ML20246F297
| ML20246F297 | |
| Person / Time | |
|---|---|
| Issue date: | 01/05/1989 |
| From: | Jordan E Committee To Review Generic Requirements |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| NUDOCS 8907130206 | |
| Download: ML20246F297 (56) | |
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RELEASEDTO Be enn y1 k
UNITED STATES y
g NUCLEAR REGULATORY COMMISSION 2
j WASHINGTON, D. C 20655
(,...../
January 5, 1989 g
MEMORANDUM FOR:
Victor Stello, Jr-.
l Executive Director for Operations FROM:
Edward L. Jordan, Chairman Committee to Review Generic Requirements
[
SUBJECT:
MINUTES OF CRGR MEETING NUMBER 152 i
The Committee to Review Generic Requirements (CRGR) met on Wednesday, i
December 14, 1988 from 10 a.m.-5 p.m.
A list of attendees for this meeting is attached (Enclosure 1).
The following items were addressed at the meeting:
l 1
1.
L. Shao (NRR) and P. T. Kuo (NRR) presented for CRGR review a draft bulletin related to thermal stresses in pressurizer piping.
The Committee recommended in favor of issuing the proposed bulletin subject to several i
l l
clarifications (to be coordinated with the CRGR staff).
This matter is discussed in Enclosure 2.
2.
M. Malsch (0GC), S. Crockett (OGC, and J. Wilson (RES) briefed the Committee on staff actions in resolving public comments on the 10 CFR Part 52 rulemaking.
The briefing was focused on the resolution of some of the key issues addressed by public comments and which were previously of concern to the Committee, such as, prototype testing, and the scope and detail of designs for certification.
A copy of the briefing slides used by the staff are included as Enclosure 3.
The Committee identified the issue of proto!.ype testing as one area which needs additional clarification in the rule.
3.
B. Grimes (NRR), W. Brach (NRR), and M. Clausen JRR) presented for CRGR consideration a proposed Advance Notice of Proposed Rulemaking (ANPR).
The ANPR sol 1cits public comment on a list of issues related to the procurement of products for use at nuclear power plants.
The Committee had no objection with issuing the ANPR, with only minor clarifications.
A copy of the briefing slides used by the staff are included as Enclosure 4.
4.
W. Houston (RES), W. Beckner (RES), L. Soffer (RES), and J. Ridgely (RES) presented for CRGR review proposed enhancements aimed at improving the r
severe accident performance of Mark I containments.
The Committee did not complete their review of the Mark I package due to some unresolved concerns
- c. 0
%l with several technical issues.
The staff also requested a subsequent
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[30 review meeting to address the method of implementation.
This matter is 0
dispussed in Enclosure 5.
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B. Morris (RES), W. Lahs (RES), and J. Roberts (NMSS) presented for CRGR review a Certificate of Compliance which will be incorporated in 10 CFR u
Part 72 rulemaking and two implementing Regulatory Guides, 3.6.1, Standard Format and Content for a Topical Safety Analysis Report for a Spent Fuel l
Dry Storage Cask, and 3.6.2, Standard Format and Content for the Safety Analysis Report for Onsite Storage of Spent Fuel Storage Casks.
The Committee recommended in favor of issuing the proposed rule with the incorporated certificates of compliance.
This matter is discussed in.
In accordance with the ED0's July 18, 1983 directive concerning " Feedback and j
Closure of CRGR Reviews," a written response is required from the cognizant office to report agreement or disagreement with the CRGR recommendations in these minutes.
The response, which is required within five working days after l
receipt of these minutes, is to be forwarded to the CRGR Chairman and if there f
is disagreement with CRGR recommendations, to the EDO for decisionmaking.
l Questions concerning these minutes should be referred to Charyl Sakenas I
(492-4148).
Drisinal'Sl9 edIff 6
l L Q Jordan l
Edward L. Jordan, Chairman
{
Committee to Review Generic l
Requirements
Enclosures:
As stated I
cc/w enclosures:
)
Commission (5)
SECY.
Office Directors Regional Administrators CRGR Members Distribution: w/o enc.
Central File CRGR SF (w/ enc.)
PDR (NRC/CRGR)
M. Taylor (w/ enc.)
- 5. Treby E. Jordan (w/ enc.)
W. Little J. Heltemes (w/ enc.)
M. Lesar J. Conran (w/ enc.)
P. Kadambi (w/ enc.)
- C15akenasMw/ enc;)
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- CRGR:AE00
- DD:AE00
- C:C R
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NAME :CSakenas
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.................._...........7...................___..........................___.......
- //j/8f DATE :12/ /88:jr :12/ /88 0FFICIAL RECORD COPY
r.
j Attendance List
.l CRGR Meeting No. 152 I
CRGR Members J. Goldberg R. Bernero D. Ross C. Paperiello l
E. Jordan F. Miraglia (for J. Sniezek)/J. Sniezek (partial)
NRC Staff C. Sakenas C. J. Heltemes J. Conran C. Rossi L. Shao J. Richardson C. Liang S. Hou P. Kadambi T. Chan P. Kuo G. Mizuno j
M. Malsch S. Crockett J. Wilson D. Scaletti M. Clausen B. Gr'. as W. Brach A. Thadani W. Hodges C. Tinkler L. Soffer W. Beckner J. Ridgely D. Houston J. Murphy M. Taylor T. Cox S. Treby J. Telford L. Rouse W. Pearson
.B. Morris i
l J. Roberts l
W. Lahs
s e to the Minutes of CRGP Meeting No. 152 Draft Bulletin Entitled Pressurizer Surge Line Thermal Stratification l
Topic l
L. Shao (NRR) and P. T. Kuo (NRR) presented for CRGR review a draft Bulletin j
entitled, Pressurizer Surge Line Thermal Stratification.
This bulletin requests
]
licensees to implement a program to confirm the integrity of the pressurizer j
surge line.
This is based on evidence of surge line movement at Trojan caused by thermal stratification in the line.
This phenomenon was not considered in the original piping design.
A copy of the briefing slides used by the staff J
are attached to this enclosure.
i 1
1 Background
4 The package submitted by the staff for review by CRGR in this matter was trans-mitted by memorandum dated December G,1988, J. H. Sniezek to E. L. Jordan.
A revised copy of the bulletin was provided to the members at the meeting.
The review package included the draft bulletin, responses to the CRGR Charter requirements, and background information.
Conclusions / Recommendations As a result of their review of this matter, including discussions with the staff at this meeting, the Committee made the following recommendations 1.
In section 1.a. of the bulletin, which discusses the visual inspection, the language should be modified to make it clear that the inspection is intended to find only gross damage.
2.
In section 1.c., the language should be corrected to include commitments as well as requirements.
3.
The staff should consider revising the bulletin to indicate that this problem could go beyond this particular component and include similar experience at other facilities.
l
- 4. of the submittal package addresses the CRGR Charter requirements.
{
The staff response to question (vii), on the potential risk to the public from the accidental offsite release of radioactive material should have been described differently.
There is no implicit understanding of risk in GDC.
The statement should have been made that there is a higher I
probability of pipe break and leakage from thermal stratification in the surge line.
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.2.
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PWR SURGE LINE THERMAL STRATIFICATION BACKGROUND SURGE LINE IS 14" TO 16" IN DIAMETER, 50' TO 80' IN LENGTH, HORIZONTALLY CONNECTING THE PRESSURIZER AND ONE OF THE HOT LEGS, WITH FLUID A T UP TO 300*F BETWEEN TWO ENDS.
UNEXPECTED PIPE DEFLECTION AND CONTACT WITH PIPE WHIP RESTRAINT WERE FOUND IN TROJAN.
l BASED ON DATA MEASURED FROM SEVERAL PWR PLANTS, THERMAL STRATIFICATION WAS DETERMINED TO BE THE ROOT CAUSE.
i TROJAN BOUNDING ANALYSIS SHOWED CUF 0F 1.0 AT TEN YEARS (WITHIN TWO YEARS)
STAFF CONCERN:
SURGE LINE AND ASSOCIATED N0ZZLES AND SUPPORTS MAY EXCEED DESIGN LIMITS (OR CODE ALLOWABLES), WHICH MAY (EVENTUALLY)
IMPAIR PIPING INTEGRITY.
POTENTIAL INAPPROPRIATE APPLICATION OF LBB ON SURGE LINES.
. E.REVIOUS STAFF ACTIONS INSPECT TROJAN SURGE LINE ON MAY 17, 1988 AND AUDIT BECHTEL AND W ANALYSES.
MET WITl! W AND COMANCHE PEAK ON AUGUST 18, 1988, AND BEAVER VALLEY ON SEPTEMBER 7, 1988.
MET WITH PWR OWNER'S GROUPS THE WEEK OF SEPTEMBER 29, 1988 TO DISCUSS THE STRATIFICATION PHENOMENA AND THEIR PLANNED ACTIONS.
f NRC INFORMATION NOTICE NO. 88-80 WAS ISSUED ON OCTOBER 7, 1988.
MET WITH W AND HL8P ON NOVEMBER 30, 1986 TO REVIEW THEIR BOUNDING ANALYSIS.
~ ~ _ _ _ - _ _ _ _ _ - _ _ _ - _ _ _
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PURPOSES OF THE BULLETIN TO ESTABLISH AND IMPLEMENT A PROGRAM TO CONFIRM Tile INTEGRITY OF THE PRESSURIZER SURGE LINE.
T0 INFORK THE STAFF OF THE ACTIONS TAKEN.
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C' PRESSURIZER SURGE LINE STRATIFICATION ISSUE BULLETIN I
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[ BOUNDING ANALYSIS VISUAL 4 MOS FOR PLANTS >10 YRS INSPECTION 1 YR FOR PLANTS < 10 YRS NO YES y
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UPDATE STRESS & FATIGUE ANALYSIS WITHIN 24 MOS AFTER BULLETIN ISSUANCE I
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3 RO~0~Y3 E ~~S~ \\ G Certify Evolutionary LWR designs - 52.45a(1)
Standardization Policy - Sept. 15,1987 Certify Advanced designs - 52.45a(2) l
- 31 - Rockwell - concurs with previous approach
- 56 NUMARC - Supports general approach,
" full sized" prototypes or " full scale" testing unwarranted, "significantly different" is imprecise.
Certify only Advanced designs
- 58 - Nuclear Information & Resource Service-P.7
- 62 - Union of Concerned Scientists - P.3&5 l
- 66 - New York Attorney General - P.9 None - Environmental Planning Lobby - P.2 L
SCOPE 4
Response to Question 5 i
Major Portion of a plant
- 56 - NUMARC
- 59 - Stone & Webster
- 69 - Combustion Engineering Complete Design except site-specific elements - 52.47b(1)
- 57 - DOE
- 68 - Ohio Citizens for Responsible Energy
- 71 - Westinghouse Reduced Scope for Advanced designs 52.47b(2) i
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SUMMARY
o BACKGROUND o
PRODUCTS PROCURED F0P USE IN SAFETY-RELATED APPLICATIONS 4
GENERAL QUESTIONS METALLIC PRODUCTS NONMETALLIC PRODUCTS COMPONENTS
-o DEDICATION OF COMMERCIAL GRADE PRODUCTS FOR USE IN SAFETY-RELATED APPLICATIONS GENERAL QUESTIONS METALLIC PRODUCTS NONMETALLIC PRODUCTS COMPONENTS 0THER QUESTIONS ENDORSEMENT OF OTHER AGENCY /0 ORGANIZATION STANDARDS OR PROGRAMS OTHER ALTERNATIVES
- to the Minutes of CRGR Meeting No. 152 Proposed (Severe Accident) Enhancements to Mark I Containments December 14, 1988 l
TOPIC l
l W. Houston (RES), W. Beckner (RES), L. Soffer (RES), and J. Ridgaly (RES) presented for CRGR review proposed enhancements (including plant modifications i
and procedures improvements) aimed at improving the severe accident perform-ance of Mark I containments.
The staff's proposal called for issuance of a generic letter to initiate as expeditiously as possible implementation of the recommended upgrades, to be followed by a rulemaking to codify new requirements imposed initially by the generic letter.
(The Committee was briefed on an earlier version of the current package of proposed Mark I upgrades at Meeting No. 104.) Copies of the slides used by the staff to guide their presentation and discussions with the Committee at this meeting are enclosed (Attachment 1 to this Enclosure).
BACKGROUND 1.
Documents provided in advance of the meeting for review by CRGR were transmitted officially by two memoranda, (1) E.S. Beckjord/T.E. Murley to E.L. Jordan, dated December 7, 1988; and (2) E.S. Beckjord to E.L. Jordan, dated December 9, 1988.
The documents transmitted to CRGR by these memoranda were as follows:
a.
Draft Commission Paper (undated), " Mark I Containment Performance Improvement Program," and attachments as follows:
- i. - Responses to August 1, 1988 SRM ii. - Table, " Mark I Challenges and Relative Likeli-hood of Failure Modes" iii. - Summary of Costs iv. - Regulatory Analysis
- v. - BWR Mark I Plant Survey vi. - BWR/ Mark I Liner Failure Issue vii. - Draft Generic Letter, " Proposed Severe Accident Requirements for Plants with Mark I Containments" viii.
Appendix A - Backfit Analysis b.
Summary Information for CRGR - Proposed Mark I Containment Enhancements (in accordance with Section IV.B. of the CRGR Charter).
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l c.
Memorandum, dated December 9, 1988, F.P. Gillespie to R.W. Houston, transmitting NRR comments on proposed Mark I enhancements package.
?
l 2.
At Meeting No. 152, the staff provided to CRGR revisions to items 1.a.
I and 1.a.iv. above, reflecting the NRR comments noted in item 1.c. above and also OGC comments.
For completeness of record, those revisions are included as part of these minutes (Attachment 2 to this Enclosure).
CONCLUSIONS / RECOMMENDATIONS i-The Committee did not complete their review of the Mark I package at Meeting No. 152., due to the following:
1.
The staff requested in their presentation to the Committee at this meeting that CRGR not review the proposed Generic Letter (Background Item 1.vii.
above), to allow the staff time to more fully consider OGC comments just received and to examine further the means implementing the proposed Mark I upgrades, i.e., rulemaking and generic letter.
In a brief preliminary discussion of these aspects of the overall approach to be taken in implementing the recommended Mark I improvements, the Committee expressed a preference for a rulemaking (to be followed by issuance of an implementing Generic Letter) as the proper course of action in this matter.
These legal issues will be addressed for review by CRGR at a future meeting.
2.
The Committee also identified several major technical issues that need to be further addressed and clarified for the Committee at a subsequent meeting, as follows:
a.
In the Regulatory Analysis that accompanies this package, the staff's recommended Alternative (vi) e7 visions acceleration of implementation of the Station Blackout rule by reducing the time required for NRC staff review and approval of licensee SB0 submittals.
The Committee questioned whether significant acceleration is actually achievable in view of practical considerations (e.g., lead times for procurement / installation of major plant upgrade equipment items) that are likely to be more controlling of the overall SB0 rule implementation schedule than any shortening that might be achieved in the staff's review schedule.
There is even the possibility that an inadequately considered / coordinated attempt to accelerate implementation of the carefully-crafted SB0 final resolution (arrived at on the basis of extensive interaction, and careful coordination with cognizant industry groups like NUMARC and the Nuclear Utility Group on Station Blackout),
might result in confusion and actually delay or interfere with the 580 rule implementation process.
The staff should carefully reexamine the basis and extent of the estimated benefits from this aspect of the Mark I package, b.
The Committee questioned whether the Mark I improvements, as currently proposed, interfere with or undermine the IPE process specified in the recently-issued IPE Generic Letter.
The Mark I package proposed earlier concentrated on mitigative-type modifications to the containment systems themselves (e.g., the hardened vent, and backup water supply for drywell sprays) as the recommended means of improving Mark I severe accident
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The current package includes preventive-type modifications to some important reactor systems (e.g., ADS improvements, and backup water supply for low pressure reactor vessel injection).
The rationale offered earlier, for imposing (in advance of IPE performance) readily-recognized,.relatively-inexpensive, mitiga*ive-type improvements to containment systems only, was that such approach would not really interfere with or undermine the IPE process, because.
current technical understanding of relevant containment failure phenomena / issues would not allow complete treatment of "back end" (i.e., containment) issues in a comprehensive IPE at this time anyway.
While this rationale may be valid for the more restricted, mitigative measures proposed earlier that would affect just containment systems, the Committee was concerned that the current proposals would affect the ongoing and planned IPE work on selected reactor plant systems.
c.
In the CRGR review of the final Station Blackout resolution package at Meeting No. 115, the staff agreed that licensees could fully satisfy the proposed Station Blackout rule by installing an " alternate AC" source, i.e., an additional, independent onsite AC power cource (e.g., an added diesel generator) that could be demonstrated to be available within about 10 minutes of the onset of a station blackout condition.
Such an " alternate AC" source would result in a very high level of reliability in a plant's onsite AC power system, to such a degree in fact that no detailed analysis of SB0 coping capability would be required of licensees who provided that option in response to the SB0 rule.
(See Attachment 3 to this Enclosure.) In discussions with the Committee at this meeting, the staff stated that a number of additional small, independent (dedicated) power sources are expected to be required to satisfy proposed Mark I improvements, even if a licensee already plans to install a fully-credited " alternate AC" l
power source in implementing the SB0 rule.
Some additional requirement for power sources beyond that needed to satisfy the 5B0 rule could act as a serious disincentive for licensees to consider or follow through now with plans' for installing an " alternate AC" source.
The Committee questioned the need for such stringent requirements in connection with the proposed Mark I upgrades.
The staff was asked to clarify this point in the planned followup discussions.
(The staff should be prepared to justify such stringent criteria / requirements in connection l
with proposed Mark I improvements that are not claimed to be required for adequate safety.)
d.
The staff's recommended Alternative (vi) appears to combine separable i
backfit measures which by themselves are not cost beneficial (e.g.,
l rule acceleration, ADS improvements, backup water supply for low pressure RV injection, etc.), together with a clearly-justifiable backfit (hardened vent), in a manner that seems not to be consistent with the intent of the CRGR Charter (i.e., to maximize the effective-ness of both NRC and industry resources expended for separable proposed backfits).
The staff's value-impact and cost-benefit analyses need to be clarified for each separable element of Alternative (vi), along the lines presented in the " DRAFT RISK BENEFITS" slide in Attachment 1 to i
_ 4_
this Enclosure, in order to allow the Committee to properly evaluate
. (1) whether, in' fact, some of those elements can/should be separated out, and (ii) more exactly, what are the costs and benefits associated with the separable ciements.
The staff should reexamine the Mark I package in the areas indicated above, and should resubmit it for CRGR review after appropriate revision to take into account the Committee's comments and recommendations.
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BRIEFING ON BWR MARK 1 CONTAINMENT IMPROVEMENT PROGRAM BEFORE CRGR DECEMBER 14, 1988 WAYNE HOUSTON WILLIAM D. BECKNER LEONARD SOFFER JOHN N. RIDGELY OFFICE OF NUCLEAR REGULATORY RESEARCH U.S. NUCLEAR REGULATORY COMMISSION
BACKGROUND o
JUNE 1986, STAFF PROPOSED 5 ELEMENT PROGRAM FOR MARK 1 CONTAINMENT PERFORMANCE ENHANCEMENT o
JUNE-JULY 1987, TWO LICENSEES INFORMED THE STAFF 0F THEIR INTENTION TO INVESTIGATE CONTAINMENT AND SAFETY ENHANCEMENT o
JULY 1987. STAFF BRIEFED COMMISSION ON A PLAN FOR CLOSURE OF SEVERE ACCIDENT ISSUES o
DECEMBER 1987, " MARK 1 CONTAINMENT PERFORMANCE PROGRAM PLAN",(SECY-87-297) o FEBRUARY 1988, WORKSHOP ON MARK I ISSUES o
MAY 1988, " INTEGRATION PLAN FOR CLOSURE OF SEVERE ACCIDENT ISSUES", (SECY-88-147) 0 JULY 1988, " STATUS OF MARK 1 CONTAINMENT PERFORMANCE EVALUATION", (SECY-88-206) o DECEMBER 6, 1988, MARK 1 CPI BRIEFING TO ACRS SUBCOMMITTEE ON CONTAINMENT SYSTEMS 2
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CONTAINMENT PERFORMANCE IMPROVEMENT PROGRAM 1
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o OBJECTIVE:
l DETERMINE WHAT ACTIONS, IF ANY, SHOULD BE TAKEN TO REDUCE VULNERABILITY OF CONTAINMENTS TO SEVERE ACCIDENT CHALLENGES o
STAFF EFFORTS FOCUSED INITIALLY ON MARK l'S 1
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OTHER CONTAINMENT TYPES TO BE ADDRESSED, AS WELL l
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PRA INSIGHTS FOR MARK 1 4
o DOMINANT ACCIDENT INITIATORS (INTERNAL) ARE:
STATION BLACK 0UT (SBO)
ATWS LOSS OF DECAY HEAT REMOVAL (TW)+
o WIDE VARIATION IN ACCIDENT LIKEllH00D o
FURTHER REDUCTIONS IN SEVERE ACCIDENT RISK VIA ACCIDENT PREVENTION AND MITIGATION (BALANCED APPROACH) POSSIBLE o
IMPLEMENTATION OF ADEQUATE VENTING PROCEDURES CAN REDUCE THE CORE MELT FREQUENCY FOR TW SEQUENCES BY AN ORDER OF MAGNITUDE OR MORE
+1N THE ABSENCE OF WETWELL VENTING 6
L.~
l BWR MARK I CONTAINMENT CHALLENGES o
CONTAINMENT COULD BE CHALLENGED BY LARGE SCALE CORE MELT, PRINCIPALLY DUE TO SMALLER SIZE o
SEVERAL EARLY CONTAINMENT FAILURE MODES IDENTIFIED o
SOME POSTULATED CONTAINMENT FAILURE MODES ARE HIGHLY UNCERTAIN, ESPECIALLY LINER MELT-THROUGH l
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SUMMARY
OF FEB. 24-26. 1988 BWR MARK I WORKSHOP l
0 THREE-DAY MEETING WITH 150 INDUSTRY, RESEARCHER, STAFF AND PUBLIC REPRESENTATIVES o
INDUSTRY EMPHASIS ON PREVENTION.
ANY FIXES SHOULD BE PLANT SPECIFIC FROM IPE l
0 VARIETY OF VIEW ON PROBABILITY OF LINER MELT-THROUGH MANNER OF VESSEL FAILURE AND RELEASE OF DEBRIS IMPORTANT INDUSTRY BELIEVES WATER CAN PREVENT LINER MELT-THROUGH WATER BENEFICIAL, BUT NO CONSENSUS FROM NRC RESEARCHERS ON WHETHER LINER FAILS AND WHEN o
GENERAL AGREEMENT--WATER IN DRYWELL USEFUL TO DELAY / PREVENT SHELL FAILURE AND TO REDUCE FISSION PRODUCT RELEASES o
AGREEMENT THAT ADS RELIABILITY IMPORTANT.
IMPROVEMENTS ACHIEVABLE AT MODEST COST o
POTENTIAL POSITIVE AND NEGATIVE SAFETY IMPACTS OF VENTING REDUCE CORE-MELT LIKELIHOOD, REDUCE CONSEQUENCES, BUY TIME POTENTIAL FOR UNNECESSARY RELEASE, INCREASE CORE-MELT LIKEllH00D FOR SOME SEQUENCES o
CONTINUED RESEARCH NEEDED ON IN-VESSEL AND EX-VESSEL ACCIDENT PROGRESSION EFFECT OF WATER ON PROBABILITY OF LINER MELT-THROUGH EFFECT OF WATER ON SOURCE TERMS 9
l J
1 CORE DEBRIS CONTROLS
)
1 o
TECHNICAL FEASIBILITY OF CURBS ~lN DRYWELL AND/0R CURBS OR WEIR WALLS IN TORUS ROOM NOT YET ESTABLISHED.
o INSTALLATION COSTS, OCCUPATIONAL EXPOSURE BELIEVED l
SIGNIFICANT l
0 GROWING BELIEF THAT WATER IN DRYWELL MAY HELP TO PREVENT OR AT LEAST DELAY LINER MELT-THROUGH o
WATER IS EFFECTIVE IN REMOVING (SCRUBBING) FISSION PRODUCT AEROSOLS o
STAFF WILL PURSUE RESEARCH TO CONFlRM THAT LINER MELT-THROUGH IS UNLIKELY IN THE PRESENCE OF WATER EXCEPT FOR MASSIVE POUR RATES OF LARGE METALLIC CONTENT AT HIGH SUPERHEAT 10
7_- _
STAFF APPROACH BALANCED APPROACH T0-REDUCE OVERALL RISK ACCIDENT PREVENTION REDUCE THE LIKELlH00D OF AN ACCIDENT OCCURRING ACCIDENT MITIGATION REDUCE THE CHALLENGE TO CONTAINMENT AND THE MAGNITUDE OF RADI0 ACTIVE RELEASES TO ENVIRONMENT i
i 11
l
SUMMARY
OF STAFF
)
RECOMMENDATIONS FOR MARK 1 o
ACCELERATE IMPLEMENTATION OF STATION BLACK 0UT RULE (ATWS IMPLEMENTATION TO BE ESSENTIALLY COMPLETE BY 1/89) o REQUIRE ALTERNATE WATER SUPPLY FOR DRYWELL SPRAY / VESSEL INJECTION WITH PUMPING CAPABILITY INDEPENDENT OF. NORMAL AND EMERGENCY AC o
REQUIRE HARDENED VENTING CAPABILITY FROM WETWELL (ABLE TO WITHSTAND SEVERE ACCIDENT PRESSURES).
' ISOLATION VALVES TO BE REMOTELY OPERABLE INDEPENDENT OF NORMAL AND EMERGENCY AC.
o REQUIRE ENHANCED ADS RELIABILITY, ADDITIONAL POWER AND/OR NITROGEN SUPPLY AND CABLE RELIABILITY o
REQUIRE IMPLEMENTATION OF IMPROVED EPG'S (REV. 4 0F BWROG)
I 12
ALTERNATE WATER SUPPLY i
o ALTERNATE SUPPLY OF WATER PLUS PUMPING CAPABILITY INDEPENDENT OF NORMAL AND EMERGENCY AC POWER o
WATER DEllVERY AVAILABLE EITHER INTO REACTOR VESSEL (VIA RHR SYSTEM) OR TO DRYWELL SPRAYS o
ALTERNATE SOURCE OF WATER FOR INJECTION INTO REACTOR VESSEL REDUCES LIKEllH00D OF CORE MELT AND PROVIDES ADDITIONAL IN-VESSEL ACCIDENT MANAGEMENT CAPABILITY o
WATER FOR DRYWELL SPRAY PROVIDES SIGNIFICANT MITIGATION CAPABILITY TO COOL CORE DEBRIS, COOL CONTAINMENT LINER, AND SCRUB AIRBORNE FISSION PRODUCTS E
l u_
I IMPROVED VENTING CAPABILITY o
VENTING CURRENTLY INCLUDED IN BWR EMERGENCY OPERATING PROCEDURES
.o.
HARD PIPE VENT WOULD REPLACE PRESENT SHEETMETAL DUCT TO WITHSTAND SEVERE ACCIDENT PRESSURES o-VENT' ISOLATION VALVES TO BE REMOTELI'0PERABLE FROM CONTROL ROOM o
VENTING CAN REDUCE LIKELIHOOD OF CORE MELT FROM LOSS OF LONG-TERM DECAY HEAT REMOVAL o
VENTING VIA SUPPRESSION P00L WILL SCRUB NON N0BLE GAS FISSION PRODUCTS PRIOR TO RELEASE p
1 d
a_ __-__ _-
. i --..
o N
)
u i-ENHANCED ADS RELIABILITY o
T0 INCREASE. RELIABILITY, ADDITIONAL DC POWER SOURCE NEEDED.
MAY NEED ADDITIONAL NITROGEN SUPPLY NEED TO REVIEW CABLE PERFORMANCE o
BENEFITS
-WITH ENHANCED ADS RELIABILITY, AN ADDITIONAL SOURCE OF LOW PRESSURE WATER INJECTION BECOMES AVAILABLE FOR CORE COOLING
-LOW REACTOR PRESSURE REDUCES LIKEllH00D OF HIGH PRESSURE MELT EJECTION IN EVENT OF PRESSURE VESSEL FAILURE 15
w:
s' 4
EMERGENCY PROCEDURES AND TRAINING 1
l 0
MAJOR ELEMENT IN MARK 1 CONTAINMENT PERFORMANCE IMPROVEMENT PROGRAM-i i
o STAFF RECENTLY APPROVED REV. 4 0F BWROG EPG's.
SIGNIFICANT IMPROVEMENT OVER EARLIER VERSIONS.
NEW EPG's EXTEND WELL BEYOND DESIGN BASIS EVENTS, INCLUDE MANY ACTIONS APPROPRIATE FOR SEVERE ACCIDENT MANAGEMENT o
. IMPROVEMENT IN EPG's HAS TO BE REFLECTED IN PLANT-SPECIFIC E0P's AND IN OPERATOR TRAINING.-
IMPLEMENTATION PRESENTLY VOLUNTARY.
PROPOSE TO MAKE MANDATORY.
16
3 I
INDUSTRY EFFORTS e
o NRC STAFF RECENTLY APPROVED' REVISION 4 TO THE EPG's, PROPOSED BY BWROG.
THESE INCLUDE VENTING OF CONTAINMENT o
VERMONT YANKEE PLANNING CHANGES DURING 1989 REFUELING.
4 0UTAGE, INCLUDING:
1
- USE OF DIESEL FIRE PUMP FOR DECAY HEAT REMOVAL
- DIESEL DRIVEN AIR COMPRESSOR TO SRV's l
- MODIFICATION OF E0P's
- UPGRADE OF SIMULATOR l
0 PILGRIM HAS DEVELOPED A SAFETY ENHANCEMENT PROGRAM WHICH INCLUDES:
- HARD PIPE VENT FROM TORUS TO STACK (PRESENTLY NOT CONNECTED)
- THIRD ONSITE DIESEL GENERATOR
- BACKUP NITROGEN SUPPLY FOR ADS AND MAINTAINING CONTAINMENT INERTED
- USE OF FIRE PROTECTION DIESEL PUMPS FOR DECAY HEAT REMOVAL 17 j
= _ _ _ _ _ _ _
i
l BACKFIT CONSIDERATIONS o
SOME OF STAFF PROPOSALS INVOLVE PLANT BACKFITS.
THESE ARE COVERED BY BACKFIT RULE (10 CFR 50.109) o BACKFIT RULE PERMITS BACKFITTING WHEN CHANGE
- RESULTS IN SUBSTANTIAL INCREASE IN OVERALL PROTECTION OF PUBLIC HEALTH AND SAFETY ANJ1
- DIRECT AND INDIRECT COSTS OF THE CHANGE ARE JUSTIFIED IN VIEW 0F INCREASED PROTECTION 18
BENEFIT OF IMPROVEMENTS
-c o
MAJOR BENEFIT IS REDUCTION IN CORE MELT FREQUENCY OF ABOUT ONE ORDER OF MAGNITUDE o-LARGE PORTION OF CORE MELT. REDUCTION DUE TO IMPROVED VENTING o
ACCIDENT MITIGATION ALSO SIGNIFICANT
- VENTING PREVENTS CONTAINMENT FAILURE RESULTING FROM SLOW OVER-PRESSURE
- VENTING VIA SUPPRESSION POOL PROVIDES FISSION PRODUCT
. SCRUBBING
- WATER IN DRYWELL MAY COOL DEBRIS, DELAY LINER FAILURE, SCRUB FISSION PRODUCT RELEASES 4
19
I i
ESTIMATED COSTS AND BENEFITS ESTIMATED COSTS * (PER PLANT)
RANGE - 1.6 TO 3.1 MILLION DOLLARS BEST ESTIMATE - 2.0 MILLION DOLLARS ESTIMATED BENEFITS ** (PER PLANT)
RANGE - 2.9 TO 23 MILLION DOLLARS SIMILAR IMPROVEMENTS AT ONE MARK 1 PLANT MAY HAVE COST ABOUT 7.3 MILLION DOLLARS.
- BASED UPON 1000 DOLLARS PER PERSON-REM AND A REMAINING PLANT LIFE OF 20 YEARS 20
COST-BENEFIT RESULTS OF ALTERNATIVES (MAN-REM AVERTED PER MILLION DOLLARS)
DO NOTHING 0
ACCELERATE RULE IMPLEMENTATION (ARI) 994 ONLY ARI + IMPROVED ADS RELIABILITY 228 TO 57*
AR1 + CONTAINMENT SPRAYS / LOW 148 TO 49*
PRESSURE INJECTION (CS)
ARI + HARDENED VENT SYSTEM 7929 TO 3238' ARI + VENTING + ADS + CS 3622 TO 1570
- RANGES DUE TO EFFECTS OF TW FREQUENCY (10-4 TO 10-5) AND TWO INSTALLATION COST ESTIMATES.
21
J....
.g.
CQST-BENEFIT RESULTS (MAN-REM AVERTED PER MILLION DOLLARS)-
LOW RISK PLANT (TW=10-5)
. LOW-INDUSTRY COSTS
- 1570***
HIGH INDUSTRY COSTS **
404 LHIGHRISKPLANT-(TW=10-4)
LOW INDUSTRY. COSTS
- 22,316 HIGH INDUSTRY COSTS ***
3,622 LOW lNDUSTRY COST IS ESTIMATED TO BE $48 MILLION-1 l
- HIGH-INDUSTRY COST IS ESTIMATED TO BE $176 MILLION 1:.
- lHCLUDES AVERTED ON-SITE COST OF CLEANUP, REPAIR AND REPLACEMENT POWER 22
.2
(:<.-
COST-BENEFIT CONCLUSIONS o
VALUE/lMPACT IS. AFFECTED BY A FACTOR OF-ABOUT 'll DEPENDING ON ESTIMATED lNDUSTRY COSTS.
HOWEVER, THE VALUE/ IMPACT RESULTS SUPPORT IMPLEMENTATION OF PROPOSED CONTAINMENT IMPROVEMENTS.
o' VALUE/ IMPACT IS NOT SIGNIFICANTLY AFFECTED BY ASSUMED VALUE OF REAL INTEREST RATE.
o VALUE/ IMPACT IS LITTLE AFFECTED (10%) BY INCLUSION OF AVERTED ONSITE COSTS.
23' l
l 1
I l
CONCLUSIONS AND RECOMMENDATIONS i
o PROPOSED ENHANCEMENTS PROVIDE SUBSTANTIAL INCREASE IN i
OVERALL PROTECTION OF PUBLIC HEALTH AND SAFETY c
o PROPOSED Et4HANCEMENTS ARE GENERALLY COST BENEFICIAL 1
o PROPOSE T0 IMPLEMENT VIA RULEMAKING o
CONTINUE CONFIRMATORY RESEARCH ON PHENOMENA RELEVANT TO IN-VESSEL AND EX-VESSEL ACCIDENT PROGRESSION, THE EFFECT OF CAVITY WATER ON THE PROBABILITY OF LINER MELT-THROUGH, AND ASSOCIATED SOURCE TERMS 24
L
. to the Minutes of CRGR Meeting No. 152 Regulatory Guides 3.6.1, and 3.6.2, and a Certificate of Compliance Topic B. Morris (RES), W. Lahs (RES), and J. Roberts (NMSS) presented for CRGR review two draft regulatory guides which address the format and content for safety analysis reports related to the onsite dry cask storage of spent fuel and the certificate of compliance which will be incorporated in 10 CFR Part 72 rulemaking.
A copy of the slides used by the staff is attached to this enclosure.
Background
The Committee previously met to review the 10 CFR Part 72 rulemaking on November 9, 1988 at CRGR Meeting No. 150.
The Committee requested, at that time, that additional material be supplied for review.
The material supplied included:
1.
Draft Reg. Guide 3.61, Standard Format and Content for a Topical Safety Analysis Report for a Spent Fuel Dry Storage Cask.
2.
Draft Reg. Guide 3.62, Standard Format and Content for the Safety Analysis Report for Onsite Storage of Spent Fuel Storage Casks.
3.
Draft Certificate of Compliance for the General Nuclear Systems, Inc.
Model No. CASTOR V/21 dry spent fuel storage cask.
Conclusions / Recommendations As a result of their review of this matter, including discussions with the staff at this meeting, the Committee made the following recommendations:
1.
In section 2.0, Functional and Operating Limits, of the Certificate of Compliance several concerns were raised, a.
2.1.1(7) - clarify what is meant by gross cladding defects to assure that licensees understand this requirement.
b.
2.1.1(9) clarify when the initial identity of the assembly is determined to make it clear that it is immediately prior to cask loading.
2.
Under section 2.4, Dry Storage Cask Surface Contamination, and 3.2, Cask Contamination, the radioactivity limits should be consistent with trans-portation limits and correct the basis section of 3.2 to be consistent with the language used in section 2.4.
The staff requested waiver of CRGR review of the three other certificates of compliance.
The Committee recommended in favor of forwarding the proposed rule and accompanying certificates of compliance provided the recommended changes are included in all four certificates.
1 A TTde M ine'r a rb e in resue e c
l CRGR BRIEFING DECEMBER 14, 1988 STORAGE OF SPENT NUCLEAR FUEL IN NRC-APPROVED STORAGE CASKS AT NPP SITES RESPONSE TO CRGR RECOMMENDATIONS BASES FOR GENERAL AND SPECIFIC LICENSING FOR ONSITE CASK STORAGE REG GUIDES 3.62 AND 3.61 1
p..
1,.
1 1
RESPONSE TO CRGR RECOMMENDATIONS l
9.72.216 REPORTING REQUIREMENTS PR MODIFIED TO REFER TO NEW SS 50.72(B)(2)(VII)(1)
~
l REFERENCES.TO NRC, I.E. AUTHORITY ASSURING COMPLIANCE RI AND SITE-RELATED INSPECTIONS DELETED RECORDS ~ON CASK-REPAIRS ELIMINATION OF DISCUSSION DESCRIBING NRC USE OF
. LICENSEE NOTICE OF FIRST USE TO ESTABLISH INDEPENDENT RECORD REVISED LANGUAGE IN 972.236 ELIMINATION OF " TECHNICAL SPECIFICATION" TERMINOLOGY CLARIFICATION OF (F), HEAT REMOVAL CAPABILITY W/0 ACTIVE COOLING 2
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- REG GUIDE 3,61 - STANDARD FORMAT AND CONTENT FOR I
A TSAR FOR'A SPENT FUEL rJY-STORAGE CASK-1 HISTORY l
INITIATED.IN.1983, ISSUED FOR COMMENT:1986 GUIDE PROCESSING' HALTED IN 1986 PENDING PART 72 REVISION CURRENTLY 4TH PMU AT BRANCH LEVEL - BEING REVISED TO INDICATE THAT ALTERNATIVES EXIST REGARDING NEED FOR SITE-SPECIFIC INFORMATION i
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ENVIRONMENTAL CONDITIONS AND NATURAL PHENOMENA
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CONFINEMENT, EQUIPMENT 8 INSTRUMENTATION, l
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1 STRUCTURAL, THERMAL, SHIELDING, CRITICALITY,-
f CONFINEMENT l
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RADIATION PROTECTION 1
ACCIDENT ANALYSIS QUALITY ASSURANCE 5
REG GUIDE 3,62 - STANDARD FORMAT AND CONTENT FOR THE SAR FOR ON-SITE STORAGE OF SPENT FUEL STORAGE CASKS SAME HISTORY AS RG 3.61 SPECIFICALLY MAKES POINT THAT MUCH INFORMATION IN REACTOR FSAR AND CASK TSAR CONTENTS OF GUIDE TOPICS COVERED IN NPP FSAR AND CASK TSAR 1
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- PEACTOR OPERATORS
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ERTIFICATE OF COMPLIANCE
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