ML20198C896
| ML20198C896 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 12/16/1998 |
| From: | Hall J NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| FACA, NUDOCS 9812220208 | |
| Download: ML20198C896 (3) | |
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- 5 E NUCLEAR REGULATORY COMMISSION I- wasuiwarow, o.c. sones.cooi [# a- 34g h
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, December 16, 1998 MEMORANDUM TO: All NRR Project Directors and Proje anagers l
P THRU: John N. Hannon, Director
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Project Directorate IV-1 -
! Division of Reactor Projec II/IV
[= Office of Nuclear React Regulation FROM: James R. Hall, Lead Project Manager Project Directorate IV-1 d' '
s Division of Reactor Projects ill/lV I Office of Nuclear Reactor Regulati i
SUBJECT:
PROJECT MANAGER GUIDANCE FOR RISK-INFORMED l CONFIRMATORY ORDERS ON POST-ACCIDENT HYDROGEN MONITORING in the August 25,1998, memorandum from the EDO to the Chairman, the staff committed to a
- i. number of short- and long-term actions to address concerns raised by Congress and other stakeholders. In the area of risk-informed and performance-based regulation, a number of i
plant-specific licensing reviews were identified. One of these actions, Item I.C.8, involved l.
reexamining and revising the TMl action plan requirements for post-accident hydrogen monitoring at ANO Units 1&2. A followup action, item I.C.12, was established to address the l Issue for all operating plants.
L l l On September 28,1998, the staff issued a confirmatory order for ANO Units 1&2, modifying the previous requirement to establish continuous indication of hydrogen concentration in containment following a severe accident. The licensee had initiated a request for relief from this requirement based, in part, on risk insights that showed that control room operators could
- have more important tasks immediately following an event, and that information on hydrogen concentration would not be used until a later time in the event response. The confirmatory order for ANO relaxed the requirement to establish hydrogen monitoring within 30 minutes of L the initiation of safety injection, replacing it with a functional requirement that allows the
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licensee the flexibility to determine the appropriate time limit for providing indication of hydrogen concentration in containment. This functional requirement provides for the establishment of procedures for the initiation of hydrogen monitoring based on: 1) consideration of other L important activities in the control room; 2) the need for information and timing for decision making for severe accident management and emergency response; and 3) insights from experience or analyses regarding significant hydrogen generation scenarios associated with core damage or loss of containment integrity.
l Similar requirements were imposed on all operating reactors, as described in Action item II.F.1,
!_ Attachment 6, of NUREG-0737," Clarification of TMI Action Plan Requirements." These
- _ requirements were typically imposed by confirmatory orders, based on commitments contained g g i
- in licensee responses to NRC Generic Letters 82-05 and 82-10. These confirmatory orders ;
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were issued for operating plants on or about March 14,1983. For plants licensed after that date, TMl action plan items were typically addressed by the staff in the Safety Evaluation Report and may not have been imposed by confirmatory order.
Project Manaaer Action:
Please fax or e-mail a copy of the attached confirmatory order for ANO to your licensing contact, and ask them if they are interested in a similar confirmatory order for their facility. The PM and/or the licensee may need to do some research to confirm that ,the commitment made in response to TMI Action Plan item II.F.1 is similar to that made for ANO (i.e.,30 minutes to establish post-accident hydrogen monitoring). For plants that received operating licenses after March 1983, item II.F.1 may have been addressed in a different manner than a confirmatory order, and therefore, a different action (if any) may be appropriate for relief from the timing requirement for establishing post-accident hydrogen monitoring.
If a licensee expresses interest in a similar confirmatory order, we would like a written request from them. The letter should simply specify the licensee's proposed wording for revising the '
current post-accident hydrogen monitoring requirement and provide a brief statement similar to the basis for the ANO confirmatory order. The goal of this effort is to offer licensees relief from a requirement which risk insights indicate may be overly restrictive; consequently, we want to minimize the effort required from licensees in requesting this relief.
Please contact your licensee and transmit the ANO order to them by December 23,1998.
Upon doing so, please call or send an e-mail to the Lead PM, Randy Hall (JRH,415-1336),
indicating that the notification is complete for your plant. If you have any questions or receive a request from your licensee, please consult with the Lead PM.
Attachment:
As stated DISTRIBUTION:
' Docket File J PUBLIC PD4-1 r/f C. Berlinger C.Hawes ACRS OGC (15B18) J. Zwolinski E. Adensam (EGA1) J. R. Hall B. Boger M. Boyle J.Hannon G. Holahan R. Barrett D. Dorman D.Lange M. Snodderly W. Reckley A. El-Bassioni Document Name: H2_MONIT.GDN _ h OFC PM/PD4-1 LA/PI)4-1 PDhD4-1 l NAME JRHalh CHahes JHannon DATE /2//' /98 lh N/98 O/ /98 COPY kS/NO YES/NO EShO OFFICIAL RECORD COPU l
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2 were issued for operating plants on or about March 14,1983. For plants licensed after that date, TMI action plan items were typically addressed by the staff in the Safety Evaluation Report and may not have been imposed by confirmatory order.
Project Manaaer Action:
Please fax or e-mail a copy of the attached confirmatory order for ANO to your licensing contact, and ask them if they are interested in a similar confirmatory order for their facility. The PM and/or the licensee may need to do some recearch to confirm that the commitment made in response to TMI Action Plan item II.F.1 is similar to that made for ANO (i.e.,30 minutes to
- establish post-accident hydrogen monitoring). For plants that received operating licenses after March 1983, item II.F.1 may have been addressed in a different manner than a confirmatory order, and therefore, a different action (if any) may be appropriate for relief from the timing requirement for establishing post-accident hydrogen monitoring.
If a licensee expresses interest in a similar confirmatory order, we would like a written request from them. The letter should simply specify the licensee's proposed wording for revising the current post-accident hydrogen monitoring requirement and provide a brief statement similar to i the basis for the ANO confirmatory order. The goal of this effort is to offer licensees relief frorn '
a requirement which risk insights indicate may be overly restrictive; consequently, we want to minimize the effort required from licensees in requesting this relief.
Please contact your licensee and transmit the ANO order to them by December 23,1998.
Upon doing so, please call or send an e-mail to the Lead PM, Randy Hall (JRH,415-1336),
indicating that the notification is complete for your plant. If you have any questions or receive a request from your licensee, please consult with the Lead PM.
Attachment:
As stated j I
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p%ine L, p' % UNITED STATES l
I g j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066-0001 f $n, e?
lp %g September 28,1998 ic l
Mr. C. Randy Hutchinson j Vice President, Operations ANO )
Entergy Operations, Inc.
, 1448 S. R. 333 Russellville, AR 72801 J, c l
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SUBJECT:
CONFIRMATORY ORDER MODIFYING POST-TMl REQUIREMENTS PERTAINING TO CONTAINMENT HYDROGEN MONITORS FOR ARKANSAS l _
NUCLEAR ONE, UNITS 1 AND 2 (TAC NOS. MA1267 AND 1268) j I
Dear Mr. Hutchinson:
- The enclosed Order modifies the current requirement pertaining to establishing a continuous
', ' indication of hydrogen concentration in containment following severe accidents. By letter dated -
March 2,1998, Entergy Operations Inc.-(EOl), requested relief from the requirement of having
[ , indication of hydrogen concentration in containment within 30 minutes of the initiation of safety injection for Arkansas Nuclear One (ANO), Units 1 and 2. The request was part of an industry initiative undertaken by the Commission and the Nuclear Energy Institute (NEI) to improve the l< incorporation of risk-informed and performance-based insights into the regulation of nuclear power plants. However, because the existing requiroments concerning hydrogen monitoring at -
! . ANO were imposed by confirmatory Orders in the aftermath of the TMI accident, the staff informed you in a letter dated July 22,1998, that it was necessary for EOl to submit an i
application for an amendment to the operating licenses of ANO-1 and ANO-2 in accordance with 10 CFR 50.90.
E in order to act in a more timely manner to the request and to address the issue by a more generic approach, we are issuing the enclosed Order. Following various discussions between r our organizations, EOl submitted a letter dated September 9,1998, in which it provided a commitment to operate and maintain the containment hydrogen monitors for ANO-1 and ANO-2
- in accordance with the functional requirement described in the enclosed Order.
Regarding your suggestion that the NRC staff use a similar approach to revise requirements
' pertaining to post-accident sampling systems, a recommendation to consider such action has
!.1 been forwarded to the NRC's Risk-informed Licensing Panel. You may wish to discuss this
! matter with NEl and other industry organizations in order to develop a generic proposal and to ATTACHMENT o
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- Mr. C. Randy Hutchinson establish an appropriate priority for changes to post-accident sampling systems in relation to other initiatives for improving the incorporation of risk informed and performance-based insights !
l into the regulation of nuclear power plants.
The enclosed Order has been forwarded to the Office of the Federal Register for publication. l If you have any questions, please contact me at (301) 415-1314.
- - Sincerely,
/S/ 4
\
William Reckley, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects lil!IV l Offlce of Nuclear Reactor Regulation Docket Nos. 50-313 and 50-368
Enclosure:
Order cc w/enci: See next page a
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of )
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Entergy Operations, Inc. ) Docket Nos. 50-313
) and 50-368
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(Arkansas Nuclear One, ) License Nos. DPR-51 Units 1 and 2) ) and NPF-6 .
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CONFIRMATORY ORDER MODIFYING POST-TMI REQUIREMENTS PERTAINING TO CONTAINMENT HYDROGEN MONITORS 1.
Entergy Operations, Inc. (the Licensee), is the holder of Facility Operating License Nos.
OPR-51 and NPF-6 issued by the Nuclear Regulatory Commission (NRC or Commission) pursuant to 10 CFR Part 50. The licenses authorize the operation of Arkansas Nuclear One, Units 1 and 2 (ANO-1, ANO-2), located in Pope County, Arkansas.
11.
As a result of the accident at Three Mile Island, Unit 2 (TMI-2), the NRC issued NUREG-0737," Clarification of TMl Action Plan Requirements"(November 1980). Generic Letters 82-05 and 82-10, issued on March 17, and May 5,1982, respectively, requested licensees of operating power reactors to furnish inforniation pertaining to their implementation of specific TMI Action Plan items described in NUREG-0737. Orders were issued to licensees
- confirming their commitments made in response to the generic letters. Orders to the Licensee issued on March 14,1983, require the Licensee to implement and maintain the various TMi Action Plan items, including item II.F.1,' Attachment 6 pertaining to monitoring of hydrogen concentration in containment.
Significant improvements have been achieved since the TMI accident in the areas of
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understanding risks associated with nuclear plant operations and developing better strategies for managing the response to potentially severe accidents at nuclear plants. Recent insights pertaining to plant risks and alternate severe accident assessment tools have led the NRC staft ,
to conclude that some TMI Action Plan items can be revised without reducing, and perhaps l l l enhancing, the ability of licensees to respond to severe accidents. The NRC's efforts to p ,
l i oversee the risks associated with nuclear technology more effectively and to eliminate undue j L )
o regulatory costs to licensees and the public have prompted the NRC's decision to revise the 1 l \
l post-TMI requirement related to establishing incication of hydrogen concentration in j containment.
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The confirmatory Orders of March 14,1983 imposed requirements upon the Licensee for having continuous indication of hydrogen concentration in the containment atmosphere 1
provided in the control room, as described by TMI Action Plan item II.F.1, Attachment 6.
Information about hydrogen cor: entration supports the Licensee's assessments of the degree
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core damage and whether a threat to the integrity of the containment may be posed by combustion of the hydrogen gas. TMI Action item II.F.1. Attachment 6 states:
If an indication is Ict available at all times, continuous indication and recordin]
shall be functioning wi',hin 30 minutes of the initiation of safety injection.
This requirement to have indication of the hydrogen concentration in containment within I !
30 minutes following the start of an accident has defined both design and operating l
,. characteristics for hydrogen monitoring systems at nuclear power plants since the l
!. implementation of NUREG-0737. In addition, the technical specifications of most nuclear power l plants and NRC regulations at 10 CFR 50.44, " Standards for combustible gas control system in j i l
~ light-water-cooled power reactors," require availability of hydrogen monitors. ;
j By letter dated March 2,1998, Entergy Operations, Inc., requested relief for the two l
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3 j j within 30 minutes of the initiation of safety injection. Specifically, the Licensee requested a 90- 'i l
minute limit for indication of hydrogen concentration in containment. The technical basis for this j request was that the actions necessary to establish the hydrogen indication are a distraction for l l control room operators f;om more important tasks during the initial attempts to respond to an I i?
event 61d that information provided by the monitors is not used until later stages of responding to an accident.-
l- The Licensee's request of March 2,1998, was made in conjunction with Task Zero of l
the Risk-informed, Performance-Based Regulation Pilot Program, an initiative undertaken by
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the NRC and the Nuclear Energy Institute to improve the incorporation of risk-informed and
. pedormance-based insights into the regulation of nuclear power plants. Because the licenses
. for ANO-1 and ANO-2 were modified by the Orders of March 14,1983, imposing TMI Action
- Plan item II.F.1, Attachment 6, the staff informed the Licensee by letter dated July 22,1998, !
that it was necessary to submit an application for an amendment to the operating licenses of i ANO-1 and ANO-2 in accordance with 10 CFR 50.90 in order to modify the time limit for post-i ,
L ' accident hydrogen monitoring. Upon further reflection, however, the NRC staff has decidad
! that it could act upon this request more expeditiously by issuance of this Order.
On the basis of the NRC staff's review of information provided by the Licensee, l consideration of the lessons learned since the TMI-2 accident pertaining to severe accident I management and emergency planning, and in order to mako'NRC licensing and regulatory l oversight more efficient, the staff concludes that the Licensee should have the flexibility and i; . -
I: assume the responsibility for determining the appropriate time limit for indication of hydrogen i l
concentration in containment,~such that control room personnel are not distracted from more important tasks la the early phases of accident mitigation, and decisionmakers, mostly outside
' the control room, are able to benefit from having useful information on hydrogen concentration.
Because the appropriate balance between control room activities and longer term management m ,
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4 of the response to severe accide;1ts can best be determined by the Licensee, the NRC staff has determined that the Licensee may elect to adopt a risk-informed functiona! requirement in lieu of the current 30 minute time limit for indication of hydrogen concentration as imposed by the Orders dated March 14,1983, and as described by TMI Action Item II.F.1, Attachment 6 in NUREG-0737. The applicable functional requirement is as follows:
Procedures shall be established for ensuring that indication of hydrogen concentration in the containment atmosphere is available in a sufficiently timely manner to support the role of the information in the Arkansas Nuclear One Emergency Plan (and related procedures) and related activities such as guidance for severe accident management. Hydrogen monitoring will be initiated on the basis of (1) the appropriate prionty for establishing indication of hydrogen concentration within containment in relation to other activities in the control room, (2) the use of the indication of hydrogen concentration by decisionmakers for severe accident management and emergency response, and (3) insights from experience or evaluation pertaining to possible scenarios that result in significant generation of hydrogen that would be indicative of core damage or a potential threat to the integrity of the containment building. Affected ll censing-basis documents and other related documents will be appropriately revised and/or updated in accordance with applicable NRC regulations.
The Licensee's technical specifications and 10 CFR 50.44 require the Licensee to maintain the ability to monitor hydrogen concentration in containment. However, the details pertaining to the design and manner of operation of the hydrogen monitoring system are determined by the Licensee.
Ill.
Following various discussions with the staff, the Licensee submitted a letter dated September 9,1998, in which it provided a commitment to operate and maintain the containment hydrogen monitors for ANO-1 and ANO-2 in accordance with the applicable functional requirement described in Section ll above. The Licensee stated that the adoption of the functional requirement statement would initially result in extending the time requirement for hydrogen monitors from 30 minutes to 90 minutes after the initiation of safety injection.
1 I find that the Licensee's commitment as set forth in its letter of September 9,1998, is
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t l 5 acceptable and conclude that with this commitment the plant's safety is reasonably assured. In view of the foregoing, I have determined that public health and safety require that the ,
Licensee's commitment be confirmed by this Order. During its discussions with the NRC staff,-
i the ' Licensee agreed to waive its right to a hearing with respect to issuance of this Order. !
IV. !
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Accordingly, pursuant to Sections 103,104b,161b,1611,1610, and 182 of the Atomic j Energy Act of 1954, as amended, and the Commission's regulations in 10 CFR 2.202 and i 10 CFR Part 50, IT IS H,EREBY ORDERED that- <
, I (1) NRC License Nos. DPR-51 and NPF-6 are modified as follows:
The Licensee may elect to either maintain the 30-minute time limit for indication of hydrogen in containment, as described by TMl Action Plan i item li.F.1, Attachment 6, in NUREG-0737 and required by the l Confirmatory Orders of March 14,1983, or modify the time limit in the -l manner specified in Sections ll and lil of this Order, j (2)' The licensee's commitments in its letter of September 9,1998, see j Secuun lillabove, are confirmed.
1 The Director, Office of Nuclear Reactor Regulation, may, in writing, relax or rescind any L of the above conditions upon demonstration by the Licensee of good cause.
V.
L Any person adversely affected by this Confirmatory Order, other than the Licensee, may request a hearing within 20 days of its issuance. Where good cause is shown, consideration -i
- will be given to extending the time to request a hearing. A request for extension of time must be made in writing to the Director, Office of Nuclear Reactor Regulation, U.S. Nuclear
- Regulatory Commission, Washington, D.C. 20555-0001, and include a statement of good '
h .cause for the extension.~ Any request for a hearing shall be submitted to the Secretary, U.S. .
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- Nuclear Reguist6ry Commission, ATTN: Chief, Rulemakings and Adjudications Staff,
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I$ Washington, D.C. 20555-0001. Copies of the hearing request shall also be sent to the Director, i
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i Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, D.C. I 20555-0001; to the Deputy Assistant General Counsel for Hearings and Enforcement at the i 1
same address; to the Regional Administrator, NRC Region IV,611 Ryan Plaza Drive, Suite 400, )
Arlington, Texas 76011; and to Nicholas S. Reynolds, Esquire, Winston and Strawn,1400 L Street, N.W., Washington, DC 20005-3532, attorney for the Licensee. If sucn a person I requests a hearing, that person will set forth with particularity the manner in which his interest is i
adversely affected by this Order and will address the criteria set forth in 10 CFR 2.714(d).
If the hearing is requested by a person whose interest is adversely affected, the Commission willissue an Order designating the time and place of any hearing. If a hearing is held, the issue to be considered at such hearing will be whether this Confirmatory Order should be sustained.
l in the absence of any request for hearing, or written approval of an extension of time in )
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- which to request a hearing, the provisions specified in Section IV above will be final 20 days l from the date of this Order without further order or proceedings. If an extension of time for requesting a hearing has been approved, the provisions specified in Section IV will be final ,
when the extension expires if a hearing request has not been received. )
FOR THE NUCLEAR REGULATORY COMMISSION i l j ORIGINAL SIGNED BY:
. Samuel J. Collins, Director l Office of Nuclear Reactor Regulation
, - Dated at Rockville, Maryland, This 28th day of September 1998.
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