ML20205G296
| ML20205G296 | |
| Person / Time | |
|---|---|
| Issue date: | 08/04/1986 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Norry P NRC OFFICE OF ADMINISTRATION (ADM) |
| Shared Package | |
| ML20205G301 | List: |
| References | |
| RULE-PRM-50-44 NUDOCS 8608190457 | |
| Download: ML20205G296 (9) | |
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August 4, 1(
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MEMORANDUM FOR: Patricia G. Norry, Director Office of Administration FROM:
Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
PETITION FOR RULEMAKING (PRM-50-44)
. FILED BY THE COMMITTEE TO BRIDGE THE GAP We have reviewed the subject petition for rulemaking and find that it does not fulfill the requirements for Fast-Track processing. Therefore, it is recommended that normal rulemaking procedures be applied. We have discussed the proposed Federal Register Notice with your staff, and have suggested some clarifying changes that are indicated on the enclosed copy.. With those suggestions addressed, I concur with publication of the notice.
Robert.E. Carter, DPLB:PBSS, extension 28206 is designated as NRR's task leader for action on this petition.
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Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
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%,.....f August 4, 1986 MEMORANDUM FOR: Patricia G. Norry, Director Office of Administration FROM:
Harold R. Centon, Director Office of Nuclear Reactor Regulation
SUBJECT:
PETITIONFORRULEMAKING(PRM-50-44)
FILED BY THE COMMITTEE TO BRIDGE THE GAP We have reviewed the subject petition for rulemaking and find that it does not fulfill the requirements for Fast-Track processing. Therefore, it is recommended that normal rulemakin5 procedures be applied. We have discussed the proposed Federal Register Notice with youF staff, a.9d have suggested some clarifying changes that are indicated on the enclosed topy. With those suggestions addressed, I concur with publication of the notice.
Robert E. Carter, DPLB:PBSS, extension 28206 is designated as NRR's task leader for action on this petition.
w' Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
As stated l
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NUCLEAR REGULATORY COMMISSION 10 CFR PART 50
[DOCKETNO.PRM-50-44]
COMMITTEE TO BRIDGE THE GAP; PETITION FOR RULEMAKING AGENCY:
Nuclear Regulatory Comission.
ACTION:
Receipt of Petition for Rulemaking.
SUf; MARY: The Nuclear Regulatory Comission requests public coments on this notice of receipt of a petition for rulemaking dated July 7,1986, that was filed by the Comittee to Bridge the Gap (CBG). The petition was docketed by the Comission on July 7,1986, and assigned Docket No. PRM-50-44. The petition requests that the Comission amend its regulations to require operators of reactors that use graphite as a moderator or reflector to (1) prepare and sub-mit for NRC approval fire response plans and evacuation plans for a graphite fire and (2) measure the energy stored in their graphite, and revise their safety analyses to consider the risks and consequences of a graphite fire in their facilities. The etitioner believes this action is necessary to ade-quately protect the public in the event of a fire.
DATE: Submit coments by Coments received after this date will be considered if it is practical to do so, but assurance of consideration cannot bc given except as to coments received on or before this date.
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. ADDRESSES: Submit comments to: Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555, Attention: Correspondence and Records Branch.
For a copy of the petition write: Division of Rules and Records, Office of Administration, 4000 MNBB, U.S. Nuclear Regulatory Commission Washington, DC 20555.
Inspect and copy the petition or comments received on the petition at:
The NR,,C Public Document Room, 1717 H Street, NW., Washington, DC.
FOR FURTHER INFORMATION CONTACT: John Philips, Chief, Rules and Procedures Branch, Division of Rules and Records, Offic'e of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555, Telephone:
(301) 492-7086 or Toll Free (800) 368-5642.
SUPPLEMENTARY INFORMATION:
I.
Basis for Petition The petitioner states that two recent developments indicate that the potential for a graphite fire at U.S. reactors has been inadequately addressed.
Credibility of Graphite Fires The petitioner states that NRC and reactor licensees have held that graphite fires are "non-credible" events and as a result have failed to take measures to help mitigate or extinguish such fires, should they occur. The petitioner asserts that the occurrence of a graphite fire at the Chernobyl plant in the Soviet Union demonstrates that graphite fires are credible events.
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- The petitioner asserts that because the NRC has deemed graphite fires non-
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credible, it has failed to require basic safety measures that could help reduce the threat of such a fire. Petitioner alleges that licensees whose reactors use graphite, including dozens of nonpower research reactors, the Fort St. Vrain plant in Colorado, and the Department of Energy's N reactor, have no fire response plans for combatting graphite fires.
The petitioner further alleges that research reactor licensees do not have adequate emergency plans to evacua,te members of the public in the event of a graphite fire.
Stored (Wigner) Energy The petitioner states that new experimental" data show that the NRC's generic Y
analysis of energy stored (graphit)research reactor significantly under-estimates the actual amount of stored energy and thus, underestimates the associated risk of graphite fire. The petitioner states that in a generic study (NUREG/CR-2079) which discusses the amount of stored energy present in research reactor graphite, that NRC contractors predicted that 5 calories per gram might The petitioner be stored in the graphite of an Argonaut-type research reactor.ietns e cr\\ea ls40ss by preA states that the UCLA research reactor is an Argonaut-type and in contrast tog yes a.,a UCLAs
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, NRC predictd ceiculatic UCLA researchers reported stored energy in the 3
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reactor graphite as high as 33.2 cal / gram; while CBG, the intervenor in the UCLA reactor relicensing proceeding calculated a minimum stored energy of 113 v
calories / gram in,2000, which corresponds to 39 calories / gram /n 1988
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. The petitioner alleges that NRC's generic estimates of Wigner energy storage are inaccurate and stresses that as a remedy to the problem, actual empirical measurements of Wigner energy will be required to assess the magnitude of the energy stored in research reactor graphite and the magnitude of the fire hazard that it presents.
II. Proposed Amendments to 10 CFR Part 50 The pe,titioner requests that the NRC adopt regulations that would require all licensees whose reactors employ graphite as a neutron moderator or reflector by January 1, 1987, to:
(a) Formulate and submit for NRC approval fire response plans for combat-ting a reactor fire involving graphite and other constituent reactor parts (e.g.
fuel) which might be involved in such a fire, taking into consideration the potential for explosive reactions.
Response plans shall identify precisely which materials will be used to suppress a fire without increasing the risk of explosion, and shall indicate where and in what quantities these materials will be stored.
(b) Formulate and submit for NRC approval evacuation plans for a reactor fire. Plans should include evacuation out to a sufficient distance from the reactor such that no member of the public receives a dose to the thyroid greater than 5 rem, assuming a release to the environment of 25% of the equilibrium radioactive iodine inventory.
(c) Perform measurements of the "Wigner energy" stored in the graphite of their reactor, and submit these measurements to NRC for review together with a revised safety analysis, which shall address the risks and consequences of a reactor fire.
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. A sufficient number of graphite samples shall be measured to identify the location of maximum stored energy, and ') determine the maximum quantity of stored energy to within 10%.
"Zero power" or " critical facilities", defined here as reactors which operate at 100 watts or less, are exempted from these requirements.
III. Conclusion In conclusion, the petitioner contends that the Chernobyl accident proves that it is a mistake to assume that graphite fires are ilon-credible, and yet the NRC has based its regulatory approach to nonpower reactors on this assumption.
Petitioner further states that just as the Soviets began after Three Mile Island to recognize the necessity of reactor containment, the NRC should learn from Chernobyl that graphite fires are credible accidents and regulate graphite reactors accordingly. Above all, the petitioner believes that the NRC must require preparation of fire response plans that include the prevention and mitigation of graphite fires and evacuation plans adequate to protect the public l
in the event of a fire.
New measurements, the petitioner further concludes, indicate that the NRC has underestimated the amount of stored energy in the graphite of nonpower reactors and, consequently, that the potential for a graphite fire in such reactors has also been underestimated. The petitioner argues that since licensee calculations (such as those made by UCLA) are similarly unreliable, the NRC should order i
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. actual empirical measurements of stored energy in all nanpower reactors that use graphite. Finally, the petitioner states that safety t:ialysis reports and hazards analyses should be revised to consider generally the consequences of a release of stored energy and the risks and consequences of reactor fires.
Dated at Washington, DC this day of 1986.
For the Nuclear Regulatory Commission.
Samuel Jo Chilk, Secretary of the Commission.
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FROM: PAT NORRY, ADM ORIG. DUE DATE:
08/04/86 TICKET NO:
869497 DOC DATE:
07/23/86 TO:
DENTON NRR RCVD DATE:
07/25/86
- YELLOW **
FOR SIGNATURE OF: DENTON DESC:
CC:
PETITION FOR RULEMAKING (PRM 50-44) FILED BY DENTON/VOLLMER THE COMMITTEE TO BRIDGE THE GAP PPAS MOSSBURG REFERRED TO: DORO NLb 072586 CONTACT:
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PLEASE REVIEW THE DUE DATE IMMEDIATELY:
IF THE DU2 DATE DOES NOT ALLOW ADEQUATE REQUESTS FOR REVISION OF YELLOW TIME TO RESPOND TO THIS TICKET YOU MAY TICKET DUE DATES MAY BE MADE. WITH REQUEST A REVISED DUE DATE. THE REQUEST JUSTIFICATION, THRU THE WEEKLY WITS MUST INCLUDE A VALID JUSTIFICATION AND UPDATE UP TO ONE WEEK AFTER ASSIGN-BE MADE THROUGH YOUR CORRESPONDENCE CO-MENT BY NRR MAIL ROOM. THE NEW DUE ORDINATOR TO THE NRR MAIL ROOM (DORIS DATE, IF APPROVED BY NRR MAILROOM, MOSSDURG, -28970)
WILL BE USED TO TRACK DIVISION COR-RESPONDENCE COMPLETION SCHEDULES.
PLEASE DO NOT HAND CARRY CONCURRENCE PACKAGES TO DIRECTORS OFFICE
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WITHOUT FIRST GOING THRU THE NRR MAIL ROOM.
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