ML20196G083

Advises That Author Represented Office Position When Generic Ltr Proposing Elimination of Certain Redundant & Marginal Requirements Transmitted.Combined Minutes of CRGR Meetings 299 & 300 & Viewgraphs Encl

ML20196G083
Person / Time
Issue date:	03/05/1997
From:	Thadani A NRC
To:	Ross D NRC
Shared Package
ML20196G081	List: ML20196G077 ML20196G083 ML20196G092 ML20196G096 ML20196G104
References
NUDOCS 9705130427
Download: ML20196G083 (17)

Text

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From:

Ashok Thadani To:

TWD1.TWP4.DFR PF IoS9 Date:

3/5/97 8:12am

Subject:

Denny, Denny.

I forgot to follow up on your request regarding the office position on the proposed generic letter.

I represented the office position when I transmitted the generic letter proposing to eliminate certain redundant and marginal requirements.

Ashok

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9705130427 970407 PDR REVGP NRCCRGR MEETING 299 P DR..

. to the Combined Minutes of CRGR Meeting No. 299 and 300 Proposed Generic Letter " Modification of the NRC Staff's Recommendations for the Post-Accident Samolina System" (CRGR Meeting No. 299 January 28, 1997)

TOPIC CRGR review and endorsement of the proposed Generic Letter titled

" Modification of the NRC Staff's Recommendations for the Post-Accident Sampling System." Following the Committee's endorsement, staff plans to publish this generic letter for comments. Although. this generic letter does not impose new requirements, it does addresse a shift in the previously accepted staff position.

It is proposed that the staff would now entertain licensea-initiated requests to modify current post-accident sampling system (PASS) requirements based on NRC's originally specified in NUREG-0737. previous recommendations for PASS,Specifica licensee-initiated requests to modifiy some of their PASS requiremerts such as (1) elimination of sampling hydrogen in containment atmosphere, dissolved gases in reactor coolant in BWRs and chloride concentration in reactor coolant: and (2) increase in sampling-and analysis-time for the variables which are used to provide information needed at a later phase of accident management, such as. dissolved gases in reactor coolant in PWRs, activity in the reactor coolant and containment atmosphere, and boron concentration in reactor coolant.

However, licensees would have to evaluate any adverse impact of these modifications on the effectiveness of their emergency plans in accordance with 10 CFR 50.54(q) der the provisions of 10 CFR 50.59 siould are Furthermore. those licensees who 3ropose to implement PASS modifications un cautioned to ensure that 10 CFR 50.54(q) requirements are met.

BACKGROUND (i)

Memorandum dated December 10, 1996, from Ashok C. Thadani to Edward L.

Jordan, " Request for Endorsement Without Formal review of the Proposed Generic Letter, ' Modification of the NRC Staff's Recommendations for the Post-Accident Sampling Systems'." This review material (CRGR Item No.

151) was forwarded to the members on January 14, 1997. The attachments are as follows:

1.

Proposed Generic Letter Titled, " Modification of the NRC Staff's Recommendations for the Post-Accident Sampling Systems" 2.

Response to the CRGR Charter Questions 3.

SECY-93-087. " Policy. Technical, and Licensing Issues Pertaining to Evolutionary and Advanced Light-Water reactor (ALWR) Designs" 4.

Staff Requirements Memorandum, dated July 15. 1993, on SECY 087. (A) contains the presentation material used by the staff at the meeting.

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ISSUES / QUESTIONS The CRGR made several comments on the technical aspects and the scope of the l

proposed generic letter.

The Committee made the following specific recommendations:

Use the words " modifications to the NUREG-037 requirements..." instead e

of ".. proposed relaxations to the NUREG-037 requirements..." Also, clearly state that adoption of these modifications is voluntary and that the staff would evaluate any licensee-initiated changes to the licensee's PASS program.

Include a lead-in paragraph in the " Discussion" section clearly stating e

that the licensees (who are required to comply with the NUREG-0737 PASS requirements by Orders or through license conditions) may initiate requests for certain PASS modifications.

However, any adverse impact of these modifications on the effectiveness of their emergency plans should be evaluated in accordance with 10 CFR 50.54(q).

Furthermore, those licensees who propose to implement PASS modifications under the provisions of 10 CFR 50.59 should also be cautioned to ensure that 10 CFR 50.54(q) requirements are met.

Under " Discussion." Item 1, clearly state that hydrogen monitor in the e

containment is required to be safety grade.

Under " Discussion." Item 3. in the context of gross amount of dissolved e

gases in the reactor coolant samples, explicitly state that reference is being made mainly to hydrogen Also under " Discussion." Item 3, delete the sentence that alleges that e

".. completing sampling and analysis by 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />...will provide adequate protection to public health and safety...." as there is no obvious basis for that conclusion.

However, it is acceptable to say that performing sampling in 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> does not provide benefits commensurate with the cost.

Under " Discussion," Item 5. time for measuring activity levels in the e

reactor coolant can be extended from 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, rather than from 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Also, include the rationale for this, Commitee also agreed that the CRGR endorsement of the proposed generic o

letter is contingent upon the receipt of a letter from Director. NRR. to the Chairman, CRGR stating in accordance with.Section IV(B)(x), CRGR Charter. Revision 6, that the public health and safety and the common defense and security would be adecuately protected if the reduction in PASS requirements were implementec.

l Atachment 3(B) contains the red-line/ strike-out version of the generic letter, l

as endorsed by the CRGR.

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BACKFIT CONSIDERATIONS No backfit is either intended or approved as the actions described in the proposed generic letter are strictly voluntary.

! (A) to the Minutes of CRGR Meeting No. 299 and 300 Prooosed Generic Letter " Modification of the NRC Staff's Recommendations for the Post-Accident Samoling System" t

(CRGR Meeting No. 299 January 28, 1997)

Presentation Material used by the Staff at the Meeting f

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., 7ratta A D, Presentation to the CRGR on the Proposed Generic Letter i

" Modification of the XRC Staff's Recommendations for the Post-Accident Sampling System

(' PASS?"

I by K.I. Parczewski, NRR/DE/EMCB January 28,1997

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Purpose for Issuing of the Generic Letter i

• To notify licensees about the

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proposed modifications of some of the j

original recommendations for PASS l

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Additional knowledge gained by the j

staff, since the original PASS j

recommendations were formulated in 1980, has indicated that several j

recommendations could be relaxed without affecting quality of the j

mformation obtained by PASS l

l To make more consistent l

implementation of the PASS

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recommendations by different licensees

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Purpose of Post-Accident Sampling System l

The original PASS requirements are:

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• Promptly obtain and analyze within 3 j

hours, from making decision to take a j

sample, coolant and conta~ inment i

atmosphere samples for the following

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variables:

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- certain radionuclides that may j

be indicators of the core damage i

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- hydrogen levels in the

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containment atmosphere j

- dissolved gases in the coolant i

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- boron concentration in the 4

coolant

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Purnose of Post-Accident Samulin_e System

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• Chloride concentration within 24 or 96 l

hours, depending on the plant's i

cooling water characteristics l

• To able to take samples without j

exceeding radiation occupational limits by the operators and without a need to place auxiliary systems in operation i

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i Background Information l

j Original recommendations for PASS l

(11 criteria) were specified in Section II.B.3 of NUREG-0737, " Clarification

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i of TMI Action Plan Requirements,"

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published in November 1980 l

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l Staff Guidance for implementation of l

the PASS recommendations were specified in two Generic Letters 83-36 l

(for BWR) and 83-37 (for PWR),

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issued in November 1,1983.

l In these letters-NRC specified that l

PASS program can be referenced in the administrative control section of the TS and its detailed description i

included in the plant operatmg l

manuals. This would allow the i

licensees to modify PASS programs

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under 10 CFR 50.59 i.

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Background Information (cont'd) j In spite of the staff guidance, j

specified in Generic Letters 83-36 and j

83-37, the recommendations of l

NUREG-0737 were imposed in the majority of operating plants as i

requirements by orders or as license i

conditions.

These licensees are i

reqmred to obtain NRC authorization j

to modify PASS operational j

procedures 3

l In 1987 PASS program was evaluated l

by Pacific Northwest Laboratory

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which in its report (NUREG/CR-4330) proposed some j

modifications i

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i Background Information (cont'd) j In 1990, in response to inquires from

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PASS Owners-Group and a 1993 l

request from Combustion j

Engineering, the NRC staff clarified its position on several PASS i

l recommendations and identified

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several areas where some changes are acceptable (elimination of analyses l

for containment hydrogen and pH l

and oxygen in the reactor coolant) l i

More recently, EPRI requested several relaxations of PASS l

requirements for their Advanced l

Light Water Reactor Utility l

Requirements Documents.

These j

relaxations were reviewed by the staff and passed to the Commission in SECY-93-087. In a staff requirements memorandum dated July 21,1993, the l

Commission approved these

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modifications with some changes 4

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Proposed Modifications of PASS j

(1)

Elimination of hydrogen analysis in the containment atmosphere i

i This analysis ~ is not needed because l

of the existence of hydrogen monitor, recommended in Item II.F.1 of NUREG-0737 (2)

Elimination of dissolved gas analysis in reactor coolant in BWRs

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Whenever the reactor vessel is j

depressurized during a suspected j

core uncovery, dissolved gases i

will be released. Measuring their l

concentration in the coolant is j

therefore meaningless. Their j

concentration before depressurization j

could be estimated from their concentration in the containment j

atmosphere. When core uncovery is i

not suspected, concentration of

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dissolved gases can be determined l

later by a normal process sampling

Proposed Modifications of PASS (cont'd) 4 i

(3)

Increasing analysis time for dissolved l

gases in PWRs from 3 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> j

after an accident This information is used later in the i

plant recovery phase and sampling at i

3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> after an accident puts i

unjustifiable burdens on a licensee.

i (4)

Elimination of chloride analysis in PWRs and BWRs This information is required for assessing the need for corrosion 4

control.

Since corrosion is a long-term phenomenon, samples can be taken later by process sampling.

Proposed Modifications of PASS (cont'd) i A

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(5)

Increasing time for making activity l

level measurements l

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Activity levels are needed for determining core damage, classify events, determine source term for l

dose calculations, determine protective action recommendations for the public and analyze the progression of an i

accident. Although other indications are available, PASS results provide l

direct confirmation. Any licensee proposing to extend of the sampling time, will be required to meet the requirements of 10 CFR 50.54(q)

Proposed Modifications of PASS (cont'd) i (6)

Increasing analysis time for boron from 3 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after an accident Knowledge of boron concentration in the reactor coolant is required for evaluating reactivity of the core.

However, for the plants equipped with neutron flux monitoring instrumentation which meets Category I criteria of Reg Guide 1.97, this information can be obtained independently of boron concentration and for these plants analysis for boron can be postponed to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after an accident

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Backfit Discussion The modifications of the PASS procedures, described in the proposed generic letter, consist of the changes of the existing recommendations, specifies in Section II.B.3 of NUREG-0737, which l

licensees may introduce into their facilities Since these licensees' actions are strictly voluntary,. the staff has not performed a backfit analysis i

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's i (B) to the Combined Minutes of CRGR Meeting No. 299 and 300 Proposed Generic Letter " Modification of the NRC Staff's Recommendations for the Post-Accident Sampling System" (CRGR Meeting No. 299 January 28, 1997)

Red-line/ strike-out version of the generic letter endorsed by the CRGR

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