ML20245J330

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Provides Background Info on Regulatory Analysis Supplementing NRC Proposed Backfit,Per 890413 Request.Util Expected to Provide Schedule for Implementation of Required Improvements
ML20245J330
Person / Time
Site: Arkansas Nuclear, Rancho Seco, 05000000
Issue date: 06/22/1989
From: Holahan G
Office of Nuclear Reactor Regulation
To: Tison Campbell
ARKANSAS POWER & LIGHT CO.
Shared Package
ML20245E948 List:
References
REF-GTECI-124, REF-GTECI-NI, TASK-124, TASK-OR NUDOCS 8907030002
Download: ML20245J330 (5)


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UNITED STATES jE)[}

NUCLEAR REGULATORY COMMISSION j

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June 22, 1989 4

s Docket tio. 50-368 j

i Mr. T. Gene Campbell

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Vice President liuclear f

Arkansas Power and Light Company F. O. Box 551 L

Little Rock, Arkansas 72203 l

Dear Mr. Campbell:

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SUBJECT:

PROPOSED BACKFIT FOR ARKANSAS NUCLEAR ONE, UNIT 2 A letter from D. James of your staff requested background information on the regulatory analysis supplementing the fiRC staff's proposed backfit, dated April 13, 1989, for improving the reliability of the Arkansas Nuclear One, Unit 2 ( A;~-2) auxiliary feedwater (AFW) system. This proposed backfit was approved by Thomas E. Murley, Director, Office of Nuclear Reactor Regulation by n.enorandum dated January 31, 1989 (Enclosure 1). The full regulatory analysis i

.was enclosed in our April 13, 1559 letter to you.

In response, I ao providing the following information.

The At:0-2 AFW systen reliability issue has been the subject of numerous dis-cussions and evaluations over the last three years.

After completion of a j

reliability assessment of the ANO-2 AFW system, the staff's preliminary determination was that improvement was needed in the secondary heat removal capability at Ah0-2 and this was a potential backfit action. These facts werc discussed with AP&L staff during a public meeting held on June 10, 1987.

Subsequently on July 31, 1987, the draft report evaluating the AFW system was trarsnitted to AP&L. The report included an initial regulatory analysis in support of the staff's position. This position has been consistent from the outset.

The evaluative effort culminated with a final decision to propose a backfit to ensure achievement of an acceptable level of reliability. This decisien was based on the information provided to you in a letter dated June 14, 1988 (Enclosure 2) and evaluation of AP&L's response dated September 2, 1988. The staff explicitly followed its detailed guidelines in preparing this backfit package and in providing the justification for proposing the backfit included in the April letter to you.

The staff's judgment was supplemented by a quantitative analysis that considered the frequency of loss of feedwater, recovery of a condensate pump, AFW system availability, feed-and-bleed f ailure probability and the remaining life of the plant in order to establish a core damage frequency.

Person-rem exposure was then determined based on conditional containment failure probability. An estinated cost for the implementation of the backfit was then assigned to 0Fol 887 M E E h e b'

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l Mr. T. Gene Canipbell establish a cost-benefit value. The staff determined that the proposed improve

  • 1 ment in secondary decay heat removal capability would result in an estimated averted dose to the'public of 1953 rem.

An estimated $2 million cost of the required. modification wculd further support the staff position that improvement in the AFW system reliability is needed even after consideration is given to other factors for decay heat removal.

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l It also should be emphasized that the staff has reviewed and evaluated a con-siderable body of information in support of the need for improvements in AFW

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reliability at ANO-2.

This effort included our experience with the decision to require modifications to the AFW system availability at the Davis Besse plant.

In that case, unnecessary delays in implementing required improvements prevented i

earlier recovery during the loss-of-all-feedwater event at that facility. This transient included multiple equipment failures and a subsequent lengthy plant j

shutdown.

'The staff has complied with its procedure in proposing this backfit and has provided a regulatory analysis that includes sufficient detail and justification for NRC management approval.

We now expect AP&L to provide a schedule for implementation of the required improvements. You may choose to appeal the proposed backfit by providing new information that would demonstrate that the backfit would not provide a substantial increase in overall protection, or that the direct and indirect costs are not justified in view of the increased protection to be achieved by the backfit implementation.

We look forward to your response and to the timely resolution of this safety issue.

Sincerely,

/Y Gary M. Holahan, Acting Director Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Enclosures:

As stated cc w/ enclosures:

See next page DISTRIBUTION:

Docket File NRC PDR Local f*0R PD4 Reading G. Holahan L. Rubenstein F. Heboon P. Noonan C. Poslusny OGC-Rockville E. Jordan B. Grimes ACRS (10)

PD4 Plant File D. Crutchfield J. Wermiel A. Thadani Tech Editor OGC T. Cox C. Sakenas

  • See previous concurrences:

g%r CONCURRENCE:

g PD4/D*

g JWermiel[U d PLB*

SAD PD4/LA*

PD4/FM*

PNoonan CPoslusny FHebdo6' AThadani 05/31/89 05/31/89 05/31/89 06/01/89 06

/89 (A)DTURSP (.

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ADR4*

TECH EDITOR

  • LRubenstein G.%rlahan 06/01/89 05/31/89 06/p /89 i

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I 1

Mr. T. Gene Campbell l i

establish a cost-benefit value. The staff determined that the proposed improve-ment in secondary decay heat removal capability would result in an estimated

)

averted dose to the public of 1953 rem.. An estimated $2 million cost of the

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required modification would further support the staff position that improvement in'the AFW system reliability is needed even after consideration is given to

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i 1.

Other factors for decay heat removal.

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It also should be emphasized that the staff has reviewed and evaluated a con-j i

siderable body of information in support of the need for improvements in AFW l

reliability at AN0-2. This effort included our experience with the decision to require modifications to the AFW system availability at the Davis Besse plant.

l In that case, unnecessary delays in implementing required improvements prevented earlier recovery during the loss-of-all-feedwater event at that facility. This transient included multiple equipment failures and a subsequent lengthy plant shutdown.

(

l The staff has. complied with its procedure in proposing this backfit and has

,j provided a regulatory analysis that includes sufficient detail and justification for NRC management approval. We now expect AP&L to provide a schedule for implementation of the required improvements. You may choose to appeal the

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proposed backfit by providing new information that would demonstrate that the l

backfit would not provide a substantial increase in overall protection, or that the direct and indirect costs are not justified in view of the increased protection to be achieved by the backfit implementation.

We look forward to your response and to the timely resolution of this safety

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issue.

Sincerely,

/Y Gary M. Holahan, Acting Director Division of Reactor Projects - III, j

IV, V and Special Projects Office of Nuclear Reactor Regulation

Enclosures:

As stated l

CC w/ enclosures:

l See next page DISTRIBUTION:

Docket File NRC PDR Local PDR PD4 Reading G. Holahan L. Rubenstein F. Hebdon P. Noonan C. Poslusny OGC-Rockville E. Jordan B. Grimes ACRS (10)

PD4 Plant File D. Crutchfield I

J. Wermiel A. Thadani Tech Editor 0GC T. Cox i

C. Sakenas I

/

j

  • See previous concurrences:

A4(

CONCURRENCE:

i$1 PD4/PM* h PD4/D*d.

PLB*

SAD l

PD4/LA*

PNoonan CPoslusny FHebdofF JWermiel AThadani l

05/31/89 05/31/89 05/31/89 06/01/89 06

/89 l

ADR4*

TECH EDITOR *

(AMTURSF -

LRubenstein G.'Hofahan l

l 06/01/89 05/31/89 06/fL/89 l

t -----_______ --

i 4

l-Mr. T, Gene Carpbell.

establish a' cost-benefit value. The staff determined that the proposed improve-1 ment in secondary decay' heat renoval capability would result in an estimated averted dose to the public of 1953 rem. An estimated $2 million cost of the-required modification would further support the staff' position that improvemen,t in the AFW system reliability is needed even after consideration is given to other factors for' decay heat renoval.

It also should be emphasized that the staff has reviewed and evaluated.a con-

.siderable body of information in support of the need for improvements in AFW reliability at ANO-2. This effort included our experience with the decision to require modifications to the AFW system availability at the Davis Besse plant.

In that case, unnecessary delays in implementing required improvements prevented

- earlier recovery during the loss-of-all-feedwater event at'that facility. This transient included rultiple equipment failures and a subsequent lengthy plant shutdown.

The staff has complied with its procedure in proposing this backfit and has provided a regulatory analysis that includes sufficient detail and justification for NRC management approval. We now expect AP&L to provide a schedule for implenientation of the required improvements. You may choose to appeal the-proposed backfit by providine new information that would demonstrate that the backfit would net provide a substantial increase in overall protection, or that the direct and indirect costs are not justified in view of the increased protection to be achieved by the backfit implementation.

-We look forward to your response and to the timely resolution of this safety issue.

Sincerely, Wty >}

Gary M. Holahar., Acting Director Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Enclosures:

As stated cc w/ enclosures:

See next page

b 34 4

r Mr. T. Gene Campbell Arkansas' Power & Light Company Arkansas Nuclear One, Unit 2-

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.c cc:

Mr.. Dan R. Howard, Manager Mr. Charles B. Brinkman, Manager.

Licensing Washington Nuclear Operations Arkansas Nuclear.One

. Combustion Engineering, Inc.

P. O. Bcx 608-12300 Twinbrook Parkway, Suite 330 Russellville, Arkansas 72801 Rockville, Maryland 20852, Mr. James M. Levine, Executive Director

. Site Nuclear Operations.

Honorable Joe W. Phillips Arkansas Nuclear One County Judge of Pope County

' P. O. Box 608 Pope County Courthouse Russellville, Arkansas 72801 Russellville, Arkansas 72801' Mr. Ilicholas S. Reynolds Bishop, Cook, Percell & Reynolds 1400 L Street, N.W.

Washington, D.C.

20005-3502 Regional Administrator, Region IV U.S. huclear Regulatory Commission Office of Executive Director for Operations 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Senior Resident Inspector U.S. liuclear Regulatory Commission 1 Nuclear Plant Road Russelhille, Arkansas 72801 Ms. Greta Dicus, Director Division of Environmental Health Protection Arkansas Department of Health 4815-West Markam Street L

Little Rock, Arkansas 72201 Mr. Robert B. Borsum Babcock & Wilcox Nuclear Power Generation Division 1700 Rockville Pike, Suite 525 Rockville, Maryland 20852 l

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