ML20246G057
| ML20246G057 | |
| Person / Time | |
|---|---|
| Issue date: | 03/08/1989 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-2627, NUDOCS 8905150178 | |
| Download: ML20246G057 (28) | |
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.3//o t1 Advisory Committee on Reactor Safeguards Thermal Hydraulic Phenomena Subcommittee Meeting Minutes March 7, 1989 Bethesda, Maryland
Purpose:
The purpose of the meeting was to review the NRC Staff's l
proposed policy statement on additional applications of leak-before-break (LBB) technolooy.
Meeting Attendees: The principal meeting attendees included:
ACRS NRC D. Ward, Chainnan R. Bosnak I. Catton, Member J. O'Brien W. Kerr, Member K. Wichman C. Michelson, Member C. Siess, Member C. Wylie, Member BNL P. Boehnert, Staff W. Horak CE W
E. Siegel B. McIntyre D. Ayres W Owners Group CE Owners Group G. Kammerdeiner D. Williams (Dukuesne Light Co.)
l Northern States Power Co.
J. Neils MOl l
I DESIGNATED ORIGINAL 8905150178 890308
- f/_./g' Certified By PDR ACRS PDC 2627 J
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T/H Phenomena Mtg Minutes March 7, IS89 Meeting Highlights, Agreements, and Requests 1.
Mr. Ward noted that the purpose of the meeting is to review.SECY-88-325 " Policy Statement on Additional Applications of Leak-Before-Break Technology."
The Chairman recounted the history of the development of the leak-before-break (LBB) broadscope (BS) Rule by the NRC Staff in 1987.- Mr. Ward noted that the suggestion was made at the time of the BS rule revision that LBB technology could be applied to other areas such as ECC systems and environmental qualification (EQ) issues.
Mr. Ward said the central topic of today's meeting is whether sufficient incentives exist for the industry to extend LBB tech-nology to other areas such as those noted above. The Chairman noted that the NRC Staff has recommended that LBB not be extended to other areas at this time.
He also indicated that upon reading the public comments received on this issue he believes one could take issue with the Staff position.
Mr. Ward said he would solicit the opinions of the Subcommittee members at the conclusion of the meeting presentations regarding what further actions (if any) the Subcommittee / Committee should take concering this issue.
The Chairman noted receipt (today) of a letter to himself from the Nuclear Utility Group on Equipment Qualification (NUGEQ) providing comments on the need for rulemaking regarding EQ and asked the Members to review the NUGEQ comments during the meeting.
Mr. Ward also discussed a study he had BNL perform which explored the dependency of PCT and containment conditions on assumed
T/H Phenomena Mtp Minutes March 7,.1989 -
characteristics of a LB-LOCA.
He said Mr. W. Horak (BNL) will make a presentation during this meeting on the results of this study.
2.
R. Bosnak (NRC-RES) discussed the NRC policy statement on addi-tional applications of LBB policy (SECY-88-325). He reviewed the Chronology of the development of the GDC-4 BS rule and the develop-mentofSECY-88-325(Figures 1-4).
Mr. Ward, noting that NRC excluded use of LBB for piping evidencing IGSCC, asked for the staff's rationale here. Mr. Bosnak and Mr.
l K. Wichman indicated that the presence of IGSCC invalidates the assumption that a leakage flaw will remain stable and not grow or "run" to a larger break than that postulated for LBB.
In response to questions from Dr. Siess, NRC indicated that it could not be assured that piping subject to fatigue cracking would not cata-trophically fail, given an initiator (e.g., water hammer, earth-quake,etc.).
-i Dr. Siess noted that NRC is willing to accept empirical evidence regarding the rate of piping failures due to water hammer, erosion-corrosion, etc., but does not accept such evidence for the double-ended guillotine rupture.
Mr. Bosnak discussed the safety benefits identified with respect to EQ. He noted that the increased service life of electrical equip-ment is an expected benefit if the less harsh environmental profiles resulting from application of LBB are used. Longer service life implies less replacement and changeout and, therefore, less radiation exposure for workers. Moreover, frequent equipment changeout can reduce safety due to potential errors while install-ing new equipment. However, these benefits will not be obtained inside the containment unless most large diameter high energy lines
T/H Phenomena Mtg Minutes March 7, 1989 l
satisfy LBB requirements. This is very unlikely. Outside the.
containment, there is less interest by industry because the EQ profiles are generally less severe.
NRC noted their receipt of the March 3,1989 letter from the NUGEQ.
Mr. Bosnak noted that NRC would welcome an initiative by the industry to develop a generic profile for EQ exemptions. NRC has in place allowance for EQ exemptions via the current LBB rule.
They are reluctant to initiate new rulemaking, absent a generic EQ profile.
NRC indicated that the safety benefits are only poten-tial, and may not be realized either inside or outside the contain-ment because of the applicability of LBB in specific systems.
For the issue of applying LBB to the ECCS system, the potential benefits of reduction of quick starts for the EDG's and reduced radiation embrittlement of the RPV were noted. Mr. Bosnak noted that these benefits can be achieved via the revised ECCS rule now in place. Further, if leak-before-break is applied to ECCS perfor-mance requirements, a replacement for the instantaneous double-
. ended rupture of the RCS is needed. Resources must be expended in developing new pipe break sizes.
Mr. Ward noted that a recent NSAC report on use of gas turbines versus diesel generators for emergency power indicated that gas turbines can't meet the new start times even under the revised ECCS rule.
He indicated that LBB may help here, in conjunction with the use of the revised ECCS rule, as gas turbines may be a more reli-able emergency power source.
In response to Dr. Siess, Mr. Bosnak noted there is indeed a dichotomy in the regulations vis-a-vis treatment of pipe breaks between GDC-4 and the ECCS rule (LBB vs instantaneous pipe rupture).
i
T/H Phenomena Mtg Minutes March 7, 1989 In response to Mr. Michelson, Mr. Bosnak said that ECC requirements may not be relaxed if the double ended rupture is eliminated and, in any respect, the results may be plant-specific.
In response to Dr. Siess, Mr. Wichman indicated that none of the advanced LWR designs have invoked LBB.
In response to another question from Dr. Siess, Mr. Bosnak said that the Commission has mandated that any modifications of LBB requirements be based on enhancing safety. NRC also indicated that the mandate from Con-gress is that priority must be given to licensing / regulatory issues that enhance safety.
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3.
W. Horak (BNL) overviewed a parametric study-requested by Mr. Ward, the purpose of which was to determine the effect of break opening time on peak clad temperature and containment pressure and tempera-ture for intermediate to large breaks.
Figure 5 lists the parame-ters of the study, and Figures 6-8 outline the code model for the primary system, core and containment parameters. The RELAP-5/ MOD 2 (Cycle 36) code was used.
In some cases, runs were terminated earlier than desired because of problems with the code.
Figure 9 summarizes the results of the study. Mr. Horak noted an anomaly for the PCTs in the base case runs (i.e., the PCT values increased slightly for increased break opening times). He did not have time to explore the reason for this anomaly. Aside from this point, there were not real surprises; the PCT's, containment temperatures, and containment pressures " behaved" as expected. Mr.
Horak summarized that for the same break flow area, the peak values of the containment temperature and pressure do not vary signifi-cantly with break opening time, i
Mr. Ward, referring to the anomaly noted above, indicated that this result has been seen in other calculations as Appendix K requires I
T/H Phenomena Mtg Minutes March 7, 1989 PCT calculations over a range of break sizes. Dr. Catton indicated that the above anom: lies are essentially code-related.
4 Mr. D. Ayres (CE) lead off the CE/CE Owners Group presentation on extention of LBB technology.
Key points noted by Mr. Ayres were:
- CE believe:; in LBB technology. They have conducted extensive studies on the phenomena associated with LBB technology.
These phenomena are "real".
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- CE has demonstrated LBB for both the main coolant loops and the pressurizer surge line under stratified flow conditions for the Korean CE plants. CE has also recently provided a submittal to NRC to consider LBB for the main steamline (inside containment). NRC has agreed the MSL is a candidate for LBB consideration.
Mr. E. Siegel (CE) reviewed the near-term future applications of LBB as CE sees them. These are:
- Environmental qualification of equipment.
- Containment pressure and temperature profile.
Emergency core cooling system requirements.
Mr. Siegel outlined an approach to allow extension of LBB.
Figure 10 details this approach.
Mr. Ward asked what CE believes it needs from NRC to satisfy the regulatory requirements here. Mr. D. Williams (AP&L - representing the CE0G) indicated that a lot of the LBB safety benefits are
T/H Phenomena Mtg Minutes March 7, 1989 conjective at this time.
If NRC is not receptive to their sub-mittals, the licensees really can't move forward. He also said the revised review fee schedules are also a potential impediment. Mr.
Ward said it seems we are going around in circles as NRC maintains the' industry hasn't shown any interest in LBB, and the industry is saying NRC is not being receptive.
Mr. Williams discussed four areas where the CEOG sees potential benefits of extending LBB applicability. These areas are:
Containment building integrity.
Environmental qualification of equipment.
Emergency operating procedures.
- Plant equipment / operational flexibility.
Figures 11-14 detail the potential benefits for each of these four areas.
The Subcommittee questioned the benefits to be obtained from relaxation of EQ requirements. Mr. Williams said they do not know at this time whether there are benefits or not but believe its worth a look, given the potential to both enhance safety and reduce costs.
In conclusion, the CEOG recommends that the option be available to pursue extension of applicability of LBB. Mr. Michelson suggested j
.the burden is on the OG to provide a hard fact case to NRC for review. Mr. Williams said the OG must be assured of a fair hearing by the Staff before they commit the necessary (up-front) resources, and they are not convinced this is the case at this time.
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- s T/H Phenomena Mtg Minutes March 7,1989 Dr. Kerr suggested that the CE0G encourage their licensees to complete their PRA's (via the IPE process) in order to be in a position to focus their energies on the true risk contributors.
5.
Mr. G. Neils (Northern States Power) provided some comments on the issue of extension of LBB.
Key points made by Mr. Neils included:
Rule changes are necessary in order to assure the industry can i
come forward with revised /new LBB application submittals, given the up-front cost risk involved, particularly if NRC does not accept the submittal for review.
For EQ considerations, the current requirements are overly restrictive as any incident of EQ non-compliance can result in forced shutdown irrespective of the probability of a LB LOCA.
Three incidents were cited at NSP plants where modifications to plant systems outside containment were mandated as a result of EQ requirements. The thrust of the examples cited was that these (expensive) fixes were really not justified if LBB was considered on a realistic basis.
- The impact of all the fixes required to comply with NRC requirements has resulted in the depreciated book value of the NSP plants to increase over the years.
In response to ques-tions from Mr. Michelson, Mr. Neils said he believes what is needed is a change in the regulations so that one doesn't have to fight an uphill battle to require an exemption from the EQ rule.
6.
B. McIntyre (g) discussed the applications of LBB to y plants. W reviewed LBB for:
(1)applicationtoydesignedplants,(2) impact on operating plants (safety injection systems, containment systems,
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T/H Phenomena Mtg Minutes March 7, 1989 and environmental qualification), (3) potential impact on new plants, and (4) impact of approved Appendix K ECCS models and best-estimate methodology (Appendix K Rule change).
For current LOCA analysis considerations, Mr. McIntyre noted that for LB LOCA (> 1 sq ft) - fluid behavior is dominated by inertial effects and for intermediate breaks (1 sq ft > B.>8 in dia), fluid
- behavior is influenced by inertia and gravity.
Intermediate breaks have received limited attention and may become limiting when LB LOCA is eliminated. Small breaks (5 8 in) give low flow rates, slow depressurization and distinct mixture levels.
2 W noted that if the DBA LOCA can be reduced to.* one ft, it may be possible to impact the safety injection systems as follows:
' Benefits in reliability may be realized by modifying tech spec SI flow rates and justifying less severe diesel generator start times.
- Comparative benefits may also be obtained from applying advanced LOCA modeling technology.
However, existing SI system equipment remains necessary for the current operating plants.
In summary, W sees the major benefits to be gained by applying the revised ECCS rule (not LBB) to current plants.
Concerning the impact of LBB on containment systems and environ-mental review, Mr. McIntyre indicated that the benefits here are l
minimal (Figure 15).
In response to Mr. Ward, Mr. McIntyre said W i
has not considered the impact of LBB on emergency operating proce-dures.
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T/H Phenomena Mtg Minutes March 7,1989 Li.
Looking at the W new plant designs, Mr. McIntyre said that assuming use of LBB, the HPSI could be eliminated or reoptimized for the APWR.
For the AP 600 design, the accumulators could be eliminated.
In conclusion, W sees the following benefits for current W plants:
.(1) relaxation in tech spec peaking factors, (2) increased reli-l ability from increased emergency diesel start times, and (3) a somewhat reduced EQ envelope. Use of the revised ECCS rul.e (in-stead of LBB) provides the greatest benefit for current plants.
In response to Mr. Ward, Mr. McIntyre indicated that for calcu-lation of intermediate break LOCA PCT's, the results are bounded by the LB LOCA.(e.g., 1000 F vs ~ 2200'F).
7.
G. Kammerdeiner (W0G) reviewed the WOG projects utilizing LBB technology. The WOG detailed the following projects:
EffectsofAginginCastStainlessSteel(CSS) nonstructural Integrity.
(Determine the degree to which thermal aging affects the structural integrity of CSS components other than piping / fittings.)
Relief from Pump Casing ISI Based Upon Leak-Before-Break Methodology.
(Eliminate the ISI requirements for RCP Casings of all W PWRs.)
- Pressurizer Surge Line Stratification.
(Assess Potential Impact of Surge Line Stratification on Plant Design and Operation.)
- Reactor Support Structure Embrittlement Issue.
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T/H~ Phenomena Mtg Minutes March 7, 1989 In response to Mr. Wylie, Mr. Kammerdeiner said the WOG has not taken'a position, per se, on use of LBB for the W plants.
In response to Mr. Ward, Mr. Kammerdeiner indicated that it is un-likely that the WOG would pursue LBB for the issues of EQ or ECCS, but LBB may be worthwhile for such issues as relaxation of ISI requirements, etc.
8.
Mr. E. Siegel (CE) made some closing comments. He said the two perceptions he sees which as limiting use of LBB are:.(1)theNRC i
staff is not receptive to extending LBB to other applications, and (2) a rule is needed to allow additional use of LBB. He said the
" door should not.be closed" on further use of LBB.
1 9.
Mr. Bosnak said NRC isn't " closing the door" on additional use of LBB, but the Commission has limited their consideration of LBB to the issues of EQ and ECCS.
NRC sees a rule revision for LBB as counterproductive.
10.
In open executive session, Mr. Ward solicited the opinions of the Subcommittee Members regarding the day's discussions.
Mr. Wylie - Confused from the industry presentations. Some representatives see benefits on use of LBB; others do not. He believes there are some regulatory inhibitors to the industry given use of GDC 4 and the revised ECCS rule. Not sure where the " truth" really lies.
- Dr. Kerr'- Also confused, he heard many different messages.
Seems there are no major advantages to be gained by a rule change. A group effort by several utilities may show the need for a rule change, but rulemaking is difficult. Uncomfortable that utilities are finding it prohibitively expensive to
l T/H Phenomena Mtg Minutes March 7, 1989 process any licensing changes. Suggested that the ACRS may want to explore this issue in the future.
- Dr. Siess - Issue of use of LBB is more complex than he originally believed. A rule change doesn't seem the way to r0 however.
- Dr. Catton - He doesn't believe licensees evaluate EQ require-ments very well now, so the margin shouldn't be relaxed. He is surprised that there isn't much benefit for ECCS via LBB.
The perception of a " closed door" at NRC for review of LBB or other "non-safety" issues, if it is real, is troublesome.
Mr. Michelson - Doesn't recommend a rule change before licensees come forward with. definitive analyses. No hard evidence was presented today that a case for a rule change exists.
He urges that licencees prr:1ide the needed case for a rule change. He shares the perception that the staff not receptive to review of industry LBB-related submittals. There is a vicious circle here and he feels the industry should take the first step (s) to break it. He also made some suggestions on the proposed presentations for the full Committee review.
- 11. The Subcommittee agreed this issue should be reviewed by the full Committee. Mr. Ward instructed the cognizant presenters regarding their appearance before the ACRS.
- 12. The meeting was adjourned at 5:10 p.m.
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T/H Phenomena Mtg Minutes March 7, 1989 3
)
SLMMARY OF AGREEMENTS, ASSIGNMENTS, REQUESTS, AND FUTURE ACTIVITIES The. Subcommittee agreed with the NRC Staff policy position detailed f
in SECY 88-325 that the.LBB rule is not prudent at this time. The 1
Subcommittee did express concern however over an apparent impasse between the NRC Staff and Industry that in effect prevents industry submittals of proposals designed to enhance either plant safety R
and/or economic operation. This impasse seems to be due to:
(1) a Congressional / Commission mandate that the Staff must give priority to industry submittals that have a clear safety benefit; and, (2) the risk on the industry's part given the need to incur costs up-front without assurance the Staff will review and/or approve the desired action.
The Subcommittee agreed to bring this issue to the ACRS for its review. Presentations are expected from NRC-RES, CE and the CE Owners Group, and W.
' Future action on this issue will depend on NRC Staff / Commission reaction to any ACRS comments generated at during the March
- Meeting, j-NOTE:
Additional meeting details can be obtained from a transcript of this meeting available in the NRC Public Document Room, 2120 L Street, N.W., Washington, D.C. 20006,(202)634-3273, or can be purchased from Heritage Reporting Corporation,1220 L Street, N.W., Suite 600, Washington, D.C. 20005,(202) 628-4888.
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.6 PLANT EQUIPMENT /0PERATIONAL FLEXIBILITY POTENTIAL BENEFITS o
REDUCED REQUIREMENTS IN LOCA ANALYSIS NUMBER OF SITS OPERABLE SIT VOLUME - PRESSURE REQUIREMENTS REDUCE LPSI PUMP REQUIREMENTS -
INCREASE LPSI PUMP / SYSTEM OPERATING MARGIN o
REDUCED CONTAINMENT BUILDING COOLING CAPACITY REDUCED NUMBER OF CONTAINMENT SPRAY (CS) PUMPS / COOLERS OPERABLE INCREASED CS SYSTEM / COOLER SYSTEM MARGIN o
INCREASE MARGIN TO SAFETY SYSTEM ACTUATION SAFETY INJECTION SYSTEM EMERGENCY FEEDWATER ACTUATION o
RELAXATION OF TECHNICAL SPECIFICATION REQUIREMENTS NUMBER OF PUMPS, COOLERS, ETC' ULTIMATE HEAT SINK / FULL POWER OPERATION o
BOTTOM LINE INCREASE OPERATIONAL MARGINS MINIMIZE CHALLENGES TO SAFETY SYSTEMS MINIMIZE POWER REDUCTION / FORCED OUTAGES ENHANCES PLANT OPERABILITY AND FLEXIBILITY ENHANCES SAFETY lf/d-If'-
CONTAINMENT SYSTEMS AND ENVIRONMENTALREVIEN(CONT'D)
O BENEFIT OF LBB FOR EQ CURVES LIMITED TO INTERMEDIATE PORTION OF TRANS~.ENT CURVE (300 TO 10,000 SECONDS)
O SHORT TERM TEMPERATURE (TH'RU 300 SEC) IS ESTABLISHED BY STEAM LINE BREAK 0
LONG TERM POST LOCA VALUES (10,000 SEC) WILL REMAIN UNCHANGED i
0 WITHOUT LBLOCA TEMPERATURE BENEFIT OF 40 DEGREES AT 1,000 SEC MAY RESULT 0
WITHOUT LBLOCA TIME-AVERAGE TEMPERATURE BENEFIT OF 18 DEGREES (300 - 10,000 SEC) i
'