ML20245C202
| ML20245C202 | |
| Person / Time | |
|---|---|
| Issue date: | 06/23/1987 |
| From: | Jordan E Committee To Review Generic Requirements |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20245A520 | List:
|
| References | |
| REF-GTECI-A-44, REF-GTECI-EL, TASK-A-44, TASK-OR NUDOCS 8707090460 | |
| Download: ML20245C202 (58) | |
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June 23, 1987 L
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fiELEASED m y
&cY p&
e MEMORANDUM FOR:
Victor Stello, Jr.
Executive Director for Operytions FROM:
' Edward L. Jordan, Chairman Committee to Review Generic Requirements
SUBJECT:
MINUTES OF CRGR MEETING NUMBE 115 1
l The Committee to Review Generic Requirements (CRGR) met on Wednesday, May 27, j
1987, from 1-5 S m.
A list of attendees for thi The following items were address,s meeting is enclosed (Enclosure 1).
ed at the meeting:
1.
W. Minners (RES), P. Baranowsky (NRR), and A. Rubin (RES) presented for 1
CRGR review the proposed final rule and regulatory guide resolving USI l
A-44, " Station Blackout." The CRGR recommended EDO approval for transmittal to the Commission, subject to some changes in the documents that would be coordinated with the CRGR staff prior to transmittal to the EDO.
The CRGR also recommended that the rule not be implemented until certain additional implementation guidance for the staff is prepared and reviewed by the CRGR.
Further, the CRGR recommended that the staff's proposed implementation schedule should be shortened.
This matter is discussed in Enclosure 2.
2.
The proposed final rule amendments to 10 CFR Parts 30, 40, 50, 51, 70, and 72 concerning general requirements for decommissioning nuclear facilities, which were scheduled for review, were not reviewed at this meeting.
The review was postponed until the next scheduled CRGR meeting.
3.
G. Arlotto (RES) and G. Millman (RES) presented for CRGR review the proposed rule amendments to 10 CFR 50.55a, " Codes and Standards." The CRGR recommended that the ED0 approve issuance of the proposed amendments for public comment.
This matter is discussed in Enclosure 3.
In accordance with the ED0's July 18, 1983 directive concerning " Feedback and Closure on CRGR Reviews," a written response is required from the cognizant office to report agreement or disagreement with CRGR recommendations in these minutes.
The response, which is required within five working days after receipt of these meeting minutes, is to be forwarded to the CRGR Chairman and if there is disagreement with the CRGR recommendations, to the EDO for decisionmaking.
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l Questions concerning these meeting minytes should be referred to Tom Cox (492-4148).
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original 518 3 gg E. D k ilan Edward L. Jordan, Chairman Committee to Review Generic Requirements
Enclosures:
As stated
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cc: Commission (5)
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SECY Office Directors Regional Administrators CRGR Members W. Parler B. Sheron G. Arlotto Distribution: w/o enc 1.
Central File PDR(NRC/CRGR)
J. Clifford S. Treby W. Little M. Lessar J. Zerbe CRGRStaff(w/ enc.)
CRGRCF(w/ enc.)
CRGR Meeting File (w/ enc.)
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OFFICIAL RECORD COPY
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Mi LIST 0F ATTENDEES I
CRGR MEETING NO. 115 l'
.May 27, 1987 CRGR MEMBERS E. Jordan
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R. Bernero
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T. Martin
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J. Scinto T. Speis l
J. Sniezek OTHERS J. Zerbe T. Cox J. Conran A. Rubin P. Baranowsky K. Kniel B. Colmar D.-Jones A..Serkiz M. El-Zeftawy i
J. Flack J. Larkins M. Federline J. Austin M. Taylor J. Clifford R. Fonner P. Norian M. Malsch W. Minners R. Bosnak S. Treby G. Millman G. Arlotto T.-Dorian
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1 i to the Minutes of CRGR Meeting No. 115 Proposed Final Resolution for USI A-44, "St,ation Blackout" May 27, 1987 4,
TOPIC 1
W. Minners (RES), P. Baranowsky (RES), and A. Rubin (RES) presented for CRGR review the proposed final resolution for Unresolved Safety Issue (USI) A-44,
" Station Blackout." The proposed resolution calls for amendments to 10CFR50 (including an addition to GDC-17) and issuance of an associated Reg. Guide which would require that licensees and applicants:
(a)assessthevulnerability of their plants to blackout (i.e. simultaneous loss'of offsite AC power and unavailability of onsite AC power), and (b) demonstrate the capability of their plants to cope with the effects of blackouts of specified duration if they occur.
Copies of briefing slides used by the staff to guide their pre-
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sentations and discussions with the Committee at this meeting are attached to this Enclosure.
BACKGROUND The proposed resolution for USI A-44 was reviewed by CRGR earlier, at the draft stage, in Meeting Nos. 59, 61, and 60; the complete account of that earlier review and the resulting recommendations of the Committee are docu-mented in the minutes of Meeting No. 60 dated May 8, 1984.
The current pack-age submitted for review by CRGR at this final stage was transmitted by memo-randum dated April 6,1987, H. R. Denton to J. E. Zerbe; the current package included the following review documents:
- 1.
Proposed Federal Register Notice, dated March 30, 1987, (Response to public comments, proposed rule amendments, backfit analysis)
- 2.
Regulatory Guide, dated March 30, 1987, " Station Blackout"
- 3.
NUREG-1109, undated, " Regulatory /Backfit Analysis for the Resolution of Unresolved Safety Issue USI A-44, Station Blackout"
- 4.
NUREG-1032, undated, " Evaluation of Station Blackout Accidents at Nuclear Power Plants"
- 5.
"Significant Changes to the USI A-44 Package,"
- undated (circa March / April 1987)
The Commission received 53 letters commenting on the draft resolution package reviewed earlier by CRGR; those comments are summarized and responded to by the staff in the proposed Federal Register Notice (FRN) included in the cur-rent review package (Background Item 1 above).
One of the public comment letters, from the Nuclear Utility Management and Resources Committee (NUMARC),
put forward as a possible alternative to the staff's proposed resolution for USI A-44 four initiatives designed to address the more important contributors
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' to blackout.
Those initiatives were enqorsed broadly by the utilities cur-rently operating nuclear power plants, And they have been pursued actively by the utilities in parallel with the staff s work on this issue over the last couple of years.
The NUMARC initiatives are included as one of the five possible alternative courses of actioh examined by the staff in regulatory and backfitanalysesdoneinconnectionwjthUSIA-44;thoseanalysesaresum-marized and documented in NUREG-1109 (Background Item 3 above).
A method acceptable to the NRC staff for licensees to determine plant-specific blackout coping durations for their facilities is provided in the proposed Reg. Guide (Background Item 2 above) included in the.urrent review package.
Technical studies funded by NRC to examine the most important parameters of the station blackout issue (i.e., frequency of loss-'of offsite power; probability that onsite AC will fail to provide power for core cooling; capability and reli-ability of shutdown cooling systems during prolonged blackout; ability of containment to withstand pressure / temperature buildup during prolonged black-out; and probability of occurrence of blackout accident sequences) are sum-marized in NUREG-1032 (Background Item 4 above).
Significant changes made to the USI A-44 package since the Committee's earlier review at the draft stage are summarized in Background Item 5.
Briefly, the staff's proposed resolution for USI A-44 includes:
(a) amendments to 10CFR50 and Appendix A to Part 50 (General Design Criteria), which would require that all nuclear power plants be able to cope with a station blac,..
for a specified du,'ation and have procedures and training for such an evetA, and (b) issuance of a supporting Regulatory Guide which would provide an ac-ceptable method for determining the station blackout duration for each plant.
The staff's analyses indicate that an improvement of about 2.6E-5 in the fre-quency/ reactor year of core damage events will be realized by implementing the proposed A-44 fix (decreasing from about 4.2E-5 before fix to 1.6E-5 after fix).
This corresponds to a best-estimate total averted risk benefit of about 145K person-rem for a population of 100 reactors over their remaining lifetime (about 30 years average).
The cost nf implementing the proposed fix is esti-mated by the staff to be about $600K per plant, for a total cost to the in-dustry of about $60M (i.e., 60 million dollars). The benefit / cost ratio for the proposed action, then, is 2400 person-rem /$M (or about $420/ person-rem, compared with $1000/ person-rem commonly used as the breakeven guideline).
DISCUSSION Major points of discussion at this meeting regarding the proposed resolution for USI A-44 were as follows:
1.
A major change in the A-44 package from the draft stage to the current version is that licensees would no longer be required to determine the maximum duration that their plants could cope with blackout conditions.
Instead, licensees would determine, by applying the screening /categoriza-tion guidance in the proposed Station Blackout Reg. Guide, a specified coping duration (i.e., 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />) appropriate for e6ch facility.
They would then be required to demonstrate by further analyses that each plant could actually cope with blackout conditions for that specified duration.
The staff did not, however, include in the re-vised package the proposed acceptance criteria / guidance (e.g. SRPs) that would be used by staff reviewers for judging the acceptability of the
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coping analyses to be pubmitted by the licensees under the proposed re-solution, or the inspe'ction guidance (e.g., tis) that would be applied by NRC inspectors in determining ultimately licensees' conformance to the proposed rule.
In the absence of such criteria, the Committee felt that theproposedcopingldemonstrationrequirementismuchtooopen-ended,and that the staff's es i
about$250K/ plant)f.imateofcosttoimplementtheproposedfix(i.e.,
1s not verifiable.
In this context, it was noted that the actual cost of analyses done by the St. Lucie 2 applicant to demon-I strate a 4-hour blackout coping capability (after Station Blackout was l
made a design basis event by the Licensing Board for that facility) was j
said by NUGSB0 to be in the neighborhood of about $2 million.
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The staff stated that'they had no detailed knowledge of actual costs in-curred in that instance.
They were, however, generally aware of the cir-l cumstances involved; and they said that the extensive analyses done by the licensee in that case (which included even some thermodynamic analy-ses) were done in the process of demonstrating the 4-hour coping duration specified by the Board.
Extensive analyses were apparently done by the licensee in a futile attempt to avoid having to make significant physical l
modifications to the plant.
The staff felt strongly that those circum-
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stances were not representative for the remaining plants that would be i
affected by this proposed blackout rule; and they stated categorically that the coping analyses envisioned in connection with the currently pro-posed USI A-44 resolution were not intended to be as extensive as those done by the St. Lucie applicant.
After much discussion, the Committee concluded that the A-44 package did not have to be held up from goin this point; but they recommended'q forward because of their concerns on that both the acceptance criteria and guidance to be used by staff reviewers (i.e., SRPs), and the guidance to be used by NRC inspectors (i.e., tis) in implementing the new rule, should be reviewed by the CRGR prior to implementation of any station blackout rule that is finally approved.
The staff agreed with this re-commendation; RES and NRR will cooperate in this effort, and will under-I take immediately the expeditious development of the acceptance criteria and review / inspection guidance needed by staff reviewers and inspectors.
The Commission currently is not scheduled to consider this matter until late summer or early fall of this yeer; it was felt, therefore, that there is a good chance that the recommended criteria / guidance could be avail-able at the time the Commission gives final consideration to the proposed resolution package.
2.
The credit to be given to " alternate" AC sources for coping with blackout wasanothermajorareaofdiscussionatthismeeting.
This had been a major point of comment by NUMARC in putting forward their initiatives as an alternative to the staff's approach for resolving A-44.
The staff is j
willing to credit such AC sources for coping purposes; but they have had I
some difficulty in specifying detailed acceptance criteria, i.e., what I
degree of independence, diversity, reliability, etc. is required for such AC sources to qualify as adequate for coping.
Although they have not fully developed their thinking in this regard, the staff indicated in these discussions, that a " swing" diesel generator configuration would not qualify as an alternate AC source adequate for coping with blackout, i
' I because of its bck of independence from the normal safety-related AC sys-l tems and J ts common-mode failure potential.
Generally, however, if an al-ternate. source can bc shown to be reliable, independent, and available 1
withins 0minutesorsooftheonsetofblackout,thestaffwillcreditit l
1 fully. IThe staff stated that such a plant would, in effect, fall into the so-calfed "zero hour" category that was the subject of much discussion with CRGR af the draft review stage.
That is to say, a fully credited alter-nate AC capability will be considered to be adequate demonstration of the l
required blackout coping capability for a plant, without the need for any
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additional coping analyses.
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3.
In discus ing the utilities' reluctance to accept the proposed coping analysis' requirement (as indicated above in Discussion Item 1)i the staff offered the view that a major concern underlyir,ig the utilities opposi-tion on.this point was that the staff might raise such extensive equip-ment operability questions in the review of such analyses as to effec-tively reopen the EQ issue. With respect to such concerns, the staff stated that, if the blackout coping capability claimed by a licensee relies on use of eguipment that previously did not require any sort of environmental qualification, then its availability and operability in the blackout context would have to be reasonably established / demonstrated.
This could be done by providing an evaluation of equipment character-istics and specifications vs. anticipated environmental conditions and equipment loads that could result from blackout, and by providing for administrative controls to reasonably assure availability of equipment designated to be relied on in coping with blackout.
The staff felt that the licensees' concerns regarding the likelihood of extensive environ-mental qualification effort being required in connection with blackout were misplaced.
The CRGR staff noted that, in recent discussions with NUGSB0 representa-tives on this point, the concern expressed was that the extensive coping analyses required under the staff's proposal would not actually fix any equipment or procedural deficiency that contributed to station blackout potential.
The emphasis in the NUMARC initiatives was on physical equip-ment and procedural improvements that would directly address blackout concerns; they felt that this represented the most effective and cost beneficial expenditure of resources in addressing the blackout issue.
With respect to demonstration of blackout coping capability, the utili-ties felt that staff's criteria for determining what was adequate in that regard (i.c., detailed analyses) were too stringent, and more like what is normally required to demonstrate adequacy of equipment / procedures judged necessary to assure public health and safety.
The staff has not claimed that any of the proposed USI A-44 fixes are necessary to assure safety; they have only said that such fixes provide significant improvement to safety in a cost beneficial manner.
In view of the relative importance (thus indicated) of A-44 fixes in general, the utilities believe that adequate demonstration of 2-hour, 4-hour, etc. coping capability should be provided by simply meeting the criteria specified by the staff in the proposed Station Blackout Reg. Guide for determining that a plant is a 2-hour plant, or a 4-hour plant, etc.
The Committee agreed generally with the view that analyses in themselves do not fix equipment or procedural deficiencies that result in vulnerability to blackout.
The staff
, reiterated strongly, however, that the analyses specified are required to
/, provide a high level of assurance that a given plant has the capability to cope with blackout conditions for the duration specified for that facility.
The Committee asked whether the staff had considered allowing i
utilities to take credit for demonstrating operability of such equipment l
by actual testing under simulated blackout conditions during a plant out-age.
The staff responded that they would consider licensee proposals to demonstrate operability in that manner, and would revise the wording of the FRN to indicate this; but they.would not require (or even necessarily encourage) that approach.
I As a final point in regard to equipment operability and reliability, and their relationship to the overall demonstration of required coping cap-ability, the Comnittee noted that, although the staff had stated expli-citly at least once in the A-44 package that it was not intended that any equipment relied on for blackout coping must be safety grade, or that full scope Appendix B QA requirements must be applied to such equipment (e.g.,
see proposed FRN, at p. 12, last paragraph), the wording of the package in other places was such as to suggest that comparably detailed and stringent QA requirements might apply to such equipment.
For example, the proposed FRN (at p.12, second to last paragraph) states that:
"...the equipment must meet certain quality assurance criteria to ensure a high level of reliability and operability during station blackout events."
The Committee commented that, because the objective of proposed rule is to further reduce risk in a cost beneficial manner (not to achieve an accept-able level of risk where reasonable assurance of that is currently lack-ing), they agreed with the staff approach of not requiring equipment re-lied on for coping with blackout to be safety grade.
In this context, the Committee recommended that the staff clarify their intent with regard to intended safety classification of, and QA requirements for, such equip-mentbyrevisingthewordingofthepackageinthespecificparagraphs noted, to identify explicitly and unambiguously the certain QA criteria" that the staff is referring to there.
The Committee also suggested that the remainder of the package be carefully reviewed for similar potentially confusing wording, and be revised as necessary to avoid possible confus-ion on this important point.
The staff agreed that the wording cited was p'certain" y confusing and should be changed (e.g., by deleting the word otentiall in the specific passage cited, and by indicating more clearly that the level of treatment given to quality in the Station Blackout Reg.
Guide and in draft ANS Standard 58.12 is representative of what is expec-ted by the staff for equipment relied on for coping with blackout).
The staff will also review other pertinent sections of the A-44 package for other such inconsistencies or ambiguities.
4.
With regard to the proposed requirement specifying that the Director, NRR, must make a determination of the specified station blackout duration for each affected operating plant (see proposed FRN, p. 45, third paragraph),
the Committee asked what standard is to be used by the Director in making that determination.
The staff responded that the operable standards are set forth in the proposed Station Blackout Reg. Guide in the guidance for categorizing existing plants (i.e., as 2-hour, 4-hour, 8-hour or 16-hour
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, plants).
Beyond those explicit deterministic standards, there is also the
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probabilistic core damage frequency objective of about 10E-5 which under-lies the staff's overall approach to resolution of this issue, as reflect-ed in NUREG-1032 and NUREG-1109.
The Committee agreed that either or both i
of these would be acceptable for use as the standard to be used for making the required determination; but they also stated that the intended stan-dard(s) must be incorporated explicitly into the rule that requires such a determination to be made.
The staff agreed to modify the wording of the l
package to reflect this recommendation.
l 5.
The Committee questioned the staff regarding the proposed implementation schedule (see proposed FRN, p. 45, last two paragraphs).
They noted that
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a stated objective of the NUMARC initiatives is to upgrade all 8-hour plants into the 4-hour category within one year; while under the staff's proposed resolution the upgrading of affected plants could drag on into the 1990's.
The Committee recommended that NRR work out a more expedi-tious implementation schedule for their proposed resolution, consistent with the general objective of reducing schedules for high priority generic actions.
6.
The Committee asked the staff to reaffirm that the wording in the next-to-last paragraph of the transmittal letter for this review package, and the wording in the proposed FRN (at p. 50, first paragraph), was intended to satisfy the requirement in 10CFR50.109 for an explicit finding by the Director, NRR that a proposed backfit will provide a substantial increase in the overall protection of the public health and safety, and is justi-fied in view of the direct and indirect costs of implementing the back-fit.
It was noted that the referenced wording actually states that the results of the staff's analyses in NUREG-1032 and NUREG-1109 support such a determination, but do not state explicitly that that is the Director's determination.
The staff agreed to verify that it was The (former)
Director's intent to make the required finding when the review package was transmitted to CRGR, and to revise the wording of the package to more clearly reflect that intent.
7.
The Committee asked if the staff had concluded on the basis of actual analyses that it is safer to shutdown a plant in the event of imminent severe weather (e.g., hurricane, tornado, blizzard, etc.) and rely on diesel generators and/or offsite power sources for power to maintain safe shutdown conditions, as strongly suggested by the staff's treatment of severe weather procedures in the A-44 context.
It was suggested in this context, in view of the problems that have been experienced with DG reli-ability and the expectation that offsite power is likely to fail in the event of very severe weather, that it might be prudent to keep reactors critical but operating at reduced power levels in such circumstances.
The staff responded that they had not done detailed comparative risk analyses on this question. Where such shutdown procedures exist, or in specific instances where shutdown actions have been taken in imminent severe wea-ther situations (e.g., during a hurricane last year), those procedures /
actions have been the result of licensees' evaluations of specific situa-tions and alternatives, with the staff only deferring to or not objecting specifically to the licensees' judgment.
It was agreed that it should not
. be assumed automatically that shutdown of the reactor and reliance on DG power is the preferred course of action in all severe weather situations, but that this question should be examined on a case basis; and this approach will be taken in implementing any approved resolution for USI A-44.
8.
The Committee inquired where in the rule is the concept of " alternate AC" sources addressed.
Specifically, where is the basis for the staff accept-ing a qualified alternate AC source as demonstration of adequate blackout capability in lieu of the requirement for analyses to demonstrate the ability of a plant to cope for the specified duration (as indicated in Discussion Item 2 above).
The staff responded that an interpretation of factors (1) and (2) of the four factors mentioned in the new proposed sec-tion (e) of GDC-17 (see proposed FRN, at p. 47) might be considered the basis for doing so.
The Committee recommended that both the concept of
" alternate AC," and the provision for waiving the requirement for analy-ses to demonstrate coping capability for the specified duration if a fully qualified alternate AC source is provided, should be included explicitly in the proposed rule.
(For alternate AC sources, as well as other black-out coping equipment, " fully qualified" does not mean that the equipment must meet safety grade, Seismic I, Appendix B QA requirements, etc.) The staff agreed to work out with OGC the appropriate wording changes needed to incorporate this recommendation by the Committee.
9.
After much discussion of the proposed A-44 resolution with the staff, the Committee agreed that it appeared that, to the extent that the staff's cost estimates are accurate and can be actually realized in practice, the costs involved in implementing the proposed resolution are justified. A major qualitative factor in the Committee's conclusion in this regard was the observation that the AC electrical systems affect so pervasively plant operations.
There is a high likelihood, therefore, that significant improvement in AC systems reliability and independence will provide a sig-nificant improvement in safety.
Assuming the proposed resolution for A-44 is approved and implemented as expected, the Committee inquired about the prospect of any further cost beneficial fixes being imposed under USI A-45.
The staff responded that, in view of the small residual risk levels remaining after implementation of the proposed resolution for A-44 and other generic fixes imposed over the last few years, and in further view of the projected cost of the type of fixes that have been most seriously considered in working that issue, it is not clear at this time that the staff can propose further cost beneficial fixes under USI A-45.
10.
The Committee felt that the wording of the last paragraph on p. 36-37 of the proposed FRN is too negative with regard to the potential ~ role and contribution of probabilistic analyses in better understanding the black-out issue, and with regard to the use of reliability goals in resolving important generic problems such as USI A-44.
They recommended that this wording be modified to reflect a more balanced agency view in this regard prior to issuance of the proposed resolution package.
The staff agreed to work with OGC in doing so.
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11.
The Committee noted that the proposed Station Blackout Reg. Guide pro-vides for 2-hour, 4-hour,.8-hour and 16-hour categories of operating plants; but the FRN refers only to 4-hour and 8-hour plants.
They recom-mended that the wording of the proposed FRN (e.g., at pp. 23, 26 and 28) be revised so that the wording of the proposed resolution package is consistent throughout.
The staff agreed to do so.
12.
With reference to the wording of the last sentence of the second para-graph on p. 14 of the proposed FRN, the Committee asked if the staff were sure that no exemptions to GDC-17 had been approved by the Commission for any operating plant, as suggested by the wording of that sentence.
The staff agreed to check this point specifically, and will adjust the word-ing of the sentence in question, if necessary, to reflect GDC-17 exemp-tion status accurately.
13.
The Committee noted that 0GC has not formally concurred in the A-44 pack-age at this point; in accordance with the CRGR charter, this must be done prior to final approval and issuance of the proposed package.
14.
In addition to the recommendations made in the preceding regarding a num-ber of general kinds of changes that should be made to the proposed resolu-tion package in various topical areas, the Committee recommended also the following revisions to the wording of specific sections of the documents provided to CRGR for review:
_ Federal Register Notice, at p. 12, last sentence.
Change to read as a.
follows:
"However, the equipment must meet the quality assurance criteria needed to establish an appropriate level of reliability and operability during station blackout events."
(See also Discussion Item 3 for indication of additional non-specific wording changes needed to this section of the FRN.)
b.
Federal Register Notice, at p. 36, next-to-last and last paragraphs.
Change to read as follows:
"...However, the Commission recognizes that there may be potential drawbacks from relying on this approach on an industry-wide basis for the reasons given below.
One detrimental aspect...is that it might lead to over-emphasis on efforts to assess the adequacy of the analysis, rather than concentrating on adequacy of the design.
There can be too strong an emphasis on fine tuning the model...to achieve results directed mainly toward meeting a numerical criterion... 0n balance, in implementing... goals...."
(See Discussion Item 11 above, for context of this recommendation.)
., c.
Federal Register Notice, at p. 44, under "(b)
LimitationofScoppl,"
Change the ending of the sentence to read as follows:
if the capability to withstand blackout was speci-fically addressed in the operating license proceeding ant was explicitly approved by the NRC."
i (Alternatively, consider simply stating that these new requirements do not apply to the St. Lucie plant, if that is what is really in-tended by the wording of this section.)
d.
Federal Register Notice, at p. 45, last paragraph.
Change to read as follows:
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"A final schedule for implementing modifications...shall be developed by the NRC staff in consultation and coordi-nation with the licensee."
(See Discussion Item 5 above for context of this recommendation.)
e.
Proposed Station Blackout Reg. Guide, at p. 6 and p. 11 (Footnote).
Revise the wording referring to " plant specific technical guide-lines" to clarify that this actually means Emergency Operating Procedures for the plants.
f.
Proposed Station Blackout Reg. Guide, at p. 8.
Clarify to indicate that references to " full power" mean that the reactor has operated long enough at 100% power to reach equilibrium Xenon conditions.
RECOMMENDATIONS TO THE EDO On the basis of their overall review of this matter, including the presenta-tions and discussions at this meeting, the CRGR recommended to the ED0 that the proposed resolution for USI A-44 be approved for implementation, subject to a number of revisions recommended by the Committee, in particular the following:
1.
The staff should resolve wording issues in several topical areas, and make specific revisions in several sections of the documer,ts in the package, as indicated in the preceding Discussion Items.
2.
The staff should develop, and submit for review by CRGR, the acceptance criteria and review / inspection guidance documents (i.e., SRPs and tis) to be used by NRC reviewers and inspectors prior to implementing any action finally approved for resolving USI A-44, as discussed in the pre-ceding Discussions Items.
3.
The staff should address explicit'ly in the body of the proposed rule the
" alternate AC source" concept, and also make clear in the rule itself that a fully qualified alternate AC source will be accepted as demonstration of adew ate blackout coping capability in lieu of extensive analyses othersise required by the proposed rule.
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4.
The staff'should. develop in coordination with affected licensees more expeditious schedules for overall implementation of the rkoposed resolu-tion than are indicated in the current package.
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INTRODUCTION
/l CRGR RECOMMENDED ISSUING PROPOSED RU E AND REG GUIDE WITH 0
MODIFICATIONS DISCUSS INTEGRATED APPROACH FOR GENERIC ISSUES (EDO DECIDED TO SEPARATE THIS FRO'M SB0 RULEMAKING)
SOLICIT COMMENT ON DEFERRING A-44 PENDING INTEGRATION OF RELATED ISSUES (COMMISSION DID NOT INCLUDE IN FR NOTICE)
DELETE REQUIREMENT FOR FMEA IN REG GUIDE i
(CUIDE MODIFIED ACCORDINGLY)-
INCLUDE "ZER0-HOUR DURATION" CATEGORY (FIN'AL RESOLUTION INCLUDES ALTERNATE AC APPROACH)
APPROACH TO FINAL RESOLUTION IS SAME AS PROPOSED RESOL o
REDUCE FREQUENCY OF OCCURRENCE OF CORE DAMAGE FROM S o
PRESENTATION FOCUSES ON CHANGES FROM PROPOSED RESOLUTION SUPPORTING TECHNICAL ANALYSIS INDUSTRY INITIATIVES I
n Tr?x HManst 7*
1 fRLoe>RG 3.- )
p w u re s o r cit 4 4.
Mettras w, II5 L
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PRESENTATION ON THE FINAL R ESOLUTION OF USIA-44,NTATIONBLACK0UT l
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TO THE COMMITTEE TO REVIEW GENERIC REQUIREMENTS BY J
i W. MINNERS, RES A. RUBIN, RES t
P. BARAN0WSKY, NRR MAY 27, 1987 l
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ELEMENTS OF FINAL RESOLUTION i
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o' FTATION BLACK 0UT RULE REQUIRES ALL PLANTS TO BE ABLE TO COPE WITH STATION BLACK 0UT-FOR SPECIFIED DURATION o
REGULATORY GUIDE ON STATION BLACK 0UT IN SUPPORT OF RULE PROVIDES GUIDANCE FOR ALL PLA.NTS TO COMPLY WITH RULE GUIDANCE ON ACCEPTABLE PLANT-SPECIFIC CDPING DURATIONS 4
GUIDANCE ON USE OF ALTERNATE POWER SOURCES 1
PROCEDUPES AND TRAINING TO COPE WITH STATION l
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BLACK 0UT MIN!PUM EDG RELIABILITY l
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CONSIDERATIONS RELATED TO NEED FOR A RULE I,
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.o TECHN CAL DIFFERENCES BETWEEN NUMARC AND STAFF POSITIONS OTHER CONSIDERATIONS IF TECHNICAL POSITIONS WERE IDENTICA o
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ENFORCEABILITY - CAN NRC ASSURE ALL PLANTS WILL IMPLEMENT RESOLUTION?
1 CAN NRC ISSUE GUIDANCE WITHOUT A RULE (E.G,, COPING WITH SBO, RCP SEALS)?
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i RllLE AND REGULATORY GUIDE SPECIFY POSITIONS TO NRC j
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APPROACH FOR'RES0 Lilt 10N OF ISSUE
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DETERMINE CURPENT ESTIMATED FREQUENCY OF CDF DUE TO STATION o
BLACK 0UT FOR A SPECTRUM 0F PLANT DESIGNS j
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IDENTIFY DOMINANT FACTORS AFFECTING CDF AND COST EFFECTIVE o
IMPROVEMENTS LIKEllH00D OF FREQUENCY AND DURATION OF LOSS OF AC P0FER ABILITY TO COPE WITH EXTENDED LOSS OF AC POWER PROPOSE NEW OR REVISED REQUIREMENTS CONSISTENT WITH LEVE c
RISK, AND COST EFFECTIVENESS I
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e RELATIONSHIP TO OTHER ISSilES B-56, DIESEL GENERATOR RELIABILITY o
o GI-23,.RCP SEALS A-45, SHUTDOWN DECAY HEAT REMOVAL REQUIREMENTS o
A-30, ADEQUACY OF SAFETY-RELATED DC POWER SUPPLY o
(PART OF GI 128) was=m
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f REVISIONS TO ANALYSES SINCE MARCH 1984 l
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l LOSS-OF-OFFSITE-POWER ANALYSES REVISED REC 0VERY TIMES FOR LOP EVENTS UPDATED AND INCORPORATED LOP EVENTS THRU 1985 j
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REVISED PLANT DESIGN GROUPS AND DATA CLASSIFICA110NS IMPROVED WEATHEP HAZARD DATA ADDED SALT SPRAY WEATHER HAZARD FOR C0ASTAL SITES j
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EMEPGENCY AC POWER RELIABILITY UPDATED EDG FAILURE DATA THRU 1985 REVISED CCF DATA AND CCF ANALYSES ADDED 2-0F-4 CONFIGURATION STATION BLACK 0UT AND CORE DAMAGE FREQUENCY USE UPDATED LOP AND EAC ANALYSES l
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SUMMARY
OF OPERATIMG EXPERIENCE RELEVANT TO STATION BLACK 0UT
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1 FROM 1968 - 1985:
64 TOTAL LOSS OF OFFSITE POWER EVENTS OF A FEW MINUTES DUP.ATION UP TO 26 HOURS
- FROM 1976 - 1985:
OVER 600 EMERGENCY DIESEL GENERATOP. FAllllRES DURING TESTING AND ACTUAL DEMANDS; 22 INSTANCES INVOLVED MULTIPLE FAILUP.ES DUE TO COMMON CAllSE.
F".0P 1958 - 1985:
SEVERAL STATION BLACK 0UT PRECURSOP.S INVOLVING TOTAL LOSS OF 0FFSITE POWER AND UNAVAILABILITY OR FAILURE OF ONE OR MORE EMERGENCY AC POWER SUPPLIES.
SEVERAL OF THESE INCIDENTS INVOLVED LOSS OF.ALL AC POWEP. - STATION BLACK 0UTS.
- LICENSEE STATES THAT POWER COULD HAVE BEEN RESTORED IN 5+ ll00PS, IF NECESSARY.
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- _ ~. - - _ _ - -
e Table 1.1 Summaryofstationblackoutprogramtechnical/results Parameter
'Value Operational Experience Loss of offsite power (occurrence per year)
Average 0.1 Range O to 0.4 j
Time to restore offsite power (hours)
[
Median 0.6 l
90% restored 3.0 Emergency diesel generator reliability (per demand)
Average 0.98 Range 0.9 to 1.0 Median emergency diesel generator repair 8
time (hours)
Analytical Results Estimated range of unavailability of 10 4 to 10 2 emergency AC power systems (per demand)
Estimated range of frequency of 10 5 10.s station blackout (per year)
Estimated range of frequency of core damage 10 5 - 10 4 I
as a result of station blackout (per year) f e
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LOSS OF 0FFSITE POWER 4
PAST OPERATING EXPERIENCE 1
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ANALYSIS OF CAUSE, FREQUENCY, DURATION O
RELATIONSillP OF DESIGN AND LOCATION TO FREQUENCY AND DURATION j
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FACTORS AFFECTING OFFSITE PCMER AVAILABill1Y
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1 DESIGN -
REIUGANCY AND INN 3410F 0FFSITE FMR CIRCulTS,I ALTERNATE POWER SOURCES AVAILABLE OPERATIONS -
PROCEDURES FOR RESTORATION AT PLANT AND CD0RDINATION WITH DISPATCH SYSTE OFFSITE LOCATION-GRID STABILITY, WEATHER O
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EMERGENCY AC POWER RELIABILITY j
I DESIGN FEATURES
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RELIABILITY DATA COMMON CAUSE FAILURE EMERGENCY AC POWER SYSTEMS RELIABILITY l
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.t TYPES OF ACUTAL At!D POTENTI AL COMMON CAUSE FAILURES l
COMMON CAUSE FAILURE GROUP TYPES OF FAILURES r
DESIGN / HAP.DWARE MECHANICAL / ELECTRICAL DESIGN INADE00ACY SUBSYSTEMS (FUEL, C00LINC, START, ACTUATION)
ENVIRONMENT (NORMAL)
OPER ATIONS/ MAINTENANCE INADE00 ATE PROCEDURES WRONG PROCEDURE ERRORS OF OMflSSION/ COMMISSION s.
DEPENDEhCE/ SUPPORT DC CONTROL POWER *.
SYSTEMS SERVICE WATER COOLING EDG ROOM HVAC ELECTRICAL INTERFACE EXTERKtL FIRE FLOOD SEVERE WEATHER SElSFlC OTHEP. ENVIRONMENTAL EXTREMES l
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FACTORS AFFECTING ONSITE AC POWER RELIABILITY
- ONSITE AC POWER SYSTEM CONFIGURATION
- RELIABILITY OF EMERGENCY DIESEL GENERATORS
- VULNERABILITY TO COMM.ON CAUSE FAILURE
- DESIGN ERROR
- HUMAN ERROR
- INTERNAL ENVIRONMENT
- EXTERNAL HAZARDS
- SUPPORT / AUXILIARY SYSTEM DEPENDENCE COOLING ACTUATION AND CONTROL O
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I, STATION BLACK 0UT ANALYSIS I
INTEGRATE LOSS OF 0FFSITE POWER
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FPIQUENCY AND DURATION
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WITH EMERGENCY AC POWER RELIABILITY MODELS INCLUDING:
FTS, FTR, CCF, SYSTEM DEPENDENCIES DETERMINE SENSITIVITY TO DESIGH, LOCATION, AND EDG RELIABILITY e
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ACCIDENT SEQUENCE ANALYSIS l
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ACCIDENT SEQUENCE DELINEATION
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ACCIDENT SEQUENCE PROGRESSION ACCIDENT SEQUENCE LIKELIHOOD CONTAINtiENT PERFORMANCE AND RISK e
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1 tocopewithastationblacko/ ability Table 6.2 Possible factors limiting the ut event Type,of plant Limiting factor PWR BWR 2/3 BWR 4/5/6 l
1 RCS pump seal leakage X
X l
RCS letdown / makeup and water X
X j
chemistry control lines j
l Stuck-open relief valve X
X' DC battery capacity (instruments-X X
X tion and control)
Compressed air (valve control)
X X
X Decay heat removal water supply X
X X
(condensate, firewater) l 0~ rsting environment 1
(temperature)
Ccntrol room X
X X
(instrumentation and control)
Containment X
(suppression pool, wetwell, drywell)
Auxiliary building X
X (AFWS/ room)
(HPCI/RCIC room) i W
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- 9-Table C.1' Summary of potentially domina'nt core damage accident sequences DHRsystem/compolnent AC recovery Generic time to avoid plant type Sequence contributors core damage, hr PWR TML B Steam-driven AFWS unavailable 1 to 2 2
(all) l TMLaB2 DC power or condensate exhausted 4 to 16
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TMQ2 2 RCS pump seal leak 4 to 16 B
BWR.
TMU B Isolation condenser unavailable I to 2 2 3 w/ isolation condenser TMQB Stuck open relief valve 1 to 2 2
TMQ2 2 RCS pump seal leak 4 to 16 B
BWR THU B HPCS/RCIC unavailable 1 to 2 2 2 w/HPCS-RCIC THU B DC power or condensate exh'a'usted, 4 to 16 22 component operability limits exceeded (HPCI/RCIC)
BWR TMU B HPCS/RCIC unavailable, I to 2 2 3 w/HPCS-RCIC THU B 22 HPCS unavailable, DC power or 4 to 16 condensate exhausted, component operability limits exceeded (RCIC)
Notes:
DHR = decay heat removal HPCI = high pressure coolant inspection AFWS = auxiliary feedwater system RCIC = reactor core isolation cooling i
RCS = reactor coolant system HPCS = high pressure core spray e
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Ranga of Estimetsd Coro Damage Frequsncy from Station Blackout Events -
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' Higher EDG Reliability h
M' ore Redundant EDG g
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, Characteristics
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, severe weather)
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i Plant's Ability to Cope with Station Blackout (hours)
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SUPMARY OF STAFF-FINDINGS
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L RELIABILITY 0FONSITEEMERGENCYACPOWERSYSTEMSVARIESCONSIDERAELY CONFIGl' RATION (REDUNDANCY)
E,DG RELIABILITY FRE0VENCY AND DURATION OF 0FFSITE POWER LOSS VARY CONSIDERABLY SITE CHARACTERISTICS (WEATHER, GPID)
PLANT FACTORS (SWITCHYARD DESIGP, TRANSMISSION LINES)
EXTENDED DURATION STATION BLACK 0UTS (> 2 HOUPS) CAN BE SIGNIFICANT CONTRIBUTORS TO RISK CORE DAMAGE FREQUENCY VARIES CONSIDERABLY FROM PLANT TO PLANT SUSCEPTIBILITY TO STATION BLACK 0UT ABILITY TO COPE WITH LOSS OF ALL AC POWER NO SINGLE FIX APPLIED UNIFORMLY TO ALL PLANTS WILL RESOLVE THIS ISSUE IN A COST-EFFECTIVE MANNER I
- ,.._ a.....
li1PLEVENTATION OF STATION BLACK 0UT RULE
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I DETERMINE ACCEPTABLE SB0DURAT.0N(BASEDON 1
(1)
F0l!R FACTORS)
V ASSESS PLANT'S CAPABILITY (lI)
TO COPE WITH SB0 FOR e AN.AClke(A//"
DURATION DETERMillED IN (I)
Sds el)
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CAN PLANT COPE WIT (III)
SB0 FOR DURATION N0 IMPLEMENT MODIFICATIONS DETERMINED TO EXTEND SB0 COPING IN (1) ?
C/PABILITY YES V
IMPLEMENT PROCEDURES (Iv)
AND TRAINING FOR COPING j
WITH SB0 M *,
IMPLEMENTATION SCHEDULE FOR 950.63 LICENSEES SUBMIT TO NRC (WITHIN 9 MONTHS AFTER RULE IS ISS O
PROPOSED ACCEPTABLE SB0 DURATION, INCLUDING
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JUSTIFICATION IDENTIFICATION OF FACTORS, IF ANY, THAT LIMIT CAPABILITY OF PLANT TO COPE FOR AB0VE DL' RATION DESCRIPTION OF PROCEDURES TO COPE WITH SB0 FOR AB0VE DURATION 1
i LIST OF EQUIPMENT MODIFICATIONS, IF'ANY, TO COMPLY WITH RULE AND PROPOSED IMPLEMENTATION SCHEDULE i
o NRC REVIEWS LICENSEES SUBMITTALS FOR PLANT'S REQUIRING EQUIPMENT MODIFICATIONS WITHIN 6 MONTHS OF NRC REVIEW, LICENSEES SUENIT SCHEDULE FOR o
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COMPLETING MODIFICATIONS, WITH JUSTIFICATION IF SCHEDULE IS LONGER THAN 2 YEARS AFTER NRC REVIEW LICENSEE AND STAFF MUTUALLY AGREE ON FINAL SCHEDULE FO o
IMPLEMENTING MODIFICATIONS
STATION BLACK 0UT REGULATORY GUIDE i
o ONSITE ENERGENCY AC POWER SOURCES i
RELIABILITY PROGRAM TO MONITOR AND MAINTAIN EDG RELIABILITY AT ACCEPTABLE LEVEL l
TARGET VALUES FOR MAXIMUM EDG FAILURE RATE PROCEDURES FOR RESTORING EMERGENCY AC POWER 0
0FFSITE POWER j
PROCEDURES TO RESTORE OFFSITE POWER AND USE NEARBY POWER SOURCE WHEN OFFSITE POWER IS UNAVAILABLE o
ABILITY TO COPE WITH STATION BLACK 0UT GUIDANCE ON DETERMINING MINIMUM-ACCEPTABLE SB0 COPING CAPABILITY GUIDANCE ON EVALUATING PLANT'S ACTUAL CAPABILITY FOR COPING WITH SB0 FOR ABOVE DURATION GUIDANCE ON CREDIT FOR ALTERNATE POWER SOURCES TO COPE WITH SB0 o
MODIFICATIONS TO EXTEND PLANT'S CAPABILITY TO COPE WITH SB0 o
PROCEDURES AND TRAINING TO WITHSTAND AND REC 0VER FROM SB0 av
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f Table 1 Acceptable Station Blackout Duration Capability'(hours)a D
Emergency AC Power Configuration Group A
8 C
D
[!
Maximum EDG Failure Rate Per Demand Offsite Power Design C
Characteristic. Group 0.025 0.05 0.025 0.05 0.025 0.05 0.025 P1 2
2 4
4 4
4 4
P2 4
4 4
4 4
8 8
s.
P3 4
8 4
8 8
16 8
" Variations from these times will be considered by the staff if justification, including a cost-benefit analysis, is provided by the licensee.
The methodol-ogy and sensitivity studies presented in NUREG-1032 (Ref. 2) are acceptable for use in this justification.
b See Table 2 to determine emergency ac power configuration group.
CSee Table 3 to determine groups P1, P2 and P3.
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IMPORTANT ITEMS TO MEET SB0 DURATION GUIDELINES
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ENSURE CAPABILITY OF SYSTEMS / COMPONENTS FOR SB0 DURATIO o
1 STATION PATTERIES
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l l
l CONDENSATE STORAGE TANK COMPRESSED AIR EQUIPMENT OPERABILITY UNDER SB0 CONDITIONS RCP SEAL INTEGRITY c
DEVELOP PROCEDURES AND TRAINING o
F.AINTAIN/ IMPROVE EDG RELIABILITY 4
?G
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VALUE/ IMPACT SilMMAP.Y l,
l ESTIMATES REDUCTION IN COPE PAMAGE FREQUENCY MEAN SB0 CDF BEFORE RULE 4.2 x 10-5fpy
/
MEAN SB0 CDF AFTER RULE 1.6 x 10-5/RY ESTIMATED COST AVERAGE $600,000/ REACTOR RANGE $350,000 - $4 MILLION TOTAL COST T0 INDUSTRY - APPR0XIMATELY $60 MILLION PRESENT VALUE OF ONSITE COSTS (1.E., AVOIDED DAMAGE)
$38 MILLION ESTIMATED RISK REDUCTION 145,000 PERSON-REM VALUE/ IMPACT RATIO 2,400 PERSON-REM /$1 MILL'10N (6,100 PERSON-REM /$1 MILLION IF ONSITE COSTS ARE INCLUDED) i I
2"7
1
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(A) SEFORE RULE i
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= 2.4 x 10 - 5 r1Y g = 4.17 x 10-5 ay,
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ESTIMATED CORE DAMAGE FREQUENCY ( x 10-5 PER REACTOR YEAR'l
- 18) AFTER RULE X
MEDIAN CDF
= 1.1 x 10 - 5/RY 25 -
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2 lMEAN COF j
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Figure 4 COMPARISON OF ESTIMATED STATION BLACKOUT (SBO)
CORE DAMAGE FREQUENCY (CDF) BEFORE AND AFTER RULE oo E _ _ _ _____ _ _______
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COST ESTIMATES
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I ESTIMATED ESTIMA' RED TOTAL COSTS (MILLION DOLLARS)
NUMBER OF L
ACTIVITY REACTORS BEST-HIGH LOW ASSESS SB0 100 25' 40 20
. CAPABILITY PROCEDURES AND 100-10 15 5
TRAINING JMPROVE EDG 10 2,5 4
1.5 RELIABILITY REQUALIFY EDG 2
5.5 11 2.5 HARDWARE 27 17 24 13 MODIFICATIONS 60 94 42 39
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Valub-impact summary for resolution of USI A-44 Table 12 Dose reduction (person-rems)
Cost ($1,000)
Best High Low Best High Low Parameter e s t'.
est.
est.
est.
est.
est.
Public health 143,000 215,000 65,000 Occupational exposure (accidental)2 1,500 1,500 1,500 Occupational exposure (routine)2 NA Industry implementation 60,000 93,500 44,500 hnu implementation 3 1,500 1,500 1,500 Total 144,500 216,500 66,500 61,500 95,000 43,000 Value-impact ratio 4 2,400 5,000 700 (Public dose reduction divided by sum of NRC and ir stry costs (person-rems /$106))
i Ms.
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PUBLIC COMMENTS ON PROPOSED RULE j,
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PROPOSED RULE ISSUED FOR COMMENT 3/21/86 (5] FP 9829)
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o DRAFT REGULATORY GUIDE ISSUED FOR COMMENT 4/3/86 (51 FR 114913) l c
90-DAY COMMENTS PERIOD ENDED 6/19/86 o
53 LETTERS COMMENTING ON PROPOSED RULE 45 FROM NUCLEAR INDUSTRY OPPOSED GENERIC RULEMAKING NUMARC INITIATIVES SUBMITTED 8 OTHER LETTERS SUPPORTED OBJECTIVE OF PROPOSED RULE PROPOSED RESOLUTION DOES NOT 60 FAR EN0 UGH
. -- _.. 1 z _ ; E-SIGNIFICANT CHANGES FROM PROPOSED RULE 8 REGLILATORY GUIDE RULE l
I ELIMINATED REQUIREMENTS TO DETERMINE MAXIMUM COPING CAPABILITY CLARIFIED DEFINITION OF SB0 j
l L
0 REGULATORY GUIDE CLARIFIED GUIDANCE GIVING CREDIT FOR ALTERNATE POWER SOURCES (E.G., REC 0VER ALTERNATE AC SOURCE TO COPE WITH SB0)
CLARIFIED GUIDANCE ON EDG FAILURE RATE (AUT0-START FAILURES NOT COUNTED AS FAILURES)
MODIFIED GUIDANCE TO DETERMINE ACCEPTABLE PLANT-SPECIFIC COPING DURATIONS BASED ON UPDATED ANALYSIS IN NUREG-1032 (REGROUPED PLANTS A'ND ADDED AND 16 HOUR COPING DURATIONS)
DELETED GUIDANCE REFERRING TO MAXIMUM COPING DURATION VALUE-IMPACT ANALYSIS IN NUREG-1109 o
INCLUDES 100 OPERATING REACTORS ACCOUNTS FOR RESULTS OF LATEST SOURCE TERMS DISCUSSES NUMARC INITIATIVES o
NUREG-1032 UPDATED ANALYSIS BASED ON CURRENT EDG AND LOSP DATA
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PUBLIC COMMENTS (PEVISIONS TO PROPOSED RESOLUTION) o FOUR COMMISSION QUESTIONS OUALITY CLASSIFICATION OF MODIFICATIONS (N0 CHANGE)
DOES BACKFIT ANALYSIS IMPLEMENT BACKFIT RULE S50.109 (BACKFIT ANALYSIS REVISED)
WOULD PROPOSED RULE SUBSTANTIALLY INCREASE OVERALL PROTECTION OF PUBLIC HEALTH AND SAFETY? (VALUE/ IMPACT ANALYSIS REVISED)
SHOULD NRC RE0lllRE IMPROVEMENTS BEYOND THOSE PROPOSED?
(N0 CHANGE)
P 0
. -.... - -.. ~....
INDUSTRY ACTIVITIES l
0 EPRI TECHNICAL STUDIES I
NSAC/103 LOSP MAY 1986 NSAC/108 EDG RELIABILITY SEPT, 1986 l
ANS DRAFT STANDARD 58.12 ON LOSS OF ALL AC POVER o
REVISED DRAFT MARCH 1987 o
NUMARC INDUSTRY INITIATIVES JUNE 1986 MEETINGS WITH STAFF JULY 86-PRESENT l
l
NUMARC INITIATIVES
/,
INITIATIVES SUBMITTED IN RESPONSE TO PUBLIC COMMENTS ON PROPOSED RULE 1.
CATEGORIZE PLANTS INTO 4 OR 8 HOUR GROUPS, AND FIX 8-HOUR
/
PLANTS TO BECOME 4-HOUR (USED STAFF GUIDANCE) 2.
PROCEDURES A.
COPE WITH SB0 (SPECIFIC DURATION AND COPING ASSESSMENT NOT SPECIFIED)
B.
RESTORE AC POWER FOLLOWING SB0 C.
PREPARE PLANT FOR SEVERE WEATHER 3.
ELIMINATE EDG COLD FAST STARTS 4.
MONITOR EDG UNAVAILABILITY (DOES NOT INCLUDE RELIABILITY PROGRAM)
STATUS OF NUMARC INITIATIVES i
1.
CATEGORIZATION OF ALL PLANTS INTO 4 OR 8 HOUR GROUPS SUBMITTED TO NUMARC 2.
GUIDELINES FOR PROCEDURES BEING DEVELOPED GUIDELINES TO COPE WITH SB0 INCLUDE AC-INDEPENDENT AND ALTERNATE AC APPROACHES (STAFF NOT IN AGREEMENT YET) 3.
REPORT ON COLD FAST STARTS TO BE ISSUED 4.
EDG MONITORING TO BE BASED ON INP0 SAFETY SYSTEM MONITORING PROGRAM (STAFF DEVELOPING DG RELIABILITY PROGRAM)
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NUMARC INITIATIVES COMPARED TO STATION BLACK 0UT RULE DETERMINE ACCEPTABLE (1)
SB0 DURATION (BASEDON F0llR FACTORS)
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t W
hr h
V i
ASSESS PLANT'S CAPABILITY
- (II)
TO COPE WITH SB0 FOR DURATION DETERMINED IN (I)
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I v
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CAN PLANT COPE WIT (111)
SB0 FOR DURATION NO IMPLEMENT MODIFICATIONS DETERMINED TO EXTEND SB0 COPING 7
IN (I) ?
CAPABILITY l
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W bJ V
IMPLEMENT PROCEDURES (IV)
AND TRAINING FOR COPING WITH SB0
i RELAT!0NSHIP BETWEEN A-44 ANirA-45
/,
A-44 A-45 SCOPE DHR SYSTEM ADE0l!ACY DHR SYSTEM OVERALL W/0 AC POWER ADE0UACY ISSUE SHOULD PLANTS BE ABLE NREADDITIONALDHR TO WITPSTAND STATION
! MEASURES NEEDED'TO BLACK 0UT?
IF S0, FOR ASSURE DHR RELIABILITY HOW LONG?
FOLLOWING TRANSIENTS, ACCIDENTS, OR SPECIAL EMERGENCIES?
MAJOR CONSIDERATIONS CONCURRENT LOSS OF DHR SYSTEM RELIABILITY, OFFSITE AND ONSITE AC INI11ATING TRANSIENTS, POWER; AC-INDEPENDENT INITIATING ACCIDENTS, DHR SYSTEM RELIABILITY; SAB0lAGE, FIRE, FLOOD RECOVERY OF AC POWER POSSIBLE SYSTEM EXTEND CAPACITY OF DC FEED AND BLEED; ADD-0N MODIFICATIONS BATTERIES, CST AND SUPPRESSION POOL COMPRESSED AIR COOLING; DEDICATED DHR SYSTEM W/ DIESEL GENERATOR SCHEDULE ISSUE RESOLUTION FOR COMMENT 03/86 LATE 1987 ISSUE FINAL RESOLUTION 10/87
l RELATIONSHIP BETWEEN A-44 AND GI-23 l
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- A-44 GI-23 O
RECOMMENDS GUIDELINES ON RCP SEAL
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INTEGRITY FOR SPECIFIC STATION BLACK 0UT DURATIONS o
IF SEAL INTEGRITY CAN NOT BE o
DEVELOPS DATA TO DETERMINE VEPIFIED, THAN PLANT MAY NEED RCP SEAL BEHAVIOR W/0 AC-INDEPENDENT CHARGING SYSTEM COOLING FOR SEAL COOLING l
l 71
p e to the Minutes of CRGR Meeting No. 115 Proposed Amendmer.t to 10/ CFR 50.55a - Codes and Standards May 27, 1987 1
TOPIC j
G. Millman (RES) presented for CRGR review the proposed rule amendment which l
would update existing references to Section III, Division 1, and Section XI, Division 1, of the ASME Code.
The Committee was requested to recommend i
approval for issuing the proposed amendment for public comment. Copies of the briefing material used by the staff in their presentation at this meeting are attached to this Enclosure.
BACKGROUND This type of amendment has been proposed approximately every three years and is expected to be proposed annually in the future.
Prior to 1986, similar proposals were generally not reviewed by CRGR on one or both of two bases:
(1) there were no new requirements to be imposed on licensees, or (2) the new imposition would result in no significant impact on licensees.
It was established that ASME Code updates which the staff sought to endorse by amendment to 10 CFR 50.55a would be reviewed by the CRGR only to the extent that the staff proposal would take exception to the standard and modify it or add to it.
10 CFR 50.109, effective October 1985, and conforming changes in the CRGR charter during 1986 have resulted in subsequent CRGR reviews of staff proposals to endorse national standards for use in the regulatory process.
RES stated in this proposal that the proposed amendment should not be snbject to the backfit provisions of 50.109, and offered a three point rationale to support that opinion.
The material submitted for review included the following:
1.
Memorandum, E. Beckjord to J. Zerbe, April 13, 1987, subject: CRGR Review of Proposed Amendment to 10 CFR 50.55a, Codes and Standards Rule.
- 2., Federal Register Notice for the proposed rule.
- 3., draft regulatory analysis.
{
l DISCUSSION j
G. Millman reviewed the consensus process by which revisions to the ASME Code
)
are developed, pointing out that all parties having interest are included in l
this process, including the NRC. He briefly reviewed what the effect on the regulated industry would be as a result of the changes in Section III and in Section XI. Only the Section XI revisions would affect licensees or plants already under construction. The limitations on use of the Winter 1983 Addenda as applied to certain types of welds in austenitic stainless steel piping subject to cracking were described. Mr. Millman also described the RES rationale for excusing ASME Code updates from CRGR review.
_ __ )
i The Coneittee, in recognition of the extensive, comprehensive, and interactive j
review process involvirig NRC and the public entities having interest in the proposal, discussed this matter only briefly before deciding that the proposed amendment should issie for public comment. The Consnittee did not accept the l
proposition that thi or future proposed amendments of this type would be excused from CRGR review at either the proposed (for public comment) or the l
final stage. This conclusion, however, was not intended to foreclose future consideration of this matter by the Committee.
RECOMMENDATION TO THE EDO
/
I The CRGR recommended that the proposed amendment should be issued for public l
comment, and that the' final amendment package, as revised after public i
comment, should be reviewed by the CRGR. No changes are necessary in the existing proposal prior to issuance for public comment.
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