m

j 9h s

4 i to the Minutes of CRGR Meeting No. 81 Proposed Draft Regulatory Guide 1.XXX

" Guide for Licensee Preparation and NRC Staff Review of Plant-5pecific Analysis Required by the Pressurized Thermal Shock Rule,10 CFR 50.61" i

i F. Schroeder and R. Woods (NRR) presented the subject Regulatory Guide (RG) for CRGR review. The handouts used by Mr. Schroder in this presentation are attached. The subject RG 1.XXX was transmitted for CRGR for its review by a memorandum dated August 5,1985 from H. Denton to V. Stello, Jr.

In addition to the-proposed RG 1.XXX, the package transmitted to CRGR included a Regulatory 4

Analyses for the proposed RG and background information pertinent to the CRGR review of this USI A-49 matter.

CRGR was requested to.reconsnend in favor of issue of the proposed RG 1.XXX for public comments. This proposed RG describes the staff's expectations for i

licensee submittal of plant-specific analyses of the PTS risks. These plant-specific analyses are required to be provided by an affected licensee 3 years before exceeding the reactor vessel screening criterion (RTPTS) specified by the final PTS rule, 10 CFR 50.61.

i The final PTS rule was published by the Commission on July 23, 1985 and it specifies that no licensee will be required to submit an analysis sooner than 1 year after the staff has published guidance on the content of the' required plant-specific analyses. The staff has chosen to fulfill this provision of the i

l PTS rule for plant-specific guidance by use of a RG.

4 The proposed RG 1.XXX represents a significant NRC step toward requiring the affected licensees to conduct very detailed probabilistic risk assessments to 3

{

enable a regulatory decision about the PTS risk. This analysis would ultimately serve as part of the regulatory decision bases for continued plant operation should a licensee propose to operate with his reactor vessel beyond screening criteria of the PTS rule. The staff indicated to the CRGR that the number of licensees potentially affected by the PTS risk analyses called for in RG 1.XXX could perhaps range from 0 to 4.

In setting forth this proposed guidance, the staffhasestablishedaprobabilisticallgbasedgoalforthePTScausedreactor vessel failure; i.e., a value of 5 x 10- per reactor year is set forth as the acceptable mean frequency for reactor vessel failure by through-wall cracking.

This through-wall cracking is taken to potentially result in core damage or a large scale core-melt accident along with a possible direct loss of contain-ment integrity. The staff provided a view, however, that the through-wall cracking of a reactor vessel by PTS does not necessarily equate to a core-melt

i.e., the core-melt accident may have a lower frequency such as accideng/per reactor year. The staff in the proposed RG also noted that this 1 x 10~

probabilistic goal may be subject to future revision.

In essence, the proposed analysis requirements in RG 1.XXX would require an affected ifcensee to conduct extensive probabilistic risk analyses closely paralleling that plant-specific analysis effort pioneered on three plants by RES and the various national labs over about the past 4 years. As the proposed RG points out (e.g., pg. 24 and 50)

there remains a number of areas in these PTS risk analysis yet to be closed but closure would be required of the affected licensee.

The CRGR reconsnended the following:

1.

The staff should consider incorporating a " trip" mechanism into the proposed RG 1.XXX such that a licensee faced with exceeding the PTS rule screening criteria (with use of the RT correlations therein) should be permitted to conduct and to submit les$Thxtensive PTS risk analyses. These less extensive analyses would focus on reducing the predicted through-wall

(

crack frequency. Should the licensees plant-specific analyses and his f

proposed corrective actions satisfy the staff that the affected reactor vessel would remain within or at about the probabilistic goal established by the staff for the frequency of PTS caused through-wall cracking, then there should be no necessity to carry out the total risk assessment (such as the core damage analyses, containment failure mode analyses, off-site consequence analyses, etc) now specified in proposed RG 1.XXX. On the other hand, if'a licensee contemplates no satisfactory alternatives but to continue operation above the PTS rule screening criteria, then the licensee

-should bear the full burden of justification and conduct the complete PTS risk assessment.

2.

The staff should reexamine the necessity to include the extensive editorial' guidance and prescriptiveness about the standard format and content ^ expected for the PTS safety analyses reports. CRGR noted that such editorial guidance and prescriptivenesse was already in existence elsewhere and the need to replicate this guidance by Section II of proposed RG 1.XXX was not evident. CRGR suggested a deletion and the j

incorporation of such editorial guidance by reference.

3.

The staff should carefully reexamine the proposed RG language so as to I

improve its clarity and provide for more bounded guidance on what should be specifically' submitted to the staff if an affected licensee is required to do the complete PTS risk assessments. For example, CRGR noted that it was unclear as to whether new calculational models and probabilistic codes would have to be developed by the industry or licensees and if.so, whether these should be part of the plant-specific analysis submitted or should these be maintained in an auditable fashion. Pages 47 and 52 were cited as examples where the guidance appeared unbounded and unclear as to cause and effects; e.g., " core movements and deformation caused by missiles should be examined to evaluate core damage and probability of core melt" (pg 47); " tube ruptures could result from superheeted steam produced during core melt down" (pg 52).

Subject to the staff's satisfactory resolution of the above, the CRGR concluded that it could reconnend to the EDO in favor of issuance of the proposed RG 1.XXX for public conment. The CRGR Chairman requested the staff to provide him with a copy of the revised RG 1.XXX prior to its issue for comment.

l l

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7, [j NUCLEAR REGULATORY COMMISSION t

WASHINGTON, D. C. 20555 P

/

SEP 161985 j

l l

MEPORANDUM FOR:

Robert Bernero, NRR Edward L. Jordan, IE Richard E. Cunningham, NMSS Denwood F. Ross, RES Clemens J. Heltemes, Jr., AE00 Joseph Scinto, ELD FROM:

Victor Stello, Jr., Chairman Committee to Review Generic Requirements

SUBJECT:

CRGR MEETING NO. 81 The Comnittee to Review Generic Requirements (CRGR) will meet on Wednesday, September 25, 1985, from 12:30 - 5:00 p.m. in Room 6507 MNBB. The agenda is as follows:

12:30 - 1:30 p.m. - G. Arlotto (RES) will brief the CRGR concerning the existing and forthcoming guidance associated with the deconinissioning rule (Category 2 item).

1:30 - 2:30 p.m. -

G. Arlotto (RES) will present for CRGR review, proposed Revision 2 to Regulatory Guide 1.99, Radiation Damage to Reactor Vessel Materials. A copy of the proposed Regulatory Guide, which was considered by the CRGR at Meeting No. 79, was enclosed in a September 6,1985 memorandum from V. Stello to the CRGR members (Category 2 item),

i 2:30 - 4:00 p.m.-

T. Speis (NRR) will present for CRGR review the proposed Regulatory Guide entitled " Guide for Licensee Preparation and NRC Staff Review of Plant-Specific Analysis Required by the Pressurized Thermal Shock Rule, 10 CFR 50.61 (USI A-49 Resolution). A copy of the proposed Regulatory Guide was enclosea in a September 6,1985 memorandum from i

V. Stello to the CRGR members (Category 2 item).

4:00 - 5:00 p.m. -

R. Baer (IE) will present for CRGR review, the enclosed proposed IE Bulletin entitled " Steam Binding of Auxiliary Feedwater Pumps" (Category 2 item).

If a CRGR member cannot attend the meeting, it is his responsibility to assure that an alternate, who is approved by the CRGR Chairman, attends the meeting.

Persons making presentations to the CRGR are responsible for (1) assuring that the information required for CRGR review is provided to the Committee (CRGR Charter - IV.8), (2) coordinating and presenting views of other Yfif j} -j j- ~j $7d r["

s SEP I6' Bd5 1

-2 offices, (3) as appropriate, assuring that other offices are represented during the presentation, and (4) assuring that agenda modifications are coordinated with the CRGR contact (Walt Schwink, x28639) and others involved with the presentation. Division Directors or higher management should attend meetings addressing agenda items under their purview.

In accordance with the ED0's March 29, 1984 memorandum to the Commission con-cerning " Forwarding of CRGR Documents to the Public Document Room (PDR)," the enclosure, which contains predecisional information, will not be released to the PDR until the NRC has considered (in a public forum) or decided the matter addressed by the information.

Original Signed 1:j V, Stallo Victor Stello, Jr., Chainnan Comittee to Review Generic Requirements

Enclosure:

As stated cc: SECY Commission (5)

W. J. Dircks Office Directors Regional Administrators G. Cunningham G. Arlotto T. Speis R. Baer Distribution:

VStello JRoe JHSniezek TRehm ROGR Staff DEDROGR cf JZwetzig EFox JPhilips JHenry FHebdon WLittle RErickson Central File PDR(NRG/CRGR) RHernan l

l

~

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1

DEDROGR 0FC :ROGR/5
R00f,/D

- _ _ _ _ : _ _,_ -. ky_)_k b

iezek

VStello NAME:WSdw

__-__:____--______:_h/85 DATE :9/13/85

9/
9/ /85 1

]

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