ML20235D736
| ML20235D736 | |
| Person / Time | |
|---|---|
| Issue date: | 06/23/1987 |
| From: | Morris P NRC |
| To: | Price H NRC |
| Shared Package | |
| ML20234E460 | List:
|
| References | |
| FOIA-87-40 NUDOCS 8707100280 | |
| Download: ML20235D736 (12) | |
Text
J l
s ,
l S ~E f ridt<tc( )
4
- g ' >< s 'y 7j , '
UNITF.D STt.TES lj ;)g).))
ATOMIC ENERGY COMMIGSION
\ f 'A/ w,w.m nc r ors. o.c. mu r%w& _-
, i JUl.18 h
. i
. i h
Marold L. Price, Director of Regulation '
e l I
.(1)
HULEiJAKING ITEl,iS ,~
At your request I have commented brief]y on current practico v/ith regard to my wouo to you of I.iny 26, 1969, listing itous to consiCor for proposed rulemaking.
A .- Requirements for flood protection using standard III'n analysis techniques plus runup.
Uc currently require " Maximum Probable Flood" analysos from applicants and insist that tbc p] ants be protected to va)ues of MDF plus tcavo action as determined by CERC or the Corps of Engineers.
B. Ecquircuents for the subm.ittal of environmental monitor-.
ing reports (and v/h:t1 they should contain) to us and Departr,'nnt of Interior.
At the CP stage vc ash applicante to agree to FLU recom-mendations. At the POL stage vce put envi ronmental uonitor--
ing requirements in the Tech Spocs. We have no standardo in this area, hovcover.
C. Specif J e requirements for providing information on R&D programs.
Uc got information on specific H&D items by requesting- c
" additional information." Applicants nood standard guidance on what to include in their applications.
, D. Use of TID assumptions, or.whatever we end up with, in the design of enginecred safety featu_'es.
On POLS (particularly BiiRs) vce indicate that we are using TlD as a basis and evaluate engineered safety feature capability, whatever it may be. On cps we now try to nahe sure that TID is being used as a basis.
E. Plant security protection requirements.
Currently we n gq '
the ucans propc -
q) p rob, .atse+n e>Ashisectu L5c 'lo.:W:1hudtj"1g f'?
l 8707100280 870623 fS 4.7/4h 7 .
.i R
U) b' i :'-
GQ l3
%./ @ b PDR FDIA THOf4AsB7-40 PDR
.z ,. . ,. ,
8
's .'
llarold L. Prico ,
provida plant security' protection." Vic are developing a l
detailed list of questions in this area.
F. Pipo whipping protection requirements.
Yle generally ascertain that some pipe whip protection is provided, usually related to main recirculation loops.
Tic have no standards in this area. n G. Tornado protection requirements. .
Wo use a 300 + 00 mph tornado with the associated 3 psi in 3 seconds pressure drop. Yle have no standards on general protection of spent fuel storage pools (which includes consideration of both tornadoes and missiles),
or on tornado uissile protection, including containment
- considerations. Vic are working on this in DRL and Dr. Ecch is discussing it with the "Dush subcommittee." .
II . .Scismic design requirements for systems nominally con-sidered Class II or otherwise not Class I.
Ylc limit f ailures of Class II, systems to dose . consequences i of the va]uan of 10 CFll 20. h*c try to assure that failure of a Class II sysicm vil] not impair a C] ass I system.
I. Minimum performance requirements for ECCS (beyond generalities of GDC).
V!c try to ascertain 1 ha t t he ECCS components are suf-ficicut]y redundant and have the capability in the event of a LOCA to (3) Jimit clad temperature to below clad molting point, (2) prevent gross distortion of the core or fraguantation of the clad, and (3) limit metal-water reaction to a value less than 1% of the total Zr in the core. In this assoasment we asriume that only onsite c s
power is available, J. Acceptable criteria for grouted or ungrouted tendons, especially with regard to surveillance requirements. ;
- Using Thrco Mile Is]and Unit 2'as the "procedent" case we toch the position that surveillance (instrumentation) program would be required for the proposed use of grouted tendons. For ungrouted systems we require periodic l tendon removal and inspections. The ACRS did not support this position. Periodic pressure tests will be required. ,
l l
I llarold ' L. price '
l K. Standards on spray additives. -
l We now accept MaOL We do not accept Na2S0 2 3, but.some RT:D work (by BLil) .romains to be reported and wo expect we will accept Na2 S0 2 3 with propor additives. For Ginna, we allowed a dose reduction factor of about 4.5 for their NaOH systcu.
L. n Requirements, if any, for periodic hydro-testing of ^
primary system above operating pressure.
There are no requirements, hnd we have no position, but ~
the question of whether there should be or not comes.up
- about cvory other ACRS meeting.
M. Fish f: Wildlifo Recommendations (Radiological):
To maho the adoption of the Fish f: Wildlife recommendations (subject to AEC cditing) a requirement upon the applicant.
In all cases we have required applicants to adopt the Fish f4 T!ildlife recownendations, as they pertain to radiological]
matters. This is being changed to screen through meaning--
.. ful regulatory review.
N. Environimntal Radiological Monitoring program:
To require the es tabJ ishm?nt and operation of an environ-montal ra di olog ien] moniioring program for a minimum of one year prior to fuel loadin;; and a continua Lion of the pro-gram for life of pinnt. Require the periodic reporting of both t he prooperational and operational survey results. {
We have been requiring the Environmental Radiological]
Monitoring program be started at least one year prior to
~
fuel loading. Continuation of the program for the plant. j life is covered in the Technical Specifications.
O. Meteorological program: c" Require the establishment of an "on site" meteorological program for two years prior to issuance of tho tech specs.
Specify the minimum scopo of such a program and the specific types of data which must be generated for use in dotormining the routine gaseous release limits.
In most casos the onsite meteoro]ogical program is ;
established at least two years prior to operation; however, l we have not established any criteria. We are current]y l handling this on a case-by-case basis. (
/
0 h____. _- _ _ - - _ - - - - - -
j i
Rarold L. Prico P. Foundations, geology and seismic: .
Specify the data required in the PSAR and FSAR relative to the founc'ationF:, geology and seismic aspects of.the plant. Perhaps all of this could be covered by requiring the use of the "Scismic Desip,n Critoria." However, that sti31 might no.t adequately cover the foundation problem.
l This is handled on a case-by-case basis depending upon s i the unusual situations that may be present at a reactor site, particularly with respect to foundations.
Q. Containment Icak rate standards'for both primary.and ~
secondary structures. .
We are applying standard containment leak rate testing procedurcs as por R. Maccary's docutrent on primary containments; however, secondary containments are being based on the capability of the system design.
, R. Leah Rate Criteria for Systems lixterna) to Containment:
, Require that systems mounted externaJ to containment that are required for long-term posL-accident operation be desir,ned for f]uid Icah rates equal to or Jess than a specifi ed st andard, and t hat Jeak measuremen't capability be provided.
We have been attempt j np; to determ.ine what are the leakage rato values for s:ysteus external to cont ainment, but at this time no specific standard has been used.
S. Post-Accident Recovery Operation:
Require that radioactive releaso be limited to a specified amount during post-accident recovery operations. Require that post-accident' recovery plans be developed at the construction permit review stage and include appropriate j monitoring capability and equipment appropriate to tho,
- i. recovery plan.
We have not dealt with the post-accident recovery plans at the construction pernit stage.
r.
T. . Primary System Leak Detection System: i Require that leaks from unidentified sources be limited to allowable maximum rates, allowable times for the maximum rates, and allowable cumulative Jeahago.
Uc are attempting to dcyclop nothods of Icak detection that are acceptahic to the AEC; howcycr, they are so varied that establishing allowable rates is rather difficult.
. j a
Rarold L. Prico U. Primary Sys tcu Irradia tion Surveil]ance Progi'am:
Require an irradiation surveillance program for the primary system coblant boundary that complies with the General Design Criteria, Supplementary Criteria, and
, ASTM Code E-185. Specify a capsule withdrawal schedule. ,
Yle have been applying the ASTM Standard E-185 as a minimum requirement for the 11adiation Surveillance Program. Ylith drawal schedules have not been developed. 1 V. Primary System In-Service Inspection:
- Require an in-service inspection program that complies with the standard drafted by the N-45 Committee and '
applicable regulatory supplomontary-critoria.
V/c'have been requiring that an in-scrvice inspection prograrc based on the Draf t N-45 document be concidered by ,
cach construction permit applicant. Yle have not directly required the N-45 criteria.
VI . pump Flywhccis . Primary SysLem:
Require that flywheel deslgns incorporate conservative margins tha t preclude brenhup of the flywheel.
Additionally, require that energy absorbing barriors be provided jf an evaluation of the f]ywheel breakup r.csults in events having consequences in excess of the DBA.
At this time no specific missile shielding fol' flywhools has been required of a reactor plant. Yie havo reviewed the design to establish margins that exist and have required certain inspection requirements for the flywhcols.
X. Class I Structures and Systetiis:
Require that all Class I structures be c]carly identified.
Also, require that all interaction with structures, systems and system extensions other than Class I be '
c identified and that derionstration be provided that thoso interactions, even with failure of non-Class I structures and systems, do not impair the functions of the Class I
, structurcs and systems.
Yle have been attempting to get a complete listing of all Class I structures in applications; however, we have not been successful at this time. Yle have been just recently concerning ourselves with the failure of other non-Class I systems and their effect on Class I structures and systems. .
i a
l ________._____i___._______u
Harold L. Prico -G- '
i Class I Jn-Scryico Inspection:
l Y. .
I Require an in-service inspection program that follows the intent of the N-45 Committoc Draft Standard for Cla~ss I mechanical system's, including vessel supports pipo hangers, penetrations, primary pump flywheels, and similar adjunct critical items.
Should be included in V. '
Z. I.cah Detection - Emergcn cy Safety Features:
Require that Emergency Safety Features be designed such that leak detection is feasible at system operating pressures and require periodic performance of leak detection procedures.
In low pressure systems, such as containment spray systems, tests may bc ]imited to periodic flow checks.
Lenk detection proceduros for emergency safety features should be equiva]cnt or better than those required under Item T. These loah detection features have not generally been required.
AA. Class I Scismic Qualifications:
- - Require certifiention that C] ass I mechanical compononis have beco 'demonst ra ted to perform spceified functions during and af ter be:ing subjec ted t o devic;n basis scismic forces.
Whercycr possib]e, t he demonstrations shall include tests, e.g., shaho t a bl e , in which the Maximum accc3cration and the frequency sinetruri conoistent wit h founda tion and mountj ug provisions are s:Imulated.
We have required certi fication tha t certain Class I mechanical components can withstand the design basis (
scismje forces. We, have not, however, tahon into account all systems, such as piping. )
1 I
DD. Controls Scismic Qualification: e l Require certification of reactor and engineered safety' -
feature control systems and components on the same basis as certification of Class I mechanical components when subjected to design basis scismic forces, w
Currently we only ash a question or two in this area. I CC. Flow Induced Primary Systen Vj brations:
Requirements for measurement and analysis of vibration of the primary system, supporting structures, and contained components subject to flow induced forces fo,r normal operation, including startup and shutdown, and for accident conditions for all times during the faciIity l ife t ime , including operation of ECCS. l G
4 9
Harold L.>Prico At the construction permit stage we have not required vibration measurement or analysis critoria cicept in arcas where review of the proposed design is extremo1y questionabic. Vibration measurements have been required on recent POL cases but not for "all times during the
- facility lifetimo," nor in a very systematic way. The ACRS stressed the importance of this subject at its July meeting.
r DD. Shear in Reinforced Poncrete and Prestressed Concrete Structurcs: .
Requirements for protecting against shear in reinforced
- concroio and prestressed concrete structures. ,
In most cases the consideration of the shcar in reinforced concrete structures has been reviewed in detail on a case basis and in some cases has required changes of design.
EE. Grouted. Tendons in Class I Structures:
Requirements for the uso and survei.11ance of grouted tendons in prestressed concrete Class I structurcs.
Samo as J.
FF. Containment Design Detail:
Requirements of containment den.ign report that describes the design of the whole containment boundary in such de tail as is necessary for a safety evaluation, including bellows, gaskets, sea l e rs , etc.
This is now handled by questions. A requirement that a containment design report he filed at the construction permit stage of review would substantially reduce the numbar of questions being ashed in this area.
GG. End-of-life Conditions for C] ass I Structures:
Design requirements for all Class I structures and systems' (especially containment) for normal operating conditions, accident conditions, and shutdown and startup conditions near the end of life of the plant.
Samo as FF.
HH. Deviations from Codes and Standards:
Requirements for deviations from existing codes, standards and regulations.
In some areas that are obvious where deviati,ons from existirc codes, standards, and regulations ar; noted by' an , applicant, v.c review them and accept or reject; however, this is not r.n all inclusive review, 9
I i l
i
- i ;
Harold L. Price {
II. Class I Design Information:
Requircinents for information on the final design of all Class I structures, equipment, piping and other systems, including, for ex'a mple , the actual critical stresses and
, strains for the most unfavorable load combinations and the corresponding allowable stresses and strains, the location of the critical sections, and the. earthquake accelera-tion for which they are designed. ,
3 We have obtained information on the final design of Class 1 structures, etc., a t the operating liccuse stage on a case-by-caso basis. This c]carly doesn't cover each and eVery Component.
JJ. Code Changes During Countruction:
Requirements, if essentjal parts of a code are changed
' or new codes jntroduced during construction, for an
, evaluation of the impac t on safety of the plant.
This is now handled only on a case-by-case basis, if ChangUS become known.
KK, Built-up St oel Frames Dahedded in Concrete:
Rcquiro that principal load -carry.i ng hui] t-tip steel framos cinbedded in concreto containment walls be designed, f abricat ed and inspected in accordance with the AGlE Boi]er & Prensuro Vessel Code, Sec(ion III.
This is now handled on a case-by -ense basis.
LL. Tornado Model:
Require thal the nuclear facility be designed to sustain load.ings renultjng from a tornado characterized by a 300 mph rotntiona] voloeity, GO mph transnational velocity, and a 3 psi pressure drop in 3 seconds. Require that all Class 1 structures and systems he. designed to maintain, their designed capabi]ity under these conditions and ,
incl uding tornado induced missiles.
See proposed rule G.
M.',i . Spent Fuel. Storage Pool:
Require that protection be provided to prevent loss of water from the spent fuel storago pool, loss of cooling water, and damage to fuel rods under conditions associated with the tornado model for the facility.
\
Soc proposed rule G. '
e
- _ ____. _ . _ _ _ _ _ _. _ _ - - _ - - - - - - - - - - - - - - - - - - - - - - - - - - " - - - - ' ' - ^ - ' - - ~ ~ - - - -
Harold L. Price ,
NN. Strong-Motion Seismographs:
Requirements for installation of strong-moticui scismo-graphs at or near each nuc] car facility to aid in evaluating carthqpake effects and peak accelerometers or equivalent on critical equipment. '
e We are currently requiring at least one strong-motion seismograph be installed at cach reactor facility; however, it is believed that more than one may bc necessary, and that other equipment may also be required. ~1 , ,
- 00. User Testing of Reinforcing Bars:
- Requirements for user test of reinforcing bars, e.g., for each heat roccived that is ] css than 50 tons and for cach 50 tons in larger heats. '
The current practice is to review testing requirements for each case; some app]icants follow the proposed rule, some
. do not.
PP. Deviation from Conventional] Practice in Design and Fabrication:
Requirements for adequat e and comprehensive description
,' and evaluation of deviation from conventional practica in the design and imbrication of sysicus and components, i Samo as Hil.
QQ. Design of Prolention Systeun in Acadrdance with IEEE 279 In most all casos we are requiring the design of pro--
tcction systens to be in accordance with IEEE-279 This in itself is not real]y adequatc; a now standard, critorion, or rule is needed.
RR. Emergency Electrical Systems Design Requirements, s a Ylc -are using as a guide the document pubidshed by DRS concerning this subject.
w SS. Fuel Supply Requirements for Emergency Generators, Fuel supply requirements for emergency generators are established on a case-by-case basis, usually based on a minimum of .a 7-day storage capability; however, in some cases a variation of this is permitted provided it can shown that fuel is promptly availabic to the site under all emergency conditions. ,
i
\
I
__________ l
l
,e
, f .
Harold L. Price
- TT. Hoquironients for Design o'f Diverse Actuation. Signals for ECCS:
Require that signals be provided for actuation of Emergency Coro Cooling Syst' ems from at least two variables, either of
,which is capable of actuating the ECCS. Require that the design shall be such that instrumentation monitoring each
-variable meet the requirements of IEEE 279 We are currently requiring that at Icast two diverse signa.l,s be used for initiation of the emergency coro cooling systems
.and that they be designed to IEEE 279.
UU. Provisions in regulations and procedures specifically '
designed for critical facilitics and low power research reactors should be deveJoped rather than attempting to fit these fac.ilitics to regulations developed for power reactors. Consideration should be given to licensing an entire critical facility rather than as individual critical assemblics and to use of a toch spec format different from that for power reactors.
Now complying with current rules and practice.
VV. Provi do defi n iii ons of "cri tical experiment 'fhcili ty,"
"readily ava i1a ble on en1) ," "research reactor," "present '
at the facility" and "at the controls" should be included.
Ndw handle in tech sjwes.
WW. Part 50 should specify all of t he standard reporting requirements that are now being incorporated in cach licence and/or in Technical Specifications. Parts 20, 50, and 70 should he amended to climinate inconsistencies and overlap.. '
Reporting requircents are now handled on ad hoc basis e in Techn.i cal Specifica ti ons. '
XX. Section 50.34 should be amended to provide more detail
, on requirements for emergency planning in the application.
s .
Now handled ad hoc.
YY. Section 50.3G should be amended to al]ow us the flexibility of placing safety limits on variables other than process .
Variables and for purposes other than protecting the l integrity of physical barriers.
Now handled ad hoc. f
,. ~ -
8 4
\ s: *.)
1 Haro.id 1,. Prico ,
ZZ. Section 50.51(n) should be doloted since we do not require
' or issue a CP for alterations to a facility constituting a chango in the Technical Specifications. Section 50.91 !
, adequately coversswhen a CP is needed for alterations to a facility.
No comment.
a .
AAA. Section 50.59(c) should be amended to spell out when an amendment to the license, as well as a change to the Technical Specifications, is necessary for any proposed chango that " presents significant hazards conside' rations not described or implicit in the safety analysis repo't" r (and presumably also a 15- or 30-day notice before issuance l of such an anonduant). In thin regard, Part 2 should be amended to reficct the 30-day notice required by the ACT for amendments to licenses for power and testing reactors when such amendu.ents involve "significant hazards considerations". !
Part 2 now only spnahs of the 15-day notice. Alternatively, the Act should be amended to reduce the notico period.
We are also having difficulty in setting forth procedures for handling information filed by construction permit s holders that might describe a change that " presents signifienn! hnzord cons.iderations." Therefore considera-tions should be given to incorporate' construction permit i
i changes in this proposed rule, j
(
BDD. It should be spe))ed out in part 50 that any time any ]
material (byproduct, SN:.1 or source) bc]d under another j license is to be u..ed or stored in a location that may 1 affcet the rea ci or, then the potentia] hazards should bc l analyzed and the facility license should be amended to l authorize such activity, i No comment, a
)
l CCC. Section 50.7.l(b) should be amended to show that we need i 10 copics of the annual financial reports rather than "a copy" as it now states. )
'~
The licensing assistants curren'tly prepare letters <
requesting additional copies of each applicant's annual report. 4 DDD. Provisions for comprehensive periodic review should be included. '
O D E is worhing on "10 year review" plan.
l
, l f
(' )
liarold L. Prico '
EEE. Changes should be made that arc described in the staff paper containing proposed amendments to Part'55 tha.t has been under revicw since 1907
~No comment.
FFF. After sufficient experJence on an interim basis has been !
obtained, Part 55 should be revised to reflect credit .s' i
given for simulator training contors in lieu of actual reactor operations, !
i No comment. , -
l
- f. r;!
Ii'.jx _ _ ,/
' P.' A. Morris, Director !
Division of Reactor Licensing cc: C. K. Ucch, DR M. M. Hann, DR R. L. Doan, DR C. L. 11en de rson , DR E. G. Case, RS
- H. K. Shapar, OCC
- L. D. Low, CO J. A. McBrido, ML
.. \
g 4 I
w 5 I
l
. l
/
e
_ _ _ . _ _ _ _ _