ML20247R435
| ML20247R435 | |
| Person / Time | |
|---|---|
| Issue date: | 06/08/1989 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| REF-GTECI-051, REF-GTECI-NI, TASK-051, TASK-51, TASK-OR ACRS-2648, NUDOCS 8908070460 | |
| Download: ML20247R435 (25) | |
Text
evi CERTIRED DATE ISSUED:
6/8/89 00f$- Ob$
O g g,gfp
)
SUMMARY
/ MINUTES OF THE ACRS SUBCOMMITTEE MEETING ON
]
AUXILIARY AND SECONDARY SYSTEMS MAY 24, 1989 BETHESDA, MARYLAND INTRODUCTION The ACRS Subcommittee on Auxiliary and Secondary System', held a meeting on Wednesday, May 24, 1989, in Room P-110, 7920 Norfolk Avenue, Bethesda, Maryland. The main purpose of this meeting was to discuss the proposed Generic Letter 3 Service Water System problems, proposed resolution of Generic Issue 51, " Improving the Reliability of Open-Cycle Service Water Systems," and other related matters. The entire meeting was cpen to public attendance. Mr. Sam Duraiswamy was the Cognizant ACES Staff Engineer for this meeting. A list of documents submitted to the Subcommittee is locluded in Attachment A, and a copy of the preser.-
tation schedule for the meeting is included in Attachmant B.
ATTENDEES ACRS:
C. Michelson (Subcommittee Chairman), and C. J. Wylie Sam Duraiswamy, Cognizant ACRS Staff Engineer Principal Speakers NRC:
C. Berlinger, R. Baer P. Lam, T. Y. Chang, a
E. Rossi, J. Rosenthal, and V. Hodge NRC Contractor Pacific North-west Lab (PNL):
D. Neitzel and P. Daling.
Nuclear Manage-ment Resources Council (NUMARC):
B. Bradley g5ol j
Service Water Workinc Group f '
TfWQ):
B. Fellers.
LE:' MATED ORIGINAL
{g80 g O 890608 Certiffea 13y__
//pg 2648 PDC
y.
..y e,
l Auxiliary & Secondary Systens.
Meeting Minutes May 24, 1989
.l
-l i
' EXECUTIVE SESSION-Mr. Michelson, the Subcommittee' Chairman, convened the meeting at 8:30 a.m..-and stated that during the meeting, the Subcommittee will hear presentations by and hold discussions with representatives of the Office for Analysis and Evaluation of Operational Data (AE00), Office of Nuclear Reactor Regulation (NRR), Office of Nuclear Regulatory Research (RES), NUMARC, and the Service Water Werking Group with respect to the following:
- Findings and recommendations resulting from a recent study per-formed by the AEOD on Service Water System Failures and Degradations.
- Proposed Generic Letter related to Service Water System Problems.
Proposed resolution of Generic Issue-SI.
- NUMARC's and the Service Water Working Group's connents on the
- scope and content of the proposed Generic Letter.
He stated that the Subcommittee had received neither written comments nor requests for time to make oral statements from members of the public.
PRESENTATIONS BY THE NRC STAFF Introduction - Mr. C. Berlinger, NRR Mr. Berlinger provided a brief preamble, stating that for the past several years the NRC Staff has been studying the probleias associated with service water systems. On September 3, 1980, Arkansas Nuclear One, Unit 2 was shut down because of the service water system problems caused by Asiatic clams.
Consequently, the NRC issued Bulletin 81-03, " Flow Blockage of Cooling Water to Safety System Components by Corbicula sp.
(Asiatic Clam) and Mytilus sp. (Mussel)," requiring licensees and
3 P
.- 9 Auxiliary & Secondary Systems Meeting Minutes May 24, 1989 1
applicants to assess macroscopic biological fouling problems at their facilities.
Subsequent to the issuance of Bulletin 81-03, service water system problems were experienced at San Onofre Unit I and Brunswick as a result i
of debris from shellfish and other conditions not described in Bulletin 81-03. As a result, the NRC Staff issued Information Notice 81-21 to make the licensees and applicants aware of the events occurred at San Onofre Unit I and Brunswick plants and the safety concerns associated with these events.
By March 1982, several plants experienced serious fouling in open-cycle service water systems caused by mud, silt, corrosion products, or aquatic bivalve organisms.
Consequently,. the Staff established Generic issue 51. To resolve this issue, the NRC initiated a research prograia.
Initially, this program was restricted to a study of biofouling, but in 1987 it was expanded to address also fouling by mud, silt, and corrosion products. This research has been completed recently and the results are documented in NUREG/CR-5210, Technical Findings Document for Generic Issue 51.
In 1987, the AE0D initiated a study to review and evaluate the service water system failures and degradations at light water reactors that occurred between 1980 and early 1987. The results of this AEOD case study are documented in NUREG-1275, Volume 3, " Operating Experience Feedback Report - Service Water System Failures and Degradations."
Mr. Berlinger stated that operating experien=ce and the results of the studies related to service water system problems have led the NRC Staff to question the adequacy of these systems in complying with the require-ments of the applicable General Design Criteria. Therefore, the NRC plans to issue a generic letter to all licensees and applicants, re-questing that they perform the actions specified in the generic letter
f s
N
+
L Auxiliary & Secondary Systems l'
Meeting Minutes May 24, 1989 to ensure that their service water systems are in compliance and will be maintained in compliance with 10 CFR Part 50, Appendix A, General Design Criteria 44, 45, and 46, and other related criteria.
AE0D Study'on Service Water System failures and Degradations -
Mr. P. Lam, AEOD Mr. Lam, AE0D, stated that in its recent study on Service Water System Failures and Degra.dations, the AE0D reviewed a total of 30,000 events that occurred between'1980 and early 1987. Of these:
- 980 events involved service water system problems. 704 of these were evaluated to be of limited safety significance.
- The. remaining 276 events related to service water systems were assessed to have potential generic safety significance, and were -
further evaluated.
- Of these 276 events, 30 events involving significant degradations or failures of the service water system were evaluated in detail and included in the the AE0D study.
Mr. Lam stated that an assessment of the 276 events related to service water systems indicated that the causes for system failures and signifi-cant degradations were attributed to the following (Attachment C, pages 1-2):
- Fouling due to sediment deposition 9 percent
- Biofouling 10 l
- Corrosion / Erosion 28
- Pipe coating and calcium carbonate 1
- Foreign Material / Debris intrusion 10
- Single failures end design deficiencies 6
a
y}
s
.u
~ Auxiliary & Secondary Systems Meeting Minutes May 24, 1989
- Flooding 4
- Multiple equipment failures 4
- Personnel e.nd Procedural errors 17
- Seismic deficiencies 11
,9 Mr. Lam stated that the results of the study indicate that the service water ~ system failures and degradations have significant safety implica-tions.. These system failures and degradations have adverse impact on a large number of safety-related systems and components that are required to mitigate reactor accidents.
Mr. Lam stated that the frequencies of service water system failures and depredations as observed in operating events are relatively high:
1.8 x 10-2 per reactor year for system failure and 4.1 x 10-I per reactor year for system ' degradation. The core-melt frequency due~to a loss of service water system is determined to be in the range of 10-3 to 10-5 per reactor year.
. Based on this study, the AEOD made the Silowing recommendations:
- Conduct, on a regular basis, performance testing of all heat exchangers which are cooled by the service water system and perform a safety function to verify heat exchanger heat transfer capabil-ity.
- Require licensees to verify that their service water systems are not vulnerable to a single failure of an active component.
- Inspect, on a regular basis, important portions of the piping of the service water system for corrosion, erosion, and biofouling.
)
p., j. '
a.
l l
'Auxil'iary & Secondary Systems L
' Meeting Minutes.May 24, 1989 l
- Reduce human errors in the operation, repair, and maintenance of
.the service water system by improving training, procedures, and maintenance'of the service water systems.
1' Stating that about one half of the system failures and degradations was caused by biofouling, fouling due to sedimentary deposition, and corro-sion/ erosion and the other half was caused by mechanically related l
problems, personnel and procedural errors, etc., Mr. Michelson asked which half is. cf more safety significant. Mr. Lam stated that in their study they looked at the ' complete loss of service water system as an accident initiator irrespective of whether the system loss was caused by
]
biofouling, corrosion / erosion, or other reasons.
Mr. Michelson commented that, in the proposed generic letter, the Staff seems to-place more emphasis on the biofouling issue c"en though it is not a major contributor to the service water system failures.
If the Staff is really concerned about the availability of the service water system, he.is not sure that they address this problem clearly in the proposed generic letter.
Mr. Wylie stated that if a system or a component is able to perform only at 50 percent capacity due to some fouling problems, it should be considered as failure rather than degradation. There are several events listeo in the AE0D study where the heat exchangers were fouled so bad that they were less than 50 percent effective. He believes that such events should have been counted as failures rather than degradations in the AE0D study.
Mr. Lam stated that realistically, those events should have been included under the failure category.
Mr. Michelson asked why the following issues that were identifieo in the 1982 AEOD report C202, " Report on Service Water System Flow Blockages by Bivalve Mollusks at Arkansas Nuclear One and Brunswick," were not
a i
i Auxiliary & Secondary Systems i
Meeting Minutes May 24, 1989 addressed either in the proposed generic letter or in the recent AE0D study:
1
' The vibratory motion induced by a seismic event may cause fouling organisms such as oysters and clams, that attach themselves to piping walls, to be broken loose in sufficient quantities to cause q
flow blockage in cooling water. systems.
- Fire protection systems using service water are also prime candi-dates for fouling by aquatic organisms. During a seismic event, the fouling organisms may break loose and plug the sprinkler heads.
If there is a seismically induced fire and if the fire protection system is-not capable of performing properly because of fouling corganisms accumulation in the sprinkler heads, it may create a Irdjor safety problem.
- Under design heat loads (e.g., post LOCA) ultimate heat sink temperature could reach 110 to 120 F during summer months. This is hot enough to cause a substantial mortality of the clam population.
Dead clams may be more of a problem than live organisms, since they are more easily swept along by the flow. Therefore, following a
-LOCA that resulted in high pond temperatures, service water system performance could be gradually degraded if the dead clams are swept into the system.
Mr. Lam stated that they are placing major emphasis in minimizing the population growth of clams.
If that is achieved, clams getting loose during a seismic event may not be a major problem. As far as the fouling of fire protection systems is concerned, he believes that it is specifically addressed in the resolution of Generic Issue 51. He stated that since some of the issues identified in the AE0D report C202 are
'being tracked down, they are not included in the recent AE0D rtport or in the proposed generic letter.
..m..(
Auxiliary & Secondary Systems j
Meeting Minutes May 24, 1989 Mr. Michelson commented that the status of the resolution of the issues previously raised by the AEOD should have been included in the recent AE0D report and also mentioned in the proposed generic letter.
Mr. Wylie stated that' about a year or two ago, the AE0D briefed the ACRS about the potential degradation of the service water system piping due to corrosion caused by biological organisms.
Pipes degraded due to bio-corrosion would not be able to withstand a seismic event.
He asked whether consideration has been given to the bio-corrosion issue in the recent AEOD study or in the proposed generic letter. Mr. Rossi stated that there are several codes and standards that provide specifications for sizing the pipes for various. systems. The proposed generic letter is not intended to be overly prescriptive. He believes that plant walkdowns could be performed to identify corroded pipes.
Mr. Wylie commented that piping designers normally take into account of the normal corrosion problem in sizing the pipes.
Since the bio-corrosion issue surfaced caly a few years ago, he does not believe that they have considered this problem when sizing the pipes.
Mr. Michelson stated that a few words about the bio-corrosion problem in the proposed generic letter would be helpful.
Proposed Resolution of Generic Issue 51, " Improving the Reliability of Open-Cycle Service Water Systems" - Mr. T. Y. Chang, RES Mr. Chang stated that Generic Issue 51 addresses failure and degradation of open-cycle service water systems due to biofouling organisms, mud, silt, and corrosion products. This issue does not deal with closed-cycle service water systems.
Mr. Chang discussed briefly the proposed resolution of Generic Issue 51, l
stating that it is based on the results of the research performed by PNL that are documented in NUREG/CR-5210. The proposed resolution requires l
l lw
4 L '.
i' i
Auxiliary & Secondary Systems g
Meeting flinutes May 24, 1989 that licensees and applicants implement either the surveillance or-contr011ed program specified below (Attachment C, page 3) or an equally effective course of action to satisfy the heat removal requirements of the service water system.
The proposed resolution requires that for those plants that use marine or esturaine (brakish) or freshwater with clams the following surveil-lance and control programs si. auld be implemented:
Surveillance Program
- The intake structure should be visually inspected, once per refueling cycle, for macroscopic biological fouling organisms (blue mussels, American oysters, and Asiatic clams), sedinent and corrcsion.
Control Program
- The service water system should be continuously chlorinated (or equivalently treated with another biocide) whenever the potential for a macroscopic biological fouling species exists.
- Redundant and infrequently used cooling loops should be flushed and flow tested periodically at the maximum flow to ensure that they are not fouled or clogged. Other components in the service water system should be tested on a regular schedule to ensure that they are not fouled or clogged.
For those plants that use freshwater without clams, the following should be implemented:
Surveillance Program
- As in the previous case, the intake structure should be visually inspected, once per refueling cycle, for macroscopic biological fouling organisms.
l
)
Auxiliary & Secondary Systems Meeting Minutes May 24, 1989
- Samples of water and substrate should be collected annually to determine if Asiatic clams have populated the water source.
If clams are detected, the chlorination or-(equivalent) treatment program should be modified. to make it effective.
Control Program
- The same actions specified for those plants'that use freshwater with clams should be implemented in this case.
Mr. Michelson commented that the proposed resolution of Generic Issue 51 seems to imply that Asiatic clams are the only concern for those systems that use freshwater, but it is not true. The AE0D study shows that there are fouling organisms in the freshwater other than Asiatic clams.
The proposed resolution provides misleading information. He suggested that.some clarification would be helpful. Mr. Chang stated that it is not the Staff's intent to say that Asiatic clams are the only fouling organisms in the freshwater. He agreed to make some clarifications to the propnsed resolution of Generic Issue 51 to make the. Staff's intent clearer.
With reference to a statement in paragraph A of Enclosure I to the proposed Generic Letter that states "Any fouling accumulations should be removed," Mr. Michelson suggested that it be changed to read "Any potentially fouling accumulations should be removed." The Staff agreed to consider this suggestion.
Stating that fire protection systems are very important, Mr. Michelson commented that he is not sure that the proposed generic letter provides adequate guidance to the licensees and applicants to prevent contamina-tion of the fire protection systems. The Staff stated that they believe that the fire _ protection system issue is properly addressed in the proposed generic letter.
a
,e' 1
Auxiliary & Secondary Systems Meeting Minutes May 24, 1989 Mr. Michelson stated that the proposed generic letter gives a choice to the licensees and applicants to implement either the programs proposed by the Staff or other equally effective programs.
In view of the fact that the licensees are not required to submit details of the alternate program to the NRC Staff for review, Mr. Michelson asked how would the Staff know that a program chosen by a licensee is equally effective.-
Mr. Rossi stated that through audits and inspection by resident inspec-tnrs, the Staff would know the nature of the program chosen by a speci-fic licensee.
Mr. Michelson. commented that this sort of approach may put too much burden on resident inspectors.
Expecting the resident inspectors to know quite a bit of everything does not seem appropriate.
In respcnse to several_ questions from Mr. Michelson and Mr. Wylie regarding lack of specific guidance on several items in the proposed generic letter, Mr. Rossi stated that the proposed generic letter is not intended to solve all the problems associated with service water sys-tems. The Staff expects that it will improve the reliability of service water systems.
In the future, if they experience other types of prob-lems, they will issue another generic letter or bulletin.
- 1. response to a question from Mr. Michelson, Mr. Baer stated that upon issuance of the proposed generic letter for industry use, Generic Issue 51 will be considered resolved.
Proposed Generic Letter, Service Water System Problems Affecting Safety-Related Equipment" - Mr. C. Berlinger, NRR Mr ' Berlinger stated that based on the operating experience, the NRC has been concerned about the problems associated with service wat v systems j
)
at nuclear power plants.
In 1984 INP0 issued some guidelines for l
enhanced monitoring of service water systems. Subsequently, the NRC Staff took e survey to determine the extent to which the licensees and
_ _ -__ A
j' 1
Auxiliary & Secondary Systems-Meeting Minutes May 24, 1989 applicants have implemented the INP0 guidelines. The results of the survey were very discouraging.
In the mean time, the study performed by the AEOD~ indicated that the problems related to service water systems are safety significant.
Consequently, the NRC Staff has decided to issue a ger<eric letter to all holders of operating licenses and construction permits.
Mr. Berlinger stated that the proposed generic letter requests that addressees perform the following actions to ensure that their service water systems are in compliance and will be maintained in compliance
'with 10 CFR Part 50, Appendix A, General Design Criteria 44, 45, and 46, and other related criteria:
- For open-cycle service water systems, implement and maintain an oncoing program of surveillance and control techniques to signifi-cantly reduce the incidents of flow blockage problems due to biofouling.
- Conduct a test program to verify the heat transfer capability of all safety-related heat exchangers cooled by service water. The program should consist of an initial test program and a periodic retest program. The initial program is to include heat exchangers cooled by both open-cycle and closed-cycle systems.
The periodic confirmatory retest program may be limited to heat exchangers cooled by open-cycle systems.
- Ensure by establishing a routine inspection and maintenance program
~
for open-cycle service water system piping and components that corrosion, erosion, protective coating failure, silting, and biofouling cannot degrade the performance of the safety-related systems supplied by service water, b
{-
b., ?.1 p
-Auxiliary & Secondary Systems Meeting. Minutes May 24, 1989
- Confirm that the service water system will accomplish its intended function in accordance with the current plant licensing basis, including confirmation that required safety functions can be accomplished in the event of failure of a single active component.
- Confirm that maintenance practices, operating and emergency proce-dures, and training that involve the service water system are adequate to ensure that safety-related equipment cooled by the service water system will function as intended and that operators of that equipment will perform effectively.
Mr. Bir11nger ste'.ed that 'since the generic letter does not require addressees to submit a detailed description of their proposed programs, including justifications for any proposed equally effective alternative course of action, the Staff does not intend to conduct a detailed review of the requested information. However, the Staff will selectively review licensee and applicant programs to assure that they comply with existing regulatory requirements.
Mr. Michelson asked whether the proposed generic letter requires testing of only those heat exchangers in the closed-cycle systems that interface with raw service water systems or all of the heat exchangers that are in the closed-cycle systems. Mr. Berlinger stated that the Staff requires that testing should be done on all heat exchangers to determine their heat transfer capability. Those heat exchangers in the closed-cycle systems that do not interface with the raw service water systems should be tested once and need not be retested.
Mr. Michelson commented that there are numerous heat exchangers in the closed-cycle systems that do not interface with raw service water systems. Since they do not contact with the raw service water systems, there is no chance that they will fail and/or degrade because of l
[-
j' "
r
(
..=.
i Auxiliary & Secondary Systems Meeting Minutes; May 24, 1989 water conditions. He does not understand the reasons for including such heat exchangers in the scope of the proposed generic letter.
)
Mr. Michelson sthted that closed-cycle systems include cooling systems l
such as chilled water systems.
These systems are not known as service water systems.
Since the proposed generic letter includes both closed-cycle and open-cycle systems, it would be more appropriate to change the title of the generic letter from service water systems to cooling water systems. Mr. Berlinger stated that they have defined clearly the open-cycle and closed-cycle service water systems in the generic letter.
Mr. Michelson stated that some licensees might have acquired heat exchangers as a part of larger pieces of equipment several years ago.
For such heat exchangers, there may not be adequate data available to.
determine their heat transfer requirements. He asked what the licensees are expected to de under such circumstances. Mr. Rossi stated that the licensees are expected to make their best effort to obtain data neces-sary to perform the test and to ensure that the heat exchangers are performing their intended functions.
Mr. Michelson asked what portion of the total cost is attributable to
. implement the provisions of the proposed generic letter for open-cycle systems and what portion is for closed-cycle systems. Mr. Berlinger stated that the Staff does not have the breakdown with them.
- However, i
he believes that for PWRs the cost is about 50 percent for open-cycle systems and about 50 percent for closed-cycle systems.
For BWRs, it is about 65 percent for closed-cycle systems and about 35 percent for open-cycle systems.
Mr. Berlinger mentioned that the cost estimate was based on the informa-tion provided by PNL, and AE00 in a memorandum from Mr. Novak to Mr.
Rossi dated April 5,1989. Mr. Michelson requested a copy of the April 5, 1989 memorandum. Mr. Lam agreed to provide a copy.
l
,e 3
Auxiliary & Secondary Systems 4
Meeting Minutes May 24, 1989 Mr. Michelson stated that operating experience and results of the studies performed by the AE0D indicate that there are serious problem; associated with open-cycle service water systems and necessary actions should be taken to remedy such problems. However, there is no documented evidence to show degradation or failure of closed-cycle service water systems. He asked, in the absence of such evidence, on what basis the Staff has included the closed-cycle service water systems in the scope of the proposed generic letter.
He wanted.to know what problems related to closed-cycle systems that the Staff expects to renedy.
He wondered whether it is really worth the cost and effort. He believes that the industry could spend its money and effort on more important safety issues.
Mr. Burlinger stated that closed-cycle systems at certain plants in Region II had experienced some problems. As a result, Region II person-nel requested specifically that these systems be included in the proposed. generic letter.
In addition, there are certain industry standards, especially ASME/ ANSI OM-1987, Part 2, that delineate requirements for performance testing of nuclear power plant closed cooling water systems. He believes that many utilities have already implemented the provisions of ASME/ ANSI OM-1987, Part 2.
Mr. Michelson suggested that the Staff obtain more information from Region II on the exact nature of the problems experienced with closed-cycle systems and provide it to the ads. He requested also a copy of the industry standard ASME/ ANSI OM-1987, Part 2.
COMMENTS BY N!! MARC ON THE PROPOSED GENERIC LETTER - MR. B. BRADLEY, NUMARC Mr. Bradley reiterated the comments included in the February 27, 1989 letter from Mr. Rasin, NUMARC, to Mr. Jordan, CRGR:
I
(
u 4
Auxiliary.& Secondary Systems Meeting Minutes May 24, 1989
- NUMARC agrees that utility actions are appropriate to address the i
degradation of open-cycle service water systems.
Industry programs are under way to address the issues associated with service water systems under the auspices of EPRI and a Service Water Working Group of utility representatives.
- Many utilities have already undertaken major programs to improve the performance of open-cycle service water systems, and many lessons have been learned. NUMARC believes that the proposed requirements for open-cycle systems would benefit greatly from continued discussion with the industry.
- The proposed generic letter requirements will have resource impacts on the order of hundreds of millions of dollars.
- NUMARC is concerned about including closed-cycle systems within the scope of the proposed generic letter. There is no documented safety basis to justify generic requirements relative to closed-cycle systems.
- Actions to address closed-cycle systems will require major resource expenditures and will detract from efforts to address open-cycle systems where problems have been experienced.
- The generic letter requirements should not apply to closed-cycle systems unless evidence of degradation similar to that documented for open-cycle systems can be shown.
- Efforts to issue the proposed generic letter in haste are likely to l
prove detrimental in the long run.
Mr. Bradley stated also that since the industry met with the NRC Staff several months ago, the scope of the proposed generic letter has been E
)
a.
{
D y~
Auxiliary & Secondary Systems Meeting Minutes May 24, 1989 v
expanded.to include fire protection systems. Since there is no do-cumented evidence of the failure or degradation of the fire protection systems due to biofouling, he does not believe that it should be in-cluded in the scope of the proposed generic letter..
COMMENTS BY SERVICE WATER WORKING GROUP - MR. B. FELLERS, EPRI Comments provided by Mr. Fellers include the following:
- There is no documented evidence of problems associated with closed-cycle systems similar to those related to open-cycle sys-tems.
Closed-cycle systems use treated demineralized water, cerrosion resistant materials, and are not exposed to biofouling organisms. They.are monitored several times a week to make sure-that proper water chemistry is maintained.
In view of the above reasons, the closed-cycle systems should not be included in the scope of the proposed generic letter.
- Although there may be some minor problems on the closed-cycle systems at certain plants, it is not justified to impose require-ments on all plants.
Requirements should be imposed on a plant-specific basis.
- The industry is already aware of the problems associated with the open-cycle service water systems. Many utilities have already implemented major programs to improve the performance of such systems. Additional actions to further improve the reliability of open-cycle service water systems are under way.
- There should be flexibility in the schedule for implementing the provisions of the proposed generic letter. Trying to implement everything in one plant outage may not be feasible or advisable.
7..
7 l
Auxiliary & Secondary Systems-Meeting Minutes' May 24, 1989
- Performance monitoring requirements should be flexible. Prior to imposing stringent requirements in this area, consideration should be given to the preventive and water treatment programs employed by several utilities.
- Nomenclature used in.the proposed generic letter is confusing.
- Federal and state regulations may have some impact on the implemen-tation of the best available technology for water treatment.
- The Service Water Working Group has been involved in developing programs to improve the performance and reliability of the service water systems.
- The Service Water Assistance Program has been in operation for about a year. Through this program, assistance has been provided to various utilities in dealing with the service water system problems.
Mr. Michelson asked whether the Service Water Working Group has made an estimate of the effort needed to implement the provisions of the pro-posed generic letter. Mr. Fellers stated that it would take significant effort on the part of the utilities to implement these provisions. He believes that.it might take at least 100 days during the first outage to implement the provisions related to both open and closed cycle systems.
In response to a question from Mr. Michelson, Mr. Fellers stated that service water system means open-cycle raw cooling water systems.
Closed-cycle systems are never called service water systems.
Mr. Michelson asked what sort of problems that the industry has to encounter if the requirements for the closed-cycle systems stay in the generic letter. Mr. Fellers stated that since most of the closed-cycle
__-_______-__-_A
i' Auxiliary & Secondary Systons' Meeting. Minutes May 24, 1989 systems are located in high-radiation areas, they are not easily accessible. Occupational radiation dose will increase since they have to work in high-radiction areas.
Performance monitoring testing of closed-cycle heat exchangers will have to be performed when the plant is in operation since they need heat load to do such testing.
STAFF'S RESPONSE TO INDUSTRY COMMENTS - MR. C. BERLINGER, NRR Mr. Berlinger stated that the Staff met with industry groups several times to discuss the provisions of the proposed generic letter. Based on the comments made by the industry groups at those meetings and the comments provided by NUMARC in a letter dated February 27, 1989, the Staff has made some changes to the proposed generic letter:
- Initially, the provisions of the proposed generic letter applied equally to both open-cycle and closed-cycle systems except in obvious cases such as chlorination control.. After considering the industry comments, the proposed generic letter has been modified to require that closed-cycle systems be tested during the initial test program and need not be retested.
- Routine inspection and maintenance program be applied only to open-cycle systems not to closed-cycle systems.
- The schedule for industry response has been modified to make it realistic.
SUBCOMMITTEE ACTION / FUTURE MEETING The Subcommittee decided to prepare coments and recommendations on the scope and contents of the proposed generic letter and submit them to the full Committee for consideration during the June 8-10, 1989 ACRS meet-ing.
No other meeting is scheduled to discuss this matter.
t as
-f
' Auxiliary & Secondary Systems Meeting Minutes May 24, 1989 ACTIONS, AGREEMENTS, AND REQUESTS
- The Subcommittee decided to submit comments and recommendations on the adequacy of the proposed generic letter related to service water system problems to the full Connittee for consideration during the June ACRS meeting.
- The Subcommittee suggested that representatives of the NRC Staff, NUMARC, and Service Water Working Group provide presentations to the full Conmittee during the June meeting with special emphasis on the bases / ramifications for including closed-cycle systems in the scope of the proposed generic letter.
- The Subcommittee requested copies of NUREG/CR-5052 related to aging effects in CCW systems.
- The Subcommittee requested copies of the memorandum from Mr. Novak, AEOD, to Mr. Rossi, NRR, dated April 5, 1989. Mr. Lam, AE0D, agreed to provide copies.
- The Subcommittee requested copies of the industry standard ASME/ ANSI OM-1987, Part 2, " Requirements for Performance Testing of Nuclear Power Plant Closed Cooling Water Systems." (Copieswere obtained from the Staff and provided to the Subcommittee during the meeting.)
Mr. Michelson thanked all participants and adjourned the meeting at 3:45 p.m.
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.
LIST OF DOCUMENTS SUBMITTED TO THE AUXILIARY AND SECONDARY SYSTEMS SUBCOMMITTEE MAY 24, 1989 1.
Presentation Schedule.
2.
Service Water System Design (Figures 1 and 2).
3.
Memorandum from J. Sniezek, NRR, for E. Jordan, CRGR transmitting the proposed Generic Letter on Service Water System problems, and Recommended Actior. for the Resolution of Generic Issue 51, dated May 4, 1989.
4.
Letter from W. Rasin, NUMARC, to E. Jordan, CRGR, providing com-ments on the proposed Generic Letter, dated February 27, 1989.
5.
NUREG-1275, Volume 3, Operating Experience Feedback Report -
Service Water System Failures and Degradations, dated November 1988.
6.
AE0D Report on Service Water System Flow Blockages by Bivalve Hollusks at Arkansas Nuclear One and Brunswick, dated February 1982.
7.
IE Information Notice No. 83-46: Common-Mode Valve Failures Degrade Surry's Recirculation Safety Subsystem, dated July 11, 1983.
8.
IE Information Notice No. 85-24:
Failures of Protective Coatings in Pipes and Heat Exchangers, dated March 26, 1985.
9.
IE Information Notice No. 85-30: Micro-biologically Induced Corrosion of Contaminant Service Water System, dated April 19, 1985.
10.
IE Information Notice No. 86-96:
Heat Exchanger Fouling Can Cause Inadequate Operability of Service Water Systems, dated November 20, 1986.
11.
IE Information Notice No. 87-06:
Loss of Suction to Low-Pressure Service Water System Pumps Resulting from Loss of Siphon, dated January 30, 1987.
12.
Closecut of IE Bulletin 81-03:
Flow Blockage of Cooling Water to Safety System Components by Corbicula, dated June 1984.
- 13. Priority Assessment for Generic Issue 51, dated November 30, 1983.
- 14. NUREG/CR-5210, Technical Findings Document for Generic Issue 51, dated August 1988.
- 15. NUREG/CP-5234, Value Impact Analysis for Generic Issue 51, dated February 1989.
ATTACHMENT A i
l
?
e.
REVISED: 5/16/89 PRESENTATION SCHEDULE ACRS SUBCOMMITTEE MEETING ON THE AUXILIARY AND SECONDARY SYSTEMS i
MAY 24, 1989 ROOM P-110, 7920 NORFOLK AVENUE BETHESDA, MARYLAND
, ACES CONTACT:
Sam Duraiswamy 301-492-9522 NOTE.:
- Presentation Time should not exceed 50% of the Total Time allocated for a specific item.
The remaining 50% of the time is reserved for the Subcommittee questions and answers by the Staff or its consultants.
- Number of copies of the presentation materials to be submitted to the Subcommittee:
25 copies.
TOTAL PRESENTATION ITEM PRESENTER TIME ACTUAL TIME 1.
EXECUTIVE SESSION SUBC. CHAIRMAN /
10 min 8:30 - 8:40 am SUBC. MEMBERS 2.
INTF0 DUCTION C. BERLINGER 10 min 8:40 - 8:50 am (NRR) 3.
AEOD STUDY ON SERVICE PETER LAM 80 min 8:50 - 10:10 am WATEP SYSTEM FAILURES (AEOD)
AND DEGRADATIONS 10 min 10:10 - 10:20 am
- BREAK ***
4.
PROPOSED RESOLUTION OF BOB BAER 30 min 10:20 - 10:50 am GENERIC ISSUE 51, RE-(RES)
QUIREMENTS FOR IMPROVING THE RELIABILITY OF OPEN CYCLE SERVICE WATER SYSTEMS 5.
PROPOSED GENERIC LETTER CARL BERLINGER 60 min 10:50 - 11:50 am ON SERVICE WATER SYSTEM (NRR)
PROBLEMS 10 min 11:50 - 12:00 Noon
- BREAK ***
6.
COMMENTS BY NUMARC AND BIFF BRADLEY 60 min 12:00 - 1:00 pm SERVICE WATER SYSTEM (NUMARC)/
WORKING GROUP BILL RLLERS (SWSWG) 7.
SUBCOMMITTEE REMARKS SUBC.
15 min 1:00 - 1:15 pm
- ADJOURN ***
1:15 pm se rs e c u u s a r -,L5
D T
N N
A E
S CR 90 8
1 0
6 4
4 7
1 0
SN E
1 2
1 1
1 0
P 1
EO RI S
T T
U A E
22 7
2 1
1 1
4 2
7 N
68 7
3 7
8 2
0 6
9 6
L D V
2 I
E AA F R S
M G N
E G
R S
U R
E E I
S S
L O
T D I
M R
E A
R I
N U
B D
F R
S T O
E S
L E
D T
I NC D
N N
C E
A Y N I
T OL
/
T I
A L
A E
O C
O I
S S
S C A
S M
R N
T I
A O O O
I P
R &
R E
P P
E FC I
T I
E R S U
C E
E G T
U E Q
F I
OF EDG
/
I I
U C
E E
OTATM N I
I E
D O
A N G
E N
D I
SN NL F
A NNI E
N L
N C
I GEU S O OG EI S
EG I
E NMO O C BI U L C D
P O
I M
I F
R ER GF O
T S
L R
S NE O
U AOSB OPA ON I
L U
E E
C C
F-CP FI S D I
I F
M P
S A
1 2
3 4
6 6
7 C
l
N S
O E
I I
T C
I S
N O
E S
P C
I E
E I
D F
R E
m U
T D
S L
N R
E C
O I
I A
G M
M R
I F
N D
S R
E I
I L
E E
D U
S S
L N
O E
F N
A O
N I
B O
S S
N R
E O
0 P
I 1
T A
7 D
M N
SE E
O R
T S
U I
S O
L Y
R 7
A E
S
/
L S
F A
E 1
R I
E O
N R
U O
E E
L M
R T
P I
I E
S U
A A
I S
O L
M F
U R
Q I
U R
A E
E F
N L
A O
G G
C C
G IE N
N R
S I
IT O
A F
O C
E P
I P
I
S LE C
C OU RQ D
D S
TI N
N P
NN A
A O
OH O
CC B
B L
E 1
T D
5 E
S U
U E
S Y
S L
I TN C
E S
I U
M R
C A
E E
L N
R C
E F
G N
C I
I E
T V
E D
A L
L N
P I
O C
A U.
S S
E' Y
Y A
E CS C
T A
R NE D
N L
R AU G
A O
O LQ D
N D
E F
T LI A
N I
N R
U O
K IN A
l.
M EH E
D F
C A
VC A
U E
E E
R RE F
T R
B H
G UT E
N C
O S
R E
T S
R L
S P
O P
R A
E O
T E
V T
O D
P I
L Y
E U
W L
D E
Q O
)
L N
C E
L T
A E
N F
N U
M O
R E
N M
O D
L N
O E
N A
A C
R N
A V
E E
U O
I I
H U
T R
TC T
S Q
A U
A U
E R
R N
L T
I F
R S
T S
R 0
F O
Y
(
U E
L L
S E
K H
L E
/
N A
C A
T R
I H T
C A
E I
N T
RT N
S I
U D
I A
A I S
RE U W M
O O
R W
ECE T
A T
U I
O TRP S R R L C
N R
L E
I E
H L
AUY EE EC E
WOT
,T T
P T
P C
P S
A A T S
N M
EW WU N
O A
N H S H O I
C O
o S
I S M S H REA ET A R L R I MF C F W A
B C
D
~
.I l