ML25016A175
| ML25016A175 | |
| Person / Time | |
|---|---|
| Issue date: | 01/16/2025 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| Download: ML25016A175 (1) | |
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Areas Comment TBS Tech basis for TBS is strong (expert elicitation, seismic risk; PFM)
A mulit plant optimization inspection schedule for piping is recomemnded for breaks above TBS in light of the lower risk significance of such breaks (inconsistency in current rule where inspection frequency is too frequent relative to risk)
Analysis beyond the TBS - focus on DiD, including containment analysis FFRD FFRD and no burst; do not allow any FFRD Best estimate definition - needed beyond what is in RG (?) Align with EPRI document on FFRD?
Core degradation - lack of clarity and consistency on definition Clad testing Need for breakaway oxidation testing; more flexible guidance needed Need to establish post quench ductility for new lower hydrogen content clad RG 1.183 FFRD DBA LOCA - what is this and why is it here as an AOO in light of DBA LB-LOCA now being BDBE?
Control room dose Linkage of CR dose to accident events instead of occupation exposure in Part 20 makes sense; good techncial basis provided for increasing dose based on relevant radiation exposure national and international standards Linkage of allowable dose to CDF not needed and sets a bad precedent; 25 rem may be acceptable in certain cases but broad use of 25 rem may be too high; 10 rem is acceptable Broader impacts how do deterministic rule changes enabled by risk information affect severe accident risk could also include how it effects other parts of plant safety need to evaluate effects on EPZ, SAMG How do all the pieces fit together - a graphic?
recommend a trial table top exercise