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| issue date = 10/29/1979
| issue date = 10/29/1979
| title = Requests Deletion of License Condition (3)(c),per Encl Revised Response to Question 212.40 in App Q of Fsar. Revision Due to Util Misinterpretation of Requirements Re Check Valve Leak Testing.W/Fee & Affidavit
| title = Requests Deletion of License Condition (3)(c),per Encl Revised Response to Question 212.40 in App Q of Fsar. Revision Due to Util Misinterpretation of Requirements Re Check Valve Leak Testing.W/Fee & Affidavit
| author name = DOLAN J E
| author name = Dolan J
| author affiliation = INDIANA MICHIGAN POWER CO.
| author affiliation = INDIANA MICHIGAN POWER CO.
| addressee name = DENTON H R
| addressee name = Denton H
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000316
| docket = 05000316
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=Text=
=Text=
{{#Wiki_filter:REGULA'TORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESS I ON NBR 0 79 1 1 090472.DOC~DATE~79/1 0/2 1 NOTARIZED~YES DOCKET FACIAL:50 316'Donald C~, Cook Nuclear Power Plenty Unit 2i Indiana L 05000316 AOTHBNAME",, AUTHOR AFFILIATION Dal AA J;E.Indiana 8 Rich,igan Power Cos-'ECIPiNAME>>
{{#Wiki_filter:REGULA'TORY INFORMATION         DISTRIBUTION SYSTEM (RIDS)
RECIPIENTT AFFlLIATION
ACCESS I ON   NBR 0 79 1 1 090472.       DOC ~ DATE ~ 79/ 1 0/2 1 NOTARIZED YES    ~           DOCKET FACIAL:50     316'Donald     C ~ , Cook   Nuclear Power Plenty Unit 2i Indiana               L 05000316 AOTHBNAME",,               AUTHOR   AFFILIATION Dal AA   J;E.               Indiana   8   Rich,igan Power Cos-
'EATONgH.R', Office of Nuclear Reactor Regulation
  'ECIPiNAME>>                 RECIPIENTT AFFlLIATION Office of Nuclear Reactor Regulation
                                                              'EATONgH.R',


==SUBJECT:==
==SUBJECT:==
Requests deletion of-License Condition (3)(c)iper encl revised response to.Question 212,40 in App Q of FSAR, Rev'is.ion due to'util'misinterpietation of-requirements re check valve leak testing,H/fee 8 affidavits DISTRIBUTION CODE: A001S COPIES RECEIVED:LTR J'NCL: J SIZE: TITLEi.Genei al'istribut>on for;after-Issuance of Ojerat>ngT L'ic NOTES: Lq(QfkZI<~K~~~~~~MDCL&+AL4~M L'd~RECIPIENT COPIES RECIPIENT COPIES ID'ODE/VAME t;TTR'NCL ID CaDEiNAME LTTR ENCL ACTION:.05 BC Qgg" 7 7 INTERNAL!-KG FIL$5 COREA PERFT BR 1S REAC SFTV BR 20.EEB 22 SAINKMAN OELD EXTERNALS 03 LPDR 23 ACRS 1 1 2 2 i 1 1, 1 1 i 1 0 1 1 16 16 02 NRC PDR 14 TA/EDO i7 ENGR BR 19 PLANT SYS BR 21 EFLT TRT SYS EPB~DOR 04 NSIC ADV 13879 VX Vl TOTAl.NUMBER OF COPIES REQUIRED!LTTR~KNCL II II I I t" II'I I g~II 1 It H 5 Ir'5 5 I 5'I le J I INDIANA II MICHIGAN POWER COMPANY Pi 6.BOX 18 BOWLING GREEN STATION NEw YoRK, N.Y.10054 October 29, 1979 REP;NgC;Q0259.
Requests deletion of- License Condition (3)(c)iper encl revised response to. Question 212,40 in App Q of FSAR, Rev'is.ion due to 'util'misinterpietation of- requirements                     re check valve leak testing,H/fee 8 affidavits DISTRIBUTION CODE: A001S COPIES RECEIVED:LTR J 'NCL: J                                 SIZE:
Donald C..Cook Nuclear Plant Unit No.2 Docket No.50-316 License No.DPR-74 Mr.Harold R.Denton, Director Office of Nuclear Reactor Regulation U.S, Nuclear Regulatory Commission Washington, D.C.20555
TITLEi. Genei al'istribut>on for; after- Issuance of Ojerat>ngT L'ic NOTES:   Lq(QfkZI<           ~K~~~ ~~~MDCL&+ AL4                                 ~M L'd~
RECIPIENT               COPIES                         RECIPIENT       COPIES ID'ODE/VAME               t;TTR'NCL
                                            "                    ID CaDEiNAME             LTTR ENCL ACTION:   . 05 BC   Qgg                   7     7 INTERNAL!     -     KG   FIL                 1       1     02 NRC PDR 2      2      14 TA/EDO
                $ 5 COREA PERFT BR            i      1      i7             ENGR BR 1S REAC SFTV BR                1,            19 PLANT SYS BR
: 20. EEB                        1      1      21 EFLT TRT SYS 22 SAINKMAN                    i      1      EPB~DOR OELD                                  0 EXTERNALS 03 LPDR                              1      1      04 NSIC 23 ACRS                        16    16 ADV   13879 VX                     Vl TOTAl. NUMBER OF COPIES REQUIRED! LTTR                     ~               KNCL


==Dear Mr.Denton:==
II                II I I t " II I
'urther review of Question 212.40 as contained in Appendix Q to the Donald C.Cook Nuclear Plant Final Safety Analysis Report'(FSAR)has led us to conclude that some of the testing described in the response is not necessary to satisfy the stated staff con-cerns and that the lists of valves need to be revised.The response to Question 212.40 was previously revised in our letter to Mr.Edson G.Case dated February 17, 1978.The intent of Question 212.40 is that we leak test the check valves which perform an isolation function , of protecting low pressure safety systems from full reactor pressure.The staff required that each check valve which performs this isolation function be identified and classified ASME IWV-2000 category AC with the leak testing being performed to code specifications.
I                        g    ~II 1 It H 5 Ir          '5 5
License condition (3)(c)was included in our Unit No.2 operating license in accordance with the'ommitments made in our response to Question 212.40.Our review has indicated that in the cases where low pressure systems are'isolated from full reactor pressure by check valves, the over-pressure protection of the low pressure system piping is provided by ASME code safety relief valves.As such, the check valve performs an isolation function but does not protect low pressure systems from full reactor pressure.Our misinterpretation of the staff position contained in Question 212.40 resulted in the commitments made in the response which became license condition (3)(c).The results of our review are con-tained in a revised response to Question 212.40 which is attached for your review.We request tha't operating license condition'(3)(c)be de-leted in accordance with the attached revision to Question 212.40.Q a V 91109D tr-'I l\N k''II i'r Nr.Harold R.Denton, Di'rector AEP;NRC:00259 This revision to the question 212.40 response does not inyolve an unreviewed safety question or Technical Specification change, nor will it endanger the health or safety of the public.We intend to formally incorporate this revised response into the FSAR as part of a future Amendment., Our review indicates that this revision constitutes a fee Class III Amendment to the facility license.In accordance with 10 CFR 170.22, we therefore enclose a check for$4,000,00.Very truly yours, John E.Dol an Vice President cc:.R.C.Callen G.Charnoff D.V.Shaller-Bridgman R.S.Hunter RE W.Jurgensen 0
5    'I I                                                le J
Res onse to uestion 212.40 There are no check valves which protect low pressure piping from full reactor pressure.This overpressure protection is provMed by safety relief valves on the low pressure piping systems as described below.This response addresses the staff concern system by system.The design pressure of the boron injection system is higher than the design pressure of the Reactor Coolant System (RCS).Therefore the check valves in the boron injection system do not perform the function of protecting a low pressure system from full reactor pressure.The function of protecting the Emergency Core Cooling Systems (ECCS)from fully reactor pressure is performed by safety relief valves.The ECCS lines to the RCS hot legs are isolated by normally closed valves.The Residual Heat Removal normal cooldown line is isolated by normally closed valves.The check valves in the other ECCS lines perform an isolation function only to the extent that any leakage should not exceed the capacity of the associated safety valves.In each case, there are either two or three check valves in series between the RCS and the ECCS components with a lower pressure rating.These series check valves are listed in Table 212.40-1 along with the associated safety valves which protect the lower pressure systems.For each check valve, the.rated capacity and pressuro setting of the associated safety valve(s)are adequate to protect the low pressure piping system.The allowable leakage rate for each listed check valve was determined, very con-servatively, based on the lowest relief capacity of the associated safety valve(s)and under the assumptions that all the other check valves in series are fully open and that all the other check valves in parallel leak at the maximum allowable rate.The performance of the check valves in isolating the ECCS from full reactor pressure is tested at least once per 72 hours during operational modes 1, 2, 3 and 4 by Technical Specification surveillance requirement 4.4.6.2d.to demonstrate that unidentified leakage from the RCS is limited to 1 gpm.Because this limit is well below the allowable leakage rate through any check valve, the adequacy of these check valves to perform thei'r isolation function is continuously verified by satisfaction of this survei'llance requirement.
I
Because of this requirement, any gradual de-teri'oration of the check valve seats will be recognized and remedied.These valves are located in systems that are normally maintained full of liquid, with either high pressure on the downstream side of the disc or no differential pressure across the disc.In this application, where th'e check valve is normally closed, any sudden, severe damage to the seating surface is very unlikely.212.40-2 The test frequency for exercising the valves identified'n Table 212.40-1 is in accordance with ASI1E Section XI paragraph IW-3520 of the 1974 edition with addenda through the summer of 1975.These valves are normally closed during plant operation and cannot be exercised without initiating conditions similar to a safety injection.
 
These valves will be exercised during cold shutdowns as stated in our Inservice Inspection Program submittals dated September 29, 1977 and September 22, 1978 (the latter resubmitted September ll, 1979.)The design pressure of the Chemical and Volume Control System (CVCS)on the discharge side of the charging pumps is higher than the design pressure of the RCS.Therefore the discharge side of the CVCS does not require pro-tection from full reactor pressure.The suction side of the charging pumps is protected by the suction header safety relief valve.The CVCS reciprocating charging pump discharge check valve i s not required to perform a pressure isolation function because the construction of a multi-piston, positive dis-.placement pump precludes pressure propagation in the reverse direction.
INDIANA II MICHIGAN POWER COMPANY Pi 6. BOX 18 BOWLING GREEN STATION NEw YoRK, N. Y. 10054 October 29, 1979 REP;NgC;Q0259.
The centrifugal charging pump discharge valves perform an isolation function only to the extent that any leakage should not exceed the capacity of the suction header safety relief valve.These check valves are listed in Table 212.40-2 along with the associated safety valve which protects the low pressure portion of the system.The pressure setpoints and relief flow capacity ratings for the safety valves are adequate to protect the low pressure piping system.The allowable leakage rate was determined assuming that all four check valves leak at the maximum allowable rate and that there is no recirculation.
Donald C..Cook Nuclear Plant                 Unit No. 2 Docket No. 50-316 License No. DPR-74 Mr. Harold R. Denton,                Director Office of Nuclear Reactor Regulation U.S, Nuclear Regulatory Commission Washington, D.C.                  20555 Dear Mr.
However, during all modes of plant operation with the Reactor Coolant System above 220 psi, normal practice.is to have one charging pump running.Therefore, any leakage through the discharge check valve of a non-operating centrifugal charging pump is recirculated by the operating pump and does not cause a significant in-crease in the suction side pressure.The testing for"exercising" will be performed for the check valves in Table 212.40-2 in the same manner and at the same frequency as described above for those in Table 212.40-1.212,40-3 I
Denton:'urther review of Question 212.40 as contained in Appendix Q to the  Donald            C. Cook Nuclear Plant Final Safety Analysis Report' (FSAR) has          led    us  to conclude that some of the testing described in the response                is not necessary to satisfy the stated staff con-cerns and that the lists of valves need to be revised. The response to Question 212.40                was previously revised in our letter to Mr. Edson G. Case  dated February 17, 1978. The intent of Question 212.40 is that we  leak test the check valves which perform an isolation function of protecting low pressure safety systems from full reactor pressure.
Check Valve TABLE 212.40-1 ECCS SERIES CHECK YALVES Nomenclature Alloivable Check Valve Protecting Leakage Rate: Safet Val ve s*GPM SI151E SI151W SI152N SI152S SI161L1 SI161 L2 SI161L3 SI161L4 SI166-1 SI166-2 SI166-3 SI166-4 SI170L1 SI170L2 S I170L3 SI170L4 ECCS Low Head Safety Injection ECCS Low Head Safety Injection ECCS Safety Injection ECCS Safety Injection SI Hot To Cold Leg Crosstie SI Hot To Cold Leg Crosstie SI Hot To Cold Leg Crosstie SI Hot To Cold Leg Crosstie Accumulator Discharge Accumulator Discharge Accumulator Discharge Accumulator Discharge ECCS Cold Leg Loop ECCS Cold Leg Loop ECCS Cold Leg Loop ECCS Cold Leg Loop SV-104E SV-104W SV-98A SV-98B SV-98A 5 SV-104E SV-98B 5 SY-104W SY-98B 5 SV-104W SV-98A 8 SV-104E SV-100-1 SY-100-2 SV-100-3 SV-100-4 SV-98A, SV-100-1 8(SV-104E SV-98B, SV-100-2&SV-104M SY-98B, SV-100-3 5 SV-104W SV-98A, SY-100-4 8 SV-104E 400 400 20 20 10 10 10 10 47 47 47 47 10 10 10 10".The Safety Valve designations are the same as those used in the Unit 2 ISI Program.
The staff required that each check valve which performs this isolation function be identified and classified ASME IWV-2000 category AC with the leak testing being performed to code specifications.                   License condition (3) (c) was included in our Unit No. 2 operating license in accordance with the'ommitments made in our response to Question 212.40.
e TABLE 212.40-2 CVCS CENTRIFUGAL CHARGING PUMPS DISCHARGE CHECK VALVES Check Valve Nomenclature Protecting Safet Val ve s Allowable Check Valve Leakage Rate GPM CS299E CS299M CS297E CS297iI Discharge Discharge Recirculation Recirculation SV-56 SV-56 SV-56 SV-56
Our review has               indicated that in the cases where low pressure systems are'isolated                 from full reactor pressure by check valves, the over-pressure protection of the low pressure system piping is provided by ASME code safety relief valves.                   As such, the check valve performs an isolation function but does not protect low pressure systems from full reactor pressure.           Our misinterpretation of the staff position contained in Question 212.40 resulted in the commitments made in the response which became license condition (3) (c). The results of our review are con-tained in a revised response to Question 212.40 which is attached for your review. We request tha't operating license condition '(3) (c) be de-leted in accordance with the attached revision to Question 212.40.
.Mr.Harold R.Denton, Director AEP:NRC:00259 STATE OF NEW YORK))ss.COUNTY OF NEW YORK)~ohn E Dolan, being duly sworn, deposes and says that he is the Vice President of licensees Indiana 8 Michigan Electric Company and Indiana 5 Michigan Power Company;that he has read the foregoing request and justificati'on for deletion of Condition (3)(c)on License No.DPR-74 and knows the contents thereof;and that said contents are true to the best of his knowledge and belief.Subscribed and sworn to before me this 29th day of October, 1979.Notary Public NOTA.,Y'yUobLcC, 5~co~Ie ot liow Yock No.4c-~~i" Gi 92 Queiifieo in 4ueens Courcy Cociiiicsiu fi!ed in iisw Ycck County'vccuno5con enoicoi cnecoh 30, 198 i
a Q
~y,fl REMI Wp o:I<0+n qo+a*<<+UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C.20555 OCT 17 1979 IIEMN08It 8fgKg I[~opy All Power Reactor Licensees All Applicants With Applications for a License Gentlemen:
V 91109D
This past March, the NRC transmitted to you a copy of Volume 3 of NUREG-0460,"Anticipated Transients Without Scram for Light Water Reactors" (ATWS)and a copy of an NRC letter that was sent this past February to each of the four nuclear reactor vendors.The letters to the vendors contained requests for information needed to perform generic analyses related to ATWS.As we pointed out in our March letters, the generic analyses we requested were intended to confirm that the modifications proposed by the NRC staff for.various classes of LWR designs would in fact accomplish the degree of ATWS prevention and mitigation described by the staff in its report.We also pointed out that we had chosen to work'directly with the vendors in obtaining this information in an effort to conserve both NRC and industry resources.
 
We requested that utilities cooperate with the vendors in per-forming the requested analyses.II Shortly after sending the letters to the vendors, the NRC Staff met with representatives of each of the NSSS vendors and many Utility representa-tives in Bethesda on March 1, 1979.The meeting was called to discuss the"early verification" approach in which we planned to use generic analyses as the basis for rulemaking.
tr-
We hoped thereby to avoid costly a~d unneces-sary repetitive analysis for individual plants.At the meeting, a, tenta-tive schedule was agreed to for generic analyses for each class pf plants to be provided in three separate packages to be submitted May l,ISeptember 1, and December 1, 1979.
                  'I k'
I og yv 1979 i ch 1 meeting, the NRC staff met separately with<<y o o g of h NSSS vendors and agreement upplied in the May 1 package.Also, as note a ATWS stqff report and the generic analyses questions w Utilities.
N    '
on A 1 and s ecific technical concerns raised by the to the ATWS resolution pro-Three Mile Island accident with regard to e posed in Volume 3 of NUREG-0460.
l\
rovide in writing, within 30 days of the meeting ent of the Three Mile Island impact on ATWS, to resolve TMI issues, and a realistic ATWS d the TMI-related analyses.roviding the needed ATW in orm both the March request an e d Because of the heavy Ml I 1 d ltd t t*I sl and acci dent occurre.e n ed to the ATWS issue for three months o e uired for Three i e s r 1 b t ti 1 d tio n effort on d d o d tio fo BWR the part of the PWR industry during that perio, an of Nuclear Reactor Regulation was temporarily d d th reorganized.
II i'r
Within thi s interim organization a gr i nat-direction of S.Hanauer to w ork on t e nre Con ress this past January in NUREG-0-510.ed by the Commission and reported to Congress ATWS is one of these 19 issues.su ested that, for PWRs, the Three Mile Island A reliminary NRR Staff review suggeste a , , land pre accident raised new questions w g t.the technical impact of Three Mile s'he corn letion and review o e 1 roceed as expeditiously as possible.for BWRs as specified in March should procee as e da on July 25, 1979 to discuss, with representa-considerations arising from the Three v s o i ie e ig r tt h d E lo 1 A a copy of the staff minute tes of that meeting is a tin the staff: can be seen ro from the minutes, at the meeting is still believed by the staff to be a serious e rotection should be provided.We sa ey 0" p stated that we are unwilling to wait anot er year TWS.
 
QCT 17 1979 gsubsequent to the July 25 meeting, we have met with representatives of the four g NSSS vendors and of some Utility/Owners.
Nr. Harold     R. Denton,   Di'rector                 AEP;NRC:00259 This revision to the question 212.40 response does not inyolve an unreviewed     safety question or Technical Specification change, nor it will endanger the health or safety of the public. We intend to formally incorporate this revised response into the FSAR as part of   a future   Amendment.,
We have met with GE to discuss the scope qf the remaining generic analysis information to be supplied for BWR 4/5/6's.We have also met with representatives of the GE BWR/3 Owners, B8W, BEW ATWS Owners Group, W, W ATWS Owners Group, and CE.At all these meetings, we considered further the required information and the schedule for its sub-.mittal.We have now received letters (see the list in Enclosure 2, attached)from the various groups describing the information to be furnished and projected schedules.
Our review indicates that this revision constitutes a fee Class   III Amendment to the facility license. In accordance with 10 CFR   170.22, we therefore enclose a check for $ 4,000,00.
On the basis of our review of these letters and meetings with the industry representatives, we perceive that the projected responses in several cases would not address several questions in our~February 15 letter.In particular, several items are lacking that we will need to justify acceptance of the hardware approaches of NUREG 0460 Vol 3 rather than using the design basis accident approach.I am determined to submit a proposed ATWS rule to the Commission for both PWRs and BWRs early in 1980.The type and content of the rule we will propose will depend critically upon the types and content of the information available to the staff.This will, of course, include whatever responses are actually pro-vided by the industry in response to the questions attached to the February 15 staff'letter, the March meetings, and the Three Mile Island related concerns as discussed in the July 25 and subsequent meetings.I still believe that it is possible for the early verification generic analysis program to provide an acceptable resolution of'he ATWS issue and that this is the way to achieve resolution with the least possible expenditure of NRC and industry resources.
Very truly yours, John E. Dol an Vice President cc:. R. C. Callen G. Charnoff D. V. Shaller-Bridgman R. S. Hunter RE W. Jurgensen
However, I want to reiterate that the success of this approach depends on whether or not all of the information necessary for the staff to confirm that its proposed ATWS modifications provide an acceptable level of protection, for all plants, is provided by the industry.I strongly encourage you to join or form Utility/Owners Groups, if you have not already done so, and provide the resources necessary to supply the needed tech-nical information pertaining to your plants, either operating or under construc-tion.It would further reduce the impact on the industry as well as the staff resources if the ATWS effort coordination and the review role is performed by one industry group, If you haye additional questions on the generic analysis early verification program discussed in this letter, please contact Mr.Ashok Thadani, (301-492-7341).
 
Sin ly,
0 Res onse   to uestion 212.40 There are no check valves which     protect low pressure piping from full reactor pressure. This overpressure protection is provMed by safety relief valves on   the low pressure piping systems as described below.
This response addresses the staff concern system by system. The design pressure of the boron injection system is higher than the design pressure of the Reactor Coolant System (RCS). Therefore the check valves in the boron injection system do not perform the function of protecting a low pressure system from full reactor pressure.
The function of protecting the Emergency Core Cooling Systems (ECCS) from fully reactor pressure is performed by safety relief valves. The ECCS lines to the RCS hot legs are isolated by normally closed valves.
The Residual Heat Removal normal cooldown line is isolated by normally closed valves. The check valves in the other ECCS lines perform an isolation function only to the extent that any leakage should not exceed the capacity of the associated safety valves.       In each case, there are either two or three check valves in series between the RCS and the ECCS components with a lower pressure rating.       These series check valves are listed in Table 212.40-1 along with the associated safety valves which protect the lower pressure systems.       For each check valve, the
. rated capacity and pressuro     setting of the associated safety valve(s) are adequate to protect the low pressure piping system. The allowable leakage rate for each listed check valve was determined, very con-servatively, based on the lowest relief capacity of the associated safety valve(s) and under the assumptions that all the other check valves in series are fully open and that all the other check valves in parallel leak at the maximum allowable rate.
The performance   of the check valves in isolating the ECCS from full reactor   pressure is tested at least once per 72 hours during operational modes 1, 2, 3 and 4 by Technical Specification surveillance requirement 4.4.6.2d. to demonstrate that unidentified leakage from the RCS is limited to 1 gpm. Because this limit is well below the allowable leakage rate through any check valve, the adequacy of these check valves to perform thei'r isolation function is continuously verified by satisfaction of this survei'llance requirement. Because of this requirement, any gradual de-teri'oration of the check valve seats will be recognized and remedied.
These valves are located   in systems that are normally maintained full of liquid,   with either high pressure on the downstream side of the disc or no differential pressure across the disc. In this application, where th'e check valve is normally closed, any sudden, severe damage to the seating surface is very unlikely.
212.40-2
 
The test frequency for exercising the valves identified'n Table 212.40-1 is in accordance with ASI1E Section XI paragraph IW-3520 of the 1974 edition with addenda through the summer of 1975. These valves are normally closed during plant operation and cannot be exercised without initiating conditions similar to a safety injection. These valves will be exercised during cold shutdowns as stated in our Inservice Inspection Program submittals dated September 29, 1977 and September 22, 1978 (the latter resubmitted September   ll, 1979.)
The design pressure of the Chemical and Volume Control System (CVCS) on the discharge side of the charging pumps is higher than the design pressure of the RCS. Therefore the discharge side of the CVCS does not require pro-tection from full reactor pressure. The suction side of the charging pumps is protected by the suction header safety relief valve. The CVCS reciprocating charging pump discharge check valve i s not required to perform a pressure isolation function because the construction of a multi-piston, positive dis-
. placement pump precludes pressure propagation in the reverse direction. The centrifugal charging pump discharge valves perform an isolation function only to the extent that any leakage should not exceed the capacity of the suction header safety relief valve. These check valves are listed in Table 212.40-2 along with the associated safety valve which protects the low pressure portion of the system. The pressure setpoints and relief flow capacity ratings for the safety valves are adequate to protect the low pressure piping system.
The allowable leakage rate was determined assuming that all four check valves leak at the maximum allowable rate and that there is no recirculation. However, during all modes of plant operation with the Reactor Coolant System above 220 psi, normal practice. is to have one charging pump running. Therefore, any leakage through the discharge check valve of a non-operating centrifugal charging pump is recirculated by the operating pump and does not cause a significant in-crease in the suction side pressure.
The testing for "exercising" will be performed for the check valves in Table 212.40-2   in the same manner and at the same frequency as described above for those in Table 212.40-1.
212,40-3
 
I TABLE 212.40 -   1 ECCS SERIES CHECK YALVES                     Alloivable Check Valve Leakage Rate:
Protecting Check Valve                    Nomenclature                Safet Val ve s
* GPM SI151E               ECCS Low Head Safety Injection       SV-104E              400 SI151W                ECCS Low Head Safety Injection       SV-104W              400 SI152N                ECCS Safety Injection                 SV-98A                20 SI152S                ECCS Safety Injection                 SV-98B                20 SI161L1              SI Hot To Cold Leg Crosstie           SV-98A 5 SV-104E      10 SI161 L2              SI Hot To Cold Leg Crosstie           SV-98B 5              10 SY-104W SI161L3              SI Hot To Cold Leg Crosstie         SY-98B 5              10 SV-104W SI161L4              SI Hot To Cold Leg Crosstie           SV-98A 8              10 SV-104E SI166-1              Accumulator Discharge                 SV-100-1              47 SI166-2              Accumulator Discharge                 SY-100-2              47 SI166-3              Accumulator Discharge                 SV-100-3              47 SI166-4              Accumulator Discharge                 SV-100-4              47 SI170L1              ECCS Cold Leg Loop                   SV-98A,              10 SV-100-1  8(
SV-104E SI170L2              ECCS Cold Leg Loop                    SV-98B,              10 SV-100-2  &
SV-104M S I170L3              ECCS Cold Leg Loop                    SY-98B,              10 SV-100-3 5 SV-104W SI170L4              ECCS Cold Leg Loop                    SV-98A,              10 SY-100-4 8 SV-104E
        ".The Safety Valve designations are the  same as those used in the Unit 2 ISI Program.
 
e TABLE 212.40 - 2 CVCS CENTRIFUGAL CHARGING PUMPS DISCHARGE CHECK VALVES Allowable Check Valve Protecting            Leakage Rate Check Valve        Nomenclature            Safet Val ve s            GPM CS299E              Discharge                    SV-56 CS299M              Discharge                    SV-56 CS297E              Recirculation                SV-56 CS297iI            Recirculation                SV-56
 
. Mr . Harold R. Denton, Director                                                                            AEP:NRC:00259 STATE OF NEW YORK )
                      )  ss.
COUNTY OF NEW YORK)
                    ~ohn E Dolan, being duly sworn, deposes and says that he  is the Vice President of licensees Indiana 8 Michigan Electric Company and Indiana 5 Michigan Power Company; that he has read the foregoing request and justificati'on for deletion of Condition (3) (c) on License No. DPR-74 and knows the contents thereof; and that said contents are true to the best of his knowledge and belief.
Subscribed and sworn to before    me this            29th          day        of                      October,        1979.
Notary Public NOTA.,Y'yUobLcC,    5~co~ Ie ot liow                Yock No. 4c-~~i" Gi 92 Queiifieo in 4ueens Courcy Cociiiicsiu fi!ed in iisw Ycck enoicoi cnecoh 30, 198 County'vccuno5con i
 
    ~y,fl REMI Wp UNITED STATES o              NUCLEAR REGULATORY COMMISSION
:I <                      WASHINGTON, D. C. 20555 0
  +n            qo
    +a*<<+
OCT 17  1979 IIEMN08It 8fgKg              I[ ~opy All Power Reactor Licensees All Applicants With Applications for      a  License Gentlemen:
This past March, the NRC transmitted to you a copy of Volume 3 of NUREG-0460, "Anticipated Transients Without Scram for Light Water Reactors" (ATWS) and a copy of an NRC letter that was sent this past February to each of the four nuclear reactor vendors. The letters to the vendors contained requests for information needed to perform generic analyses related to ATWS.
As we    pointed out in our March letters, the generic analyses we requested were intended    to confirm that the modifications proposed by the NRC staff for. various classes of LWR designs would in fact accomplish the degree of ATWS prevention and mitigation described by the staff in its report.      We also pointed out that we had chosen to work'directly with the vendors in obtaining this information in an effort to conserve both NRC and industry resources.      We requested that utilities cooperate with the vendors in per-forming the requested analyses.                      II Shortly after sending the letters to the vendors, the NRC Staff met with representatives of each of the NSSS vendors and many Utility representa-tives in Bethesda on March 1, 1979. The meeting was called to discuss the "early verification" approach in which we planned to use generic analyses as the basis for rulemaking. We hoped thereby to avoid costly a~d unneces-sary repetitive analysis for individual plants. At the meeting, a, tenta-tive schedule was agreed to for generic analyses for each class pf plants to be provided in three separate packages to be submitted May l,ISeptember 1, and December 1, 1979.
 
I og yv  1979
              <<y    o  o    g          ch 1 meeting, the NRC staff met separately with of   h  NSSS    vendors and agreement i              upplied in the May 1 package. Also, as note a ATWS     stqff  report and the generic analyses questions w Utilities.
n                                            I sl and acci dent occurre d . Because    e      of the heavy e  uired for Three Ml      i e Is 1 d          ltd ed to the ATWS issue for three months o r t t 1          b  t ti    1    d    tio n effort    on the part of the        PWR  industry during that         perio,d    an d  o        d    tio fo BWR of Nuclear Reactor Regulation was temporarily reorganized. Within thi s interim organization a gr                                          d  d    th direction of S. Hanauer to work on t e                        nre                                      i nat-ed by the Commission and reported to Congress        Con ress this past January in NUREG-0            - 510.
ATWS is one of these 19 issues.
                  'he A    reliminary pre              NRR  Staff review su        ested that, suggeste        a , for    PWRs,,   the Three Mile Island land accident raised        new  questions    w          g
: t. the technical impact of Three Mile s                                          corn  letion    and review o          e                1 for   BWRs  as  specified in March should procee      roceed as eexpeditiously as possible.
da on    July 25,    1979 to discuss, with representa-v s o               i ie          e ig r          considerations arising from the Three a  copy  of the staff minute  tes of that      meeting is a     tt    h d      E    lo      1    A can be seen from    ro the minutes, at the meeting        tin the     staff:
is still believed by        the staff to       be a serious sa  ey    0              "            e p rotection should be provided.               We stated that      we  are unwilling to wait anot er year on ATWS.
1 and s    ecific technical        concerns raised by the Three Mile Island accident with regard                to thee    ATWS    resolution pro-posed  in  Volume 3  of  NUREG-0460.
rovide in writing, within 30 days of the meeting ent of the Three Mile Island impact on ATWS, to resolve TMI issues, and a realistic roviding the needed ATW     ATWS in orm both the March request an d thee TMI-related analyses.
 
QCT 17  1979 gsubsequent to the July 25 meeting, we have met with representatives of the four g NSSS vendors and of some Utility/Owners. We have met with GE to discuss the scope qf the remaining generic analysis information to be supplied for BWR 4/5/6's. We have also met with representatives of the GE BWR/3 Owners, B8W, BEW ATWS Owners Group, W, W ATWS Owners Group, and CE.       At all these meetings, we considered further the required information and the schedule for its sub- .
mittal.
We  have now received letters (see the list in Enclosure 2, attached) from the various groups describing the information to be furnished and projected schedules.
On the basis of our review of these letters and meetings with the industry representatives, we perceive that the projected responses in several cases would not address several questions in our ~February 15 letter. In particular, several items are lacking that we will need to justify acceptance of the hardware approaches of NUREG 0460 Vol 3 rather than using the design basis accident approach.
I am determined to submit a proposed ATWS rule to the Commission for both      PWRs and BWRs early in 1980. The type and content of the rule we will propose        will depend critically upon the types and content of the information available      to the staff. This will, of course, include whatever responses are actually pro-vided by the industry in response to the questions attached to the February 15 staff 'letter, the March meetings, and the Three Mile Island related concerns as discussed in the July 25 and subsequent meetings.
I  still  believe that it is possible for the early verification generic analysis program to provide an acceptable resolution of'he ATWS issue and that this is the way to achieve resolution with the least possible expenditure of NRC and industry resources. However, I want to reiterate that the success of this approach depends on whether or not all of the information necessary for the staff to confirm that its proposed ATWS modifications provide an acceptable level of protection, for all plants, is provided    by the industry.
I strongly encourage you to join or form Utility/Owners Groups,       if you have not already done so, and provide the resources necessary to supply the needed tech-nical information pertaining to your plants, either operating or under construc-tion. It would further reduce the impact on the industry as well as the staff resources  if  the ATWS effort coordination and the review role is performed by one industry group, If  you haye additional questions on the generic analysis early verification program discussed in this letter, please contact Mr. Ashok Thadani, (301-492-7341).
Sin      ly, s
                                              ~
H. R, 'Denton,
                                                    ~
                                                      ~        Director Office of Nuclear Reactor Regulation


==Enclosures:==
==Enclosures:==
: 1. NRC-Industry ATWS Meeting Summary dtd 7/25/79
: 2. List of letters from Industry on Content of Report Submittals


1.NRC-Industry ATWS Meeting Summary dtd 7/25/79 2.List of letters from Industry on Content of Report Submittals s~~~H.R,'Denton, Director Office of Nuclear Reactor Regulation
' 4, ENCLOSURE 1 g RECg
'4,ENCLOSURE 1 g RECg~tp 0 y~~*4 Task Action Plan A-9 UNITED STATES NUCLEAR REGULATORY COMhlISSION WASHINGTON, D.C.20555 JUL 2P 1379 MENORANOUtl FOR: S.H.Hanauer FROM:  
            ~
tp 0                                     UNITED STATES NUCLEAR REGULATORY COMhlISSION WASHINGTON, D. C. 20555 y~ ~*4                                            JUL 2P 1379 Task Action Plan A-9 MENORANOUtl FOR:                 S. H. Hanauer FROM:                           A. Thadani


==SUBJECT:==
==SUBJECT:==
A.Thadani NRC-INDUSTRY ATWS tlEETING'UIlMARY Th taff met-with the PWR vendors, the Atomic Industrial Forum (AIF)and e sa me-w'everal utility representatives to discuss the impac t of TMI-2 events on the ATWS resolution plan described in Volume 3 of NUREG-0460.
NRC-INDUSTRY ATWS tlEETING'UIlMARY Th e  sataff  met-         with the PWR vendors, the Atomic Industrial Forum (AIF)   and utility representatives to discuss the impac t of TMI-2 events me-w'everal on the ATWS resolution plan described in Volume 3 of NUREG-0460.
The staff'ade the following initial remarks: 1)ATWS is still a safety concern and protec ion from these events must be d d Alth h plants need not be shutdown immediately because of relatively low likelihood of a severe ATWS in a PWR in the nex p of years, ATMS resolution with suitable speed is necessary to permit an implementation plan which would assure an acceptably low risk from ATWS over the life of nuclear plants.2)The staff would like to recei,ve industry views on the impact of TflI-2 on ATWS and how to proceed from now on to resolve ATWS.The staff noted that they intend to propose an ATMS solution to the Commission preferably with but if necessary without the industry input.3)In view of TMI-2 accident, the staff expressed the following general con-cerns with the Vol.3 proposed resolution and asked for industry comments.a)What assurance do we have that the excessive calculated pressures for some designs modified per Alternative 83 would not result in loss of integrity of reactor coolant pressure boundary.(Note-Some designs may experience peak pressures-4000 psi).b)Would increasing the number of safety valves as per Alternative 84 result in insufficient overall risk reductionf Would the primary system integrity be maintained?
The   staff'ade             the following   initial remarks:
Would it be better to have larger capacity valves' S.H.Hanauer c)n v ew 0 que)I i f stions a and b above, the pressurizer relief and safety valves must be qualified for water relief to assure that th e nozzles,'he valve body and the support s.ructure integrity will be maintained and to estimate discharge flow rate and the likelihood and effects of valve chatter.d)I i w of significant plant differences in the designs of auxiliary feedwater system, Emergency Core Cooling Systems and other y nve s stems how would the industry provide assurances that plant specific f tures have been adequately addressed in the"Early Verification" approach for resolving ATMS as described in NUREG-0460,~ea Vol.3.e)Other Lessons Learned from TNI-2.Following prelim>nary comments from the NRC staff members, G.Sorensen of WPPS who is.also the Chairman of the AIF ATMS committee, made the following comments.1)ATMS is not a safety issue but rather it is a licensing issue which needs resolution.
: 1)     ATWS   is           still a safety concern and protec ion from these events must be d d             Alth h plants need not be shutdown immediately because of relatively low likelihood of a severe ATWS in a PWR in the nex                   p of years, ATMS resolution with suitable speed is necessary to permit an implementation plan which would assure an acceptably low risk from               ATWS over the life of nuclear plants.
2)AIF in concert with the industry had reviewed ATMS in light of TMI-2 and had concluded that the Alternative 84 fix{mitigation) in Vol.3 of NUREG-0460 is not the correct solution to ATMS.The industry believes that the alternative 82 fix{Prevention
: 2)     The   staff           would like to recei,ve industry views on the impact of TflI-2 on ATWS and how to proceed from now on to resolve ATWS. The staff noted that they intend to propose an ATMS solution to the Commission preferably with but             if necessary without the industry input.
-Electrical Portion of RPS)is the appropriate ATMS solution.3)Industry recognizes the THI-2 impact on the role of the operator, his training aids and other lessons learned from this event.The industry believes that there is no need to rush to resolve ATWS because of the low probability of ATMS and because some of the anticipated changes to plants as a result of TMI-2 accident review would direct resources to other issues.Following the AIF presentation, the staff raised their concerns that the ATWS resolution
: 3)     In view of TMI-2 accident, the staff expressed the following general con-cerns with the Vol. 3 proposed resolution and asked for industry comments.
{not yet achieved)gas been anything but hasty, that the NUREG docu-t ATHS have been out for sufficiently long time period, that protection from ATWS is necessary, that THI-2 event has raised"oncerns with the ana y H" 1 ses assumptions and therefore the htaff needs industry technical assessment of the TMI-2 impact on ATWS.The staff suggested that the THI-2 event indicates a need to answer at least the following specific questions.
a)   What assurance             do we have that the excessive calculated pressures for some           designs modified per Alternative 83 would not result in loss of integrity of reactor coolant pressure boundary. (Note - Some designs may experience peak pressures - 4000 psi).
I , I S.H.Hanauer-3-1)Analyses indicate the sensitivity of peak pressure to AFWS design and actuation time for some plants.Mhy should auxiliary feedwater actuation not be delayed beyond technical spehification values?What bases are available to assume AFWS actua-tion earlier than the technical specification value?How do the analysestake into consideration the limits on AFWS injection rate due to water~hammer considerations?
b)   Would           increasing the number of safety valves as per Alternative 84 result in insufficient overall risk reductionf Would the primary system integrity be maintained? Would it be better to have larger capacity valves'
How is the impact of flow restrictors on some AFMS designs considered in the ATWS analyses?How are the significant plant specific features of AFWS treated in the analyses?2)As in question 1 above how are the differences in ECCS designs evaluated?
 
For example, for some ATMS events, the pressure and the pressurizer level remain hiqh enough such that either the HPSI cannot be actuated (because of shut off head considerations) or the operator may fail to actuate HPSI because of insufficient available information.
S. H. Hanauer I
3)Would single failure cause all PORVs to fail to open?If so, then analyses must be based on all PORVs failing to open.Further, several plants are operating today with PORVs isolated.For these plants credit cannot be taken for relieving capability of these valves.4)What assurance do we have that the ATWS events with a stuck open safety.valve have been correctly analyzed?What is the potential for core un-covering under this scenario?What is the importance of ECCS actuation, reactor coolant pumps operation, and the pressurizer safety/relief valve discharge model on the potential for uncovering of the core?Further, why should more valves not be assumed to stick open following discharge of subcooled water.5)For long term shutdown, discuss the following:
I c))  In  v i ew 0 f que stions a and b above, the pressurizer relief and safety valves must be qualified       for water relief to assure that th e nozzles, valve body and the support     s .ructure integrity will be maintained
a)available equipment, instrumentation and their qualification.(Must consider the effect of water discharged to the containment via ruptured quench tank).b)impact of loss of offsite power c)continued operation'of reactor coolant pumps.Also consider tripping of reactor coolant pumps.d)Describe natural circulation, including effects of non-condensables.
                                                                                          'he and to estimate discharge flow rate and the likelihood and effects of valve chatter.
Is reflux boiling mode of operation anticipated?
d)   I nve  i w of significant plant differences in the designs of auxiliary feedwater system, Emergency Core Cooling Systems and other s ystems how would the industry provide assurances         that plant specific
If so, justify.
        ~
S.H.Hanauer 4-e)Would one anticipate Boron precipitatton problem?Also consider TMI-2 type problems with possible letdown line plugging from Boron precipitation.
f ea tures have been adequately addressed in the "Early Verification" approach for resolving ATMS as described in NUREG-0460, Vol. 3.
f)How are leakage problems from equipment outside containment considered?
e)   Other Lessons       Learned from TNI-2.
6)Why should credit be given for operator action even after ten minutes fallowing an ATWS event injtiation7 TMI-2 experience does not provide enoughconfidence in the ability of the operator to perform correct actions only in this short time period under high stress conditions.
Following prelim>nary comments from the NRC staff members, G. Sorensen of WPPS   who is. also the Chairman of the AIF ATMS committee, made the following comments.
In response.to the staff concerns the industry made the following comnents.AIF 1)The industry is frustrated because the staff concerns imply consideration of multiple failures and small LOCA which are beyond the credible events to be considered under ATWS.(Note-safety valve stuck open (small LOCA)is considered an anticipated transient).
: 1)   ATMS   is not   a safety issue but rather   it is a licensing issue which needs resolution.
2)Industry would like to wait for approximately six months before consider-ing ATWS evaluations to minimize duplicate expenditures.
: 2)   AIF in concert with the industry had reviewed ATMS in light of TMI-2 and had concluded that the Alternative 84 fix {mitigation) in Vol. 3 of NUREG-0460 is not the correct solution to ATMS. The industry believes that the alternative 82 fix {Prevention - Electrical Portion of RPS) is the appropriate       ATMS   solution.
l)W has submitted responses to the 2/15/79 Mattson letter.2)Calculated peak pressure of 2800>2900 psi (for Alt, 83)and proposed modifications in turbine trip and auxiliary feedwater system actuation ci rcui try.3)EPRI expects to issue a request for proposal to conduct tests on PORVs and safety valves and some results should be available by end of CY 79.4)Recommended that"Early Verification" approach should be continued.
: 3)   Industry recognizes the THI-2 impact on the role of the operator, his training aids and other lessons learned from this event. The industry believes that there is no need to rush to resolve ATWS because of the low probability of ATMS and because some of the anticipated changes to plants as a result of TMI-2 accident review would direct resources to other issues.
CE-Ed Shearer speakin for himself 1)TMI raises few questions like the behavior of S/R valves and the operator action.Further, prevention is better than mitigation and that mitigation would mean more and more analyses.2)Continue with early verification.
Following the AIF presentation, the staff raised their concerns that the ATWS resolution {not yet achieved) gas been anything but hasty, that the NUREG docu-t       ATHS have been out for sufficiently long time period, that protection from ATWS is necessary, that THI-2       H  event has raised ""oncerns with the ana 1 y ses assumptions and therefore the htaff needs industry technical assessment of the TMI-2 impact on ATWS. The staff suggested that the THI-2 event indicates a need to answer at least the following specific questions.
a S.H.Hanauer BlkW 1)Basically agrees with the staff concerns.Industry has longer list of items that could impact ATWS.2)Stress analyses should be completed.
 
3)Likelihood of additional failures beyond ATWS should be considered.
S. H. Hanauer                             1)   Analyses indicate the     sensitivity of     peak pressure   to AFWS design and actuation time for   some plants.
4)Prevention is better than mitigation.
Mhy should auxiliary feedwater actuation not       be delayed beyond technical spehification   values?   What bases   are available to assume AFWS actua-tion earlier than the technical   specification   value?   How do the analyses take into consideration the     limits   on AFWS injection   rate due to water
~BLfl 0 6 1)ATWS is not a safety pr.oblem.2)Even if ATWS occurs, no significant risk to public health and safety.3)TMI-2 suggests a desirability for realistic analyses.TMI-2 suggests a need to assure that analyses bound the facilities.
    ~
4)-Wait until"Lessons Learned" and"Bulletins and Orders" issues are resolved before pushing ahead with ATWS.After the above industry comments, the staff made the following concluding remarks.1)We don't intend to go too fast on ATWS.2)If Early Verification is to be pursued then there is a need to assure that-earlier ATWS analyses are correct and review the industry TMI-2 related list.In this regard the industry was invited to meet with the staff to discuss the technical issues which impact ATWS.The staff asked the indus-try to provide their assessment of TMI-2 impact on ATWS, the scope of I effort to resolve these issues, and the schedule for performing this effort within 30 days.I 3)We cannot wait another year to make progress in ATWS.A.Thadani  
hammer considerations?     How is   the impact   of flow restrictors   on some AFMS designs considered in     the ATWS analyses?   How are the significant plant specific features of AFWS treated in the analyses?
: 2)   As in question 1 above how are the     differences in   ECCS designs evaluated?
For example, for some ATMS events, the pressure         and the   pressurizer level remain hiqh enough such that either the HPSI         cannot be actuated   (because of shut off head considerations) or the operator may           fail to actuate   HPSI because of insufficient available information.
: 3)   Would single failure cause all PORVs to fail to open?           If so, then analyses must be based on all PORVs failing to open. Further, several plants are operating today with PORVs isolated. For these plants credit cannot be taken for relieving capability of these valves.
: 4)   What assurance do we have that the ATWS events with a stuck open safety
  . valve have been correctly analyzed? What is the potential for core un-covering under this scenario? What is the importance of ECCS actuation, reactor coolant pumps operation, and the pressurizer safety/relief valve discharge model on the potential for uncovering of the core? Further, why should more valves not be assumed to stick open following discharge of subcooled water.
: 5)   For long term shutdown, discuss the       following:
a)   available equipment, instrumentation       and their qualification.       (Must consider the effect of water discharged to the containment via ruptured quench tank).
b)   impact of loss of offsite     power c)   continued operation 'of reactor coolant pumps.         Also consider tripping of reactor coolant   pumps.
d)   Describe natural   circulation, including effects of non-condensables.
Is reflux boiling   mode of operation anticipated?         If so, justify.
 
S. H. Hanauer                                 4-e)   Would one   anticipate   Boron precipitatton   problem? Also consider TMI-2 type problems with possible letdown         line plugging from Boron precipitation.
f)   How are leakage problems from equipment outside containment considered?
: 6)   Why   should   credit   be given   for operator action even after ten minutes fallowing     an ATWS   event   injtiation7 TMI-2 experience does not provide enoughconfidence       in the ability of the operator to perform correct actions only in this short time period under high stress conditions.
In response.to     the staff concerns the industry made the following comnents.
AIF
: 1)   The   industry is frustrated because the staff concerns imply consideration of multiple failures and small LOCA which are beyond the credible events to be considered under ATWS. (Note - safety valve stuck open (small LOCA) is considered an anticipated transient).
: 2) Industry would like to wait for approximately six months before consider-ing ATWS evaluations to minimize duplicate expenditures.
l)   W   has submitted responses       to the 2/15/79 Mattson letter.
: 2)   Calculated peak pressure of 2800 > 2900 psi (for           Alt, 83) and proposed modifications in turbine         trip and auxiliary feedwater system actuation ci rcui try.
: 3)   EPRI   expects to issue     a request   for proposal to conduct tests on   PORVs and safety valves and       some results   should be available by end of   CY 79.
: 4)   Recommended     that "Early Verification"     approach should be continued.
CE -   Ed Shearer   speakin   for himself
: 1)   TMI   raises few questions like the behavior of S/R valves and the operator action. Further, prevention is better than mitigation and that mitigation would mean more and more analyses.
: 2)   Continue with early       verification.
 
a S. H. Hanauer BlkW
: 1)     Basically agrees with the staff concerns.         Industry has longer list of items that could impact ATWS.
: 2)     Stress analyses should       be completed.
: 3)     Likelihood of additional failures beyond         ATWS should be considered.
: 4)     Prevention is better than mitigation.
  ~BLfl 0       6
: 1)     ATWS is not   a safety pr.oblem.
: 2)     Even if ATWS   occurs, no significant risk to public health and safety.
: 3)     TMI-2 suggests a       desirability for realistic analyses. TMI-2 suggests a need to assure     that analyses bound the facilities.
4)-   Wait until "Lessons Learned" and "Bulletins and Orders" issues are resolved before pushing ahead with ATWS.
After the     above   industry   comments, the   staff made the following concluding remarks.
: 1)     We don't intend to     go too fast on ATWS.
: 2)     If Early   Verification is to     be pursued then there is a need to assure that
      - earlier   ATWS   analyses are correct and review the industry TMI-2 related list. In this regard the industry was invited to meet with the staff to discuss the technical issues which impact ATWS. The staff asked the indus-try to provide their assessment of TMI-2 impact on ATWS, the scope of           I effort to resolve these issues, and the schedule for performing this effort within 30 days.                                                                 I
: 3)     We cannot wait another year to make progress in       ATWS.
A. Thadani


==Enclosure:==
==Enclosure:==


As stated cc: See next page S.Hanauer cc: Meet)ng Attendees ATWS Distrfbut)on PDR RSB Files T.Spels ENCLOSURE ATWS Meetin with Vendors&AIF July 25, 1979 Ashok Thadani Arthur McBride.Alan Hosier Samir K.Sarkar Alan E.Ladieu Fred T.Stetson Richard G.Rateick Andrew J.Rushnok M.Srinivasan F.Akstulewicz G.Sorensen T.Speis F.C.Cherny J.A.Norberg Stuart Thickman Karl 0.Layer J.Ted Enos Ted Myers Robert Dieterick Michael J.Salerno S.Hardy Duerson Bob Steither Gary Augustine P.M.Abraham Mark Wisenburg Michael Tokar Paul Boehnert David Bessette Steven Traisman Sam Miranda Pat Loftus Fred Mosby Roger Newton Craig Grochmal Charles A.Daverid Robert L.Stright Joseph M.Weiss Joseph A.Gonyeau NRC/DSS B&W WPPSS FP&L YAEC A!F DECO OEC NRC/DSS NRC/DSE WPPSS/A IF NRC/DSS NRC/DSS NRC/OSD TVA-EN DES BBR AP&L TECo SMUD CPCo B&W W Duke Power USTVA-Office of Power NRC/DSS NRC/ACRS NRC/ACRS Pacific Gas&Electric W W Wyl e Laboratory Wisconsin Electric Power Stone&Webster Long Island Lighting Co.SNUPPS GE Northern States Power Seth M.Coplan Clayton L.Pittiglio~Kulin D.Desai Fuat Odar Kris Par czewski Roy Hoods Harold Vander Molen Gururajarao Rangarao Frank McPhatter Steve Banwarth William R.Murray Ben Rodell Don Swanson Paul Y, Holton Tommy Errington Ron Clauson Charles B.Brinkman C.L.Kling William BenjaminDenny Kreps Villiam E.Burchill A.E.Scherer Richard C.L.Qlson NRC/OSE NRC/OSE NRC/OSS NRC/OSS NRC/DOR NRC/DOR~NRC/DOR PASNY B&H BGH Virginia Electric 5 Power Co.VEPCO PGE Co.Bechtel Mississippi Power E Light Florida Power Corporation CE CE Commonwealth Edison Co.CE CE CE Baltimore Gas It Electric Co.  
As   stated cc:     See next page
~ENCLOSURE 2 I'etter from R.H.Bucholz (GE)to S.Hanauer,"ATWS Generic Analyses-Content of December 1979 Submittal", dated September 5, 1979.Letter from D.H.Taylor (BLM)to S.Hanauer,"B8W Commitments for ATWS", dated September 13, 1979.Letter A.E.Scherer (CE)to S.Hanauer,"NRC Request for Generic , ATWS Information", dated August 31, 1979.Letter L.0.DelGeorge (BMR 3 Owners representative) to S.Hanauer,"ATWS BMR/3 Plants and Vermont Yankee-Generic Analysis Supplement", dated August 28, 1979.Letter T.N.Anderson (W)to S.Hanauer,"ATWS", dated August 24, 1979.
 
altinore Gas 6 Electric Company 50-317 50-318 CC: Jan s A.Biddison, Jr.G neral Counsel G and E Building Charles Center Bal timore, tlaryl and 21203.George F.Trowbridge, Esquire Shaw,.Pittman, Potts and Trowbridge 1800 N Street, tt,tt.Washington, D.C.20036.ttr.R.C.L.Olson Baltimore Gas and'Electric Company Room 922-G and E Building Post Office Box 1475 Bal timore, Maryland 21203 fir.Leon B.Russell, Chief Enqineer Calvert Cliffs I!uclear Power Plant''altinore Gas and Electric Company Lusoy, ttaryland 20657" Bechtel Power Corporation ATTH: tlr..J.C.Judd Chief Nuclear Engineer 15740 Shady Grove Road Gaithersburg, ttaryland 20760 Combustion Engineering, Inc.ATTN: Nr.P.W.Kruse, Hanager Engineering Services Post Of fice Box 500 t"indsor, Connec ticut 06095 Cal vert County Library Prince Frederick, Maryland 20678 ttr.R.M.Douglass, Hanaoer gual ity Assurance Depart>rent Room 923 Gas 5 Electric Building P.0.Box 1475 Bal tirrare, Maryland.21203}}
S. Hanauer cc: Meet)ng Attendees ATWS Distrfbut)on PDR RSB Files T. Spels
 
ENCLOSURE ATWS Meetin with Vendors   & AIF July 25,   1979 Ashok Thadani                   NRC/DSS Arthur McBride                 B&W
.Alan Hosier                     WPPSS Samir K. Sarkar                 FP&L Alan E. Ladieu                 YAEC Fred T. Stetson                 A!F Richard G. Rateick             DECO Andrew J. Rushnok               OEC M. Srinivasan                 NRC/DSS F. Akstulewicz                 NRC/DSE G. Sorensen                     WPPSS/A IF T. Speis                       NRC/DSS F. C. Cherny                   NRC/DSS J. A. Norberg                   NRC/OSD Stuart Thickman                 TVA - EN DES Karl 0. Layer                   BBR J. Ted   Enos                   AP&L Ted Myers                       TECo Robert Dieterick               SMUD Michael J. Salerno             CPCo S. Hardy Duerson               B&W Bob Steither                   W Gary Augustine P. M. Abraham                   Duke Power Mark Wisenburg                 USTVA - Office of Power Michael Tokar                  NRC/DSS Paul Boehnert                  NRC/ACRS David Bessette                  NRC/ACRS Steven Traisman                Pacific Gas & Electric Sam Miranda                    W Pat Loftus                      W Fred Mosby                      Wyl e Laboratory Roger Newton                    Wisconsin Electric Power Craig Grochmal                  Stone & Webster Charles A. Daverid              Long   Island Lighting Co.
Robert L. Stright            SNUPPS Joseph M. Weiss                GE Joseph A. Gonyeau              Northern States Power
 
Seth M. Coplan       NRC/OSE Clayton L. Pittiglio   NRC/OSE
~
Kulin D. Desai         NRC/OSS Fuat Odar             NRC/OSS Kris Par czewski       NRC/DOR Roy Hoods             NRC/DOR Harold Vander Molen ~ NRC/DOR Gururajarao Rangarao   PASNY Frank McPhatter       B&H Steve Banwarth         BGH William R. Murray     Virginia Electric  5 Power Co.
Ben Rodell             VEPCO Don Swanson           PGE Co.
Paul Y, Holton         Bechtel Tommy Errington       Mississippi Power E Light Ron Clauson           Florida Power Corporation Charles B. Brinkman   CE C. L. Kling           CE William Benjamin      Commonwealth Edison Co.
Denny Kreps           CE Villiam E. Burchill   CE A. E. Scherer         CE Richard C. L. Qlson   Baltimore Gas It Electric Co.
 
                                                                      ~
ENCLOSURE 2 from R. H. Bucholz (GE) to S. Hanauer, "ATWS Generic Analyses-I'etter Content of December 1979 Submittal", dated September 5, 1979.
Letter from D. H. Taylor   (BLM)       to S. Hanauer, "B8W Commitments for ATWS", dated September   13, 1979.
Letter A. E. Scherer (CE) to S. Hanauer,         "NRC Request for Generic   ,
ATWS Information", dated August 31, 1979.
Letter L. 0. DelGeorge (BMR 3 Owners       representative)   to S. Hanauer, "ATWS BMR/3 Plants and Vermont Yankee - Generic Analysis Supplement",
dated August 28, 1979.
Letter T. N. Anderson (W) to S. Hanauer,       "ATWS", dated August 24, 1979.
 
50-317 altinore     Gas 6 Electric   Company                           50-318 CC:
Jan   s A. Biddison, Jr.                               ttr. R. M. Douglass, Hanaoer G neral Counsel                                       gual  ity Assurance Depart>rent G and   E Building                                    Room 923 Gas    5 Electric Building Charles Center                                         P. 0. Box 1475 Bal timore, tlaryl and       21203                    Bal tirrare, Maryland    .21203
. George F. Trowbridge, Esquire Shaw,. Pittman, Potts and Trowbridge 1800 N Street, tt,tt.
Washington, D.         C. 20036
. ttr. R. C. L. Olson Baltimore       Gas and'Electric Company Room 922     - G and   E Building Post Office Box 1475 Bal timore, Maryland         21203 fir. Leon B. Russell, Chief Enqineer Calvert Cliffs I!uclear Power Plant Gas and Electric Company     ''altinore Lusoy, ttaryland         20657
" Bechtel Power Corporation ATTH:     tlr..J. C. Judd Chief Nuclear Engineer 15740 Shady Grove Road Gaithersburg, ttaryland           20760 Combustion Engineering,           Inc.
ATTN:     Nr. P. W. Kruse, Hanager Engineering Services Post Of fice Box 500 t"indsor,     Connec   ticut   06095 Cal vert   County     Library Prince Frederick, Maryland             20678}}

Latest revision as of 01:10, 4 February 2020

Requests Deletion of License Condition (3)(c),per Encl Revised Response to Question 212.40 in App Q of Fsar. Revision Due to Util Misinterpretation of Requirements Re Check Valve Leak Testing.W/Fee & Affidavit
ML17326A329
Person / Time
Site: Cook American Electric Power icon.png
Issue date: 10/29/1979
From: Dolan J
INDIANA MICHIGAN POWER CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
AEP:NRC:00259, AEP:NRC:259, NUDOCS 7911090472
Download: ML17326A329 (27)


Text

REGULA'TORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESS I ON NBR 0 79 1 1 090472. DOC ~ DATE ~ 79/ 1 0/2 1 NOTARIZED YES ~ DOCKET FACIAL:50 316'Donald C ~ , Cook Nuclear Power Plenty Unit 2i Indiana L 05000316 AOTHBNAME",, AUTHOR AFFILIATION Dal AA J;E. Indiana 8 Rich,igan Power Cos-

'ECIPiNAME>> RECIPIENTT AFFlLIATION Office of Nuclear Reactor Regulation

'EATONgH.R',

SUBJECT:

Requests deletion of- License Condition (3)(c)iper encl revised response to. Question 212,40 in App Q of FSAR, Rev'is.ion due to 'util'misinterpietation of- requirements re check valve leak testing,H/fee 8 affidavits DISTRIBUTION CODE: A001S COPIES RECEIVED:LTR J 'NCL: J SIZE:

TITLEi. Genei al'istribut>on for; after- Issuance of Ojerat>ngT L'ic NOTES: Lq(QfkZI< ~K~~~ ~~~MDCL&+ AL4 ~M L'd~

RECIPIENT COPIES RECIPIENT COPIES ID'ODE/VAME t;TTR'NCL

" ID CaDEiNAME LTTR ENCL ACTION: . 05 BC Qgg 7 7 INTERNAL! - KG FIL 1 1 02 NRC PDR 2 2 14 TA/EDO

$ 5 COREA PERFT BR i 1 i7 ENGR BR 1S REAC SFTV BR 1, 19 PLANT SYS BR

20. EEB 1 1 21 EFLT TRT SYS 22 SAINKMAN i 1 EPB~DOR OELD 0 EXTERNALS 03 LPDR 1 1 04 NSIC 23 ACRS 16 16 ADV 13879 VX Vl TOTAl. NUMBER OF COPIES REQUIRED! LTTR ~ KNCL

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INDIANA II MICHIGAN POWER COMPANY Pi 6. BOX 18 BOWLING GREEN STATION NEw YoRK, N. Y. 10054 October 29, 1979 REP;NgC;Q0259.

Donald C..Cook Nuclear Plant Unit No. 2 Docket No. 50-316 License No. DPR-74 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S, Nuclear Regulatory Commission Washington, D.C. 20555 Dear Mr.

Denton:'urther review of Question 212.40 as contained in Appendix Q to the Donald C. Cook Nuclear Plant Final Safety Analysis Report' (FSAR) has led us to conclude that some of the testing described in the response is not necessary to satisfy the stated staff con-cerns and that the lists of valves need to be revised. The response to Question 212.40 was previously revised in our letter to Mr. Edson G. Case dated February 17, 1978. The intent of Question 212.40 is that we leak test the check valves which perform an isolation function of protecting low pressure safety systems from full reactor pressure.

The staff required that each check valve which performs this isolation function be identified and classified ASME IWV-2000 category AC with the leak testing being performed to code specifications. License condition (3) (c) was included in our Unit No. 2 operating license in accordance with the'ommitments made in our response to Question 212.40.

Our review has indicated that in the cases where low pressure systems are'isolated from full reactor pressure by check valves, the over-pressure protection of the low pressure system piping is provided by ASME code safety relief valves. As such, the check valve performs an isolation function but does not protect low pressure systems from full reactor pressure. Our misinterpretation of the staff position contained in Question 212.40 resulted in the commitments made in the response which became license condition (3) (c). The results of our review are con-tained in a revised response to Question 212.40 which is attached for your review. We request tha't operating license condition '(3) (c) be de-leted in accordance with the attached revision to Question 212.40.

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Nr. Harold R. Denton, Di'rector AEP;NRC:00259 This revision to the question 212.40 response does not inyolve an unreviewed safety question or Technical Specification change, nor it will endanger the health or safety of the public. We intend to formally incorporate this revised response into the FSAR as part of a future Amendment.,

Our review indicates that this revision constitutes a fee Class III Amendment to the facility license. In accordance with 10 CFR 170.22, we therefore enclose a check for $ 4,000,00.

Very truly yours, John E. Dol an Vice President cc:. R. C. Callen G. Charnoff D. V. Shaller-Bridgman R. S. Hunter RE W. Jurgensen

0 Res onse to uestion 212.40 There are no check valves which protect low pressure piping from full reactor pressure. This overpressure protection is provMed by safety relief valves on the low pressure piping systems as described below.

This response addresses the staff concern system by system. The design pressure of the boron injection system is higher than the design pressure of the Reactor Coolant System (RCS). Therefore the check valves in the boron injection system do not perform the function of protecting a low pressure system from full reactor pressure.

The function of protecting the Emergency Core Cooling Systems (ECCS) from fully reactor pressure is performed by safety relief valves. The ECCS lines to the RCS hot legs are isolated by normally closed valves.

The Residual Heat Removal normal cooldown line is isolated by normally closed valves. The check valves in the other ECCS lines perform an isolation function only to the extent that any leakage should not exceed the capacity of the associated safety valves. In each case, there are either two or three check valves in series between the RCS and the ECCS components with a lower pressure rating. These series check valves are listed in Table 212.40-1 along with the associated safety valves which protect the lower pressure systems. For each check valve, the

. rated capacity and pressuro setting of the associated safety valve(s) are adequate to protect the low pressure piping system. The allowable leakage rate for each listed check valve was determined, very con-servatively, based on the lowest relief capacity of the associated safety valve(s) and under the assumptions that all the other check valves in series are fully open and that all the other check valves in parallel leak at the maximum allowable rate.

The performance of the check valves in isolating the ECCS from full reactor pressure is tested at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during operational modes 1, 2, 3 and 4 by Technical Specification surveillance requirement 4.4.6.2d. to demonstrate that unidentified leakage from the RCS is limited to 1 gpm. Because this limit is well below the allowable leakage rate through any check valve, the adequacy of these check valves to perform thei'r isolation function is continuously verified by satisfaction of this survei'llance requirement. Because of this requirement, any gradual de-teri'oration of the check valve seats will be recognized and remedied.

These valves are located in systems that are normally maintained full of liquid, with either high pressure on the downstream side of the disc or no differential pressure across the disc. In this application, where th'e check valve is normally closed, any sudden, severe damage to the seating surface is very unlikely.

212.40-2

The test frequency for exercising the valves identified'n Table 212.40-1 is in accordance with ASI1E Section XI paragraph IW-3520 of the 1974 edition with addenda through the summer of 1975. These valves are normally closed during plant operation and cannot be exercised without initiating conditions similar to a safety injection. These valves will be exercised during cold shutdowns as stated in our Inservice Inspection Program submittals dated September 29, 1977 and September 22, 1978 (the latter resubmitted September ll, 1979.)

The design pressure of the Chemical and Volume Control System (CVCS) on the discharge side of the charging pumps is higher than the design pressure of the RCS. Therefore the discharge side of the CVCS does not require pro-tection from full reactor pressure. The suction side of the charging pumps is protected by the suction header safety relief valve. The CVCS reciprocating charging pump discharge check valve i s not required to perform a pressure isolation function because the construction of a multi-piston, positive dis-

. placement pump precludes pressure propagation in the reverse direction. The centrifugal charging pump discharge valves perform an isolation function only to the extent that any leakage should not exceed the capacity of the suction header safety relief valve. These check valves are listed in Table 212.40-2 along with the associated safety valve which protects the low pressure portion of the system. The pressure setpoints and relief flow capacity ratings for the safety valves are adequate to protect the low pressure piping system.

The allowable leakage rate was determined assuming that all four check valves leak at the maximum allowable rate and that there is no recirculation. However, during all modes of plant operation with the Reactor Coolant System above 220 psi, normal practice. is to have one charging pump running. Therefore, any leakage through the discharge check valve of a non-operating centrifugal charging pump is recirculated by the operating pump and does not cause a significant in-crease in the suction side pressure.

The testing for "exercising" will be performed for the check valves in Table 212.40-2 in the same manner and at the same frequency as described above for those in Table 212.40-1.

212,40-3

I TABLE 212.40 - 1 ECCS SERIES CHECK YALVES Alloivable Check Valve Leakage Rate:

Protecting Check Valve Nomenclature Safet Val ve s

  • GPM SI151E ECCS Low Head Safety Injection SV-104E 400 SI151W ECCS Low Head Safety Injection SV-104W 400 SI152N ECCS Safety Injection SV-98A 20 SI152S ECCS Safety Injection SV-98B 20 SI161L1 SI Hot To Cold Leg Crosstie SV-98A 5 SV-104E 10 SI161 L2 SI Hot To Cold Leg Crosstie SV-98B 5 10 SY-104W SI161L3 SI Hot To Cold Leg Crosstie SY-98B 5 10 SV-104W SI161L4 SI Hot To Cold Leg Crosstie SV-98A 8 10 SV-104E SI166-1 Accumulator Discharge SV-100-1 47 SI166-2 Accumulator Discharge SY-100-2 47 SI166-3 Accumulator Discharge SV-100-3 47 SI166-4 Accumulator Discharge SV-100-4 47 SI170L1 ECCS Cold Leg Loop SV-98A, 10 SV-100-1 8(

SV-104E SI170L2 ECCS Cold Leg Loop SV-98B, 10 SV-100-2 &

SV-104M S I170L3 ECCS Cold Leg Loop SY-98B, 10 SV-100-3 5 SV-104W SI170L4 ECCS Cold Leg Loop SV-98A, 10 SY-100-4 8 SV-104E

".The Safety Valve designations are the same as those used in the Unit 2 ISI Program.

e TABLE 212.40 - 2 CVCS CENTRIFUGAL CHARGING PUMPS DISCHARGE CHECK VALVES Allowable Check Valve Protecting Leakage Rate Check Valve Nomenclature Safet Val ve s GPM CS299E Discharge SV-56 CS299M Discharge SV-56 CS297E Recirculation SV-56 CS297iI Recirculation SV-56

. Mr . Harold R. Denton, Director AEP:NRC:00259 STATE OF NEW YORK )

) ss.

COUNTY OF NEW YORK)

~ohn E Dolan, being duly sworn, deposes and says that he is the Vice President of licensees Indiana 8 Michigan Electric Company and Indiana 5 Michigan Power Company; that he has read the foregoing request and justificati'on for deletion of Condition (3) (c) on License No. DPR-74 and knows the contents thereof; and that said contents are true to the best of his knowledge and belief.

Subscribed and sworn to before me this 29th day of October, 1979.

Notary Public NOTA.,Y'yUobLcC, 5~co~ Ie ot liow Yock No. 4c-~~i" Gi 92 Queiifieo in 4ueens Courcy Cociiiicsiu fi!ed in iisw Ycck enoicoi cnecoh 30, 198 County'vccuno5con i

~y,fl REMI Wp UNITED STATES o NUCLEAR REGULATORY COMMISSION

I < WASHINGTON, D. C. 20555 0

+n qo

+a*<<+

OCT 17 1979 IIEMN08It 8fgKg I[ ~opy All Power Reactor Licensees All Applicants With Applications for a License Gentlemen:

This past March, the NRC transmitted to you a copy of Volume 3 of NUREG-0460, "Anticipated Transients Without Scram for Light Water Reactors" (ATWS) and a copy of an NRC letter that was sent this past February to each of the four nuclear reactor vendors. The letters to the vendors contained requests for information needed to perform generic analyses related to ATWS.

As we pointed out in our March letters, the generic analyses we requested were intended to confirm that the modifications proposed by the NRC staff for. various classes of LWR designs would in fact accomplish the degree of ATWS prevention and mitigation described by the staff in its report. We also pointed out that we had chosen to work'directly with the vendors in obtaining this information in an effort to conserve both NRC and industry resources. We requested that utilities cooperate with the vendors in per-forming the requested analyses. II Shortly after sending the letters to the vendors, the NRC Staff met with representatives of each of the NSSS vendors and many Utility representa-tives in Bethesda on March 1, 1979. The meeting was called to discuss the "early verification" approach in which we planned to use generic analyses as the basis for rulemaking. We hoped thereby to avoid costly a~d unneces-sary repetitive analysis for individual plants. At the meeting, a, tenta-tive schedule was agreed to for generic analyses for each class pf plants to be provided in three separate packages to be submitted May l,ISeptember 1, and December 1, 1979.

I og yv 1979

<<y o o g ch 1 meeting, the NRC staff met separately with of h NSSS vendors and agreement i upplied in the May 1 package. Also, as note a ATWS stqff report and the generic analyses questions w Utilities.

n I sl and acci dent occurre d . Because e of the heavy e uired for Three Ml i e Is 1 d ltd ed to the ATWS issue for three months o r t t 1 b t ti 1 d tio n effort on the part of the PWR industry during that perio,d an d o d tio fo BWR of Nuclear Reactor Regulation was temporarily reorganized. Within thi s interim organization a gr d d th direction of S. Hanauer to work on t e nre i nat-ed by the Commission and reported to Congress Con ress this past January in NUREG-0 - 510.

ATWS is one of these 19 issues.

'he A reliminary pre NRR Staff review su ested that, suggeste a , for PWRs,, the Three Mile Island land accident raised new questions w g

t. the technical impact of Three Mile s corn letion and review o e 1 for BWRs as specified in March should procee roceed as eexpeditiously as possible.

da on July 25, 1979 to discuss, with representa-v s o i ie e ig r considerations arising from the Three a copy of the staff minute tes of that meeting is a tt h d E lo 1 A can be seen from ro the minutes, at the meeting tin the staff:

is still believed by the staff to be a serious sa ey 0 " e p rotection should be provided. We stated that we are unwilling to wait anot er year on ATWS.

1 and s ecific technical concerns raised by the Three Mile Island accident with regard to thee ATWS resolution pro-posed in Volume 3 of NUREG-0460.

rovide in writing, within 30 days of the meeting ent of the Three Mile Island impact on ATWS, to resolve TMI issues, and a realistic roviding the needed ATW ATWS in orm both the March request an d thee TMI-related analyses.

QCT 17 1979 gsubsequent to the July 25 meeting, we have met with representatives of the four g NSSS vendors and of some Utility/Owners. We have met with GE to discuss the scope qf the remaining generic analysis information to be supplied for BWR 4/5/6's. We have also met with representatives of the GE BWR/3 Owners, B8W, BEW ATWS Owners Group, W, W ATWS Owners Group, and CE. At all these meetings, we considered further the required information and the schedule for its sub- .

mittal.

We have now received letters (see the list in Enclosure 2, attached) from the various groups describing the information to be furnished and projected schedules.

On the basis of our review of these letters and meetings with the industry representatives, we perceive that the projected responses in several cases would not address several questions in our ~February 15 letter. In particular, several items are lacking that we will need to justify acceptance of the hardware approaches of NUREG 0460 Vol 3 rather than using the design basis accident approach.

I am determined to submit a proposed ATWS rule to the Commission for both PWRs and BWRs early in 1980. The type and content of the rule we will propose will depend critically upon the types and content of the information available to the staff. This will, of course, include whatever responses are actually pro-vided by the industry in response to the questions attached to the February 15 staff 'letter, the March meetings, and the Three Mile Island related concerns as discussed in the July 25 and subsequent meetings.

I still believe that it is possible for the early verification generic analysis program to provide an acceptable resolution of'he ATWS issue and that this is the way to achieve resolution with the least possible expenditure of NRC and industry resources. However, I want to reiterate that the success of this approach depends on whether or not all of the information necessary for the staff to confirm that its proposed ATWS modifications provide an acceptable level of protection, for all plants, is provided by the industry.

I strongly encourage you to join or form Utility/Owners Groups, if you have not already done so, and provide the resources necessary to supply the needed tech-nical information pertaining to your plants, either operating or under construc-tion. It would further reduce the impact on the industry as well as the staff resources if the ATWS effort coordination and the review role is performed by one industry group, If you haye additional questions on the generic analysis early verification program discussed in this letter, please contact Mr. Ashok Thadani, (301-492-7341).

Sin ly, s

~

H. R, 'Denton,

~

~ Director Office of Nuclear Reactor Regulation

Enclosures:

1. NRC-Industry ATWS Meeting Summary dtd 7/25/79
2. List of letters from Industry on Content of Report Submittals

' 4, ENCLOSURE 1 g RECg

~

tp 0 UNITED STATES NUCLEAR REGULATORY COMhlISSION WASHINGTON, D. C. 20555 y~ ~*4 JUL 2P 1379 Task Action Plan A-9 MENORANOUtl FOR: S. H. Hanauer FROM: A. Thadani

SUBJECT:

NRC-INDUSTRY ATWS tlEETING'UIlMARY Th e sataff met- with the PWR vendors, the Atomic Industrial Forum (AIF) and utility representatives to discuss the impac t of TMI-2 events me-w'everal on the ATWS resolution plan described in Volume 3 of NUREG-0460.

The staff'ade the following initial remarks:

1) ATWS is still a safety concern and protec ion from these events must be d d Alth h plants need not be shutdown immediately because of relatively low likelihood of a severe ATWS in a PWR in the nex p of years, ATMS resolution with suitable speed is necessary to permit an implementation plan which would assure an acceptably low risk from ATWS over the life of nuclear plants.
2) The staff would like to recei,ve industry views on the impact of TflI-2 on ATWS and how to proceed from now on to resolve ATWS. The staff noted that they intend to propose an ATMS solution to the Commission preferably with but if necessary without the industry input.
3) In view of TMI-2 accident, the staff expressed the following general con-cerns with the Vol. 3 proposed resolution and asked for industry comments.

a) What assurance do we have that the excessive calculated pressures for some designs modified per Alternative 83 would not result in loss of integrity of reactor coolant pressure boundary. (Note - Some designs may experience peak pressures - 4000 psi).

b) Would increasing the number of safety valves as per Alternative 84 result in insufficient overall risk reductionf Would the primary system integrity be maintained? Would it be better to have larger capacity valves'

S. H. Hanauer I

I c)) In v i ew 0 f que stions a and b above, the pressurizer relief and safety valves must be qualified for water relief to assure that th e nozzles, valve body and the support s .ructure integrity will be maintained

'he and to estimate discharge flow rate and the likelihood and effects of valve chatter.

d) I nve i w of significant plant differences in the designs of auxiliary feedwater system, Emergency Core Cooling Systems and other s ystems how would the industry provide assurances that plant specific

~

f ea tures have been adequately addressed in the "Early Verification" approach for resolving ATMS as described in NUREG-0460, Vol. 3.

e) Other Lessons Learned from TNI-2.

Following prelim>nary comments from the NRC staff members, G. Sorensen of WPPS who is. also the Chairman of the AIF ATMS committee, made the following comments.

1) ATMS is not a safety issue but rather it is a licensing issue which needs resolution.
2) AIF in concert with the industry had reviewed ATMS in light of TMI-2 and had concluded that the Alternative 84 fix {mitigation) in Vol. 3 of NUREG-0460 is not the correct solution to ATMS. The industry believes that the alternative 82 fix {Prevention - Electrical Portion of RPS) is the appropriate ATMS solution.
3) Industry recognizes the THI-2 impact on the role of the operator, his training aids and other lessons learned from this event. The industry believes that there is no need to rush to resolve ATWS because of the low probability of ATMS and because some of the anticipated changes to plants as a result of TMI-2 accident review would direct resources to other issues.

Following the AIF presentation, the staff raised their concerns that the ATWS resolution {not yet achieved) gas been anything but hasty, that the NUREG docu-t ATHS have been out for sufficiently long time period, that protection from ATWS is necessary, that THI-2 H event has raised ""oncerns with the ana 1 y ses assumptions and therefore the htaff needs industry technical assessment of the TMI-2 impact on ATWS. The staff suggested that the THI-2 event indicates a need to answer at least the following specific questions.

S. H. Hanauer 1) Analyses indicate the sensitivity of peak pressure to AFWS design and actuation time for some plants.

Mhy should auxiliary feedwater actuation not be delayed beyond technical spehification values? What bases are available to assume AFWS actua-tion earlier than the technical specification value? How do the analyses take into consideration the limits on AFWS injection rate due to water

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hammer considerations? How is the impact of flow restrictors on some AFMS designs considered in the ATWS analyses? How are the significant plant specific features of AFWS treated in the analyses?

2) As in question 1 above how are the differences in ECCS designs evaluated?

For example, for some ATMS events, the pressure and the pressurizer level remain hiqh enough such that either the HPSI cannot be actuated (because of shut off head considerations) or the operator may fail to actuate HPSI because of insufficient available information.

3) Would single failure cause all PORVs to fail to open? If so, then analyses must be based on all PORVs failing to open. Further, several plants are operating today with PORVs isolated. For these plants credit cannot be taken for relieving capability of these valves.
4) What assurance do we have that the ATWS events with a stuck open safety

. valve have been correctly analyzed? What is the potential for core un-covering under this scenario? What is the importance of ECCS actuation, reactor coolant pumps operation, and the pressurizer safety/relief valve discharge model on the potential for uncovering of the core? Further, why should more valves not be assumed to stick open following discharge of subcooled water.

5) For long term shutdown, discuss the following:

a) available equipment, instrumentation and their qualification. (Must consider the effect of water discharged to the containment via ruptured quench tank).

b) impact of loss of offsite power c) continued operation 'of reactor coolant pumps. Also consider tripping of reactor coolant pumps.

d) Describe natural circulation, including effects of non-condensables.

Is reflux boiling mode of operation anticipated? If so, justify.

S. H. Hanauer 4-e) Would one anticipate Boron precipitatton problem? Also consider TMI-2 type problems with possible letdown line plugging from Boron precipitation.

f) How are leakage problems from equipment outside containment considered?

6) Why should credit be given for operator action even after ten minutes fallowing an ATWS event injtiation7 TMI-2 experience does not provide enoughconfidence in the ability of the operator to perform correct actions only in this short time period under high stress conditions.

In response.to the staff concerns the industry made the following comnents.

AIF

1) The industry is frustrated because the staff concerns imply consideration of multiple failures and small LOCA which are beyond the credible events to be considered under ATWS. (Note - safety valve stuck open (small LOCA) is considered an anticipated transient).
2) Industry would like to wait for approximately six months before consider-ing ATWS evaluations to minimize duplicate expenditures.

l) W has submitted responses to the 2/15/79 Mattson letter.

2) Calculated peak pressure of 2800 > 2900 psi (for Alt, 83) and proposed modifications in turbine trip and auxiliary feedwater system actuation ci rcui try.
3) EPRI expects to issue a request for proposal to conduct tests on PORVs and safety valves and some results should be available by end of CY 79.
4) Recommended that "Early Verification" approach should be continued.

CE - Ed Shearer speakin for himself

1) TMI raises few questions like the behavior of S/R valves and the operator action. Further, prevention is better than mitigation and that mitigation would mean more and more analyses.
2) Continue with early verification.

a S. H. Hanauer BlkW

1) Basically agrees with the staff concerns. Industry has longer list of items that could impact ATWS.
2) Stress analyses should be completed.
3) Likelihood of additional failures beyond ATWS should be considered.
4) Prevention is better than mitigation.

~BLfl 0 6

1) ATWS is not a safety pr.oblem.
2) Even if ATWS occurs, no significant risk to public health and safety.
3) TMI-2 suggests a desirability for realistic analyses. TMI-2 suggests a need to assure that analyses bound the facilities.

4)- Wait until "Lessons Learned" and "Bulletins and Orders" issues are resolved before pushing ahead with ATWS.

After the above industry comments, the staff made the following concluding remarks.

1) We don't intend to go too fast on ATWS.
2) If Early Verification is to be pursued then there is a need to assure that

- earlier ATWS analyses are correct and review the industry TMI-2 related list. In this regard the industry was invited to meet with the staff to discuss the technical issues which impact ATWS. The staff asked the indus-try to provide their assessment of TMI-2 impact on ATWS, the scope of I effort to resolve these issues, and the schedule for performing this effort within 30 days. I

3) We cannot wait another year to make progress in ATWS.

A. Thadani

Enclosure:

As stated cc: See next page

S. Hanauer cc: Meet)ng Attendees ATWS Distrfbut)on PDR RSB Files T. Spels

ENCLOSURE ATWS Meetin with Vendors & AIF July 25, 1979 Ashok Thadani NRC/DSS Arthur McBride B&W

.Alan Hosier WPPSS Samir K. Sarkar FP&L Alan E. Ladieu YAEC Fred T. Stetson A!F Richard G. Rateick DECO Andrew J. Rushnok OEC M. Srinivasan NRC/DSS F. Akstulewicz NRC/DSE G. Sorensen WPPSS/A IF T. Speis NRC/DSS F. C. Cherny NRC/DSS J. A. Norberg NRC/OSD Stuart Thickman TVA - EN DES Karl 0. Layer BBR J. Ted Enos AP&L Ted Myers TECo Robert Dieterick SMUD Michael J. Salerno CPCo S. Hardy Duerson B&W Bob Steither W Gary Augustine P. M. Abraham Duke Power Mark Wisenburg USTVA - Office of Power Michael Tokar NRC/DSS Paul Boehnert NRC/ACRS David Bessette NRC/ACRS Steven Traisman Pacific Gas & Electric Sam Miranda W Pat Loftus W Fred Mosby Wyl e Laboratory Roger Newton Wisconsin Electric Power Craig Grochmal Stone & Webster Charles A. Daverid Long Island Lighting Co.

Robert L. Stright SNUPPS Joseph M. Weiss GE Joseph A. Gonyeau Northern States Power

Seth M. Coplan NRC/OSE Clayton L. Pittiglio NRC/OSE

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Kulin D. Desai NRC/OSS Fuat Odar NRC/OSS Kris Par czewski NRC/DOR Roy Hoods NRC/DOR Harold Vander Molen ~ NRC/DOR Gururajarao Rangarao PASNY Frank McPhatter B&H Steve Banwarth BGH William R. Murray Virginia Electric 5 Power Co.

Ben Rodell VEPCO Don Swanson PGE Co.

Paul Y, Holton Bechtel Tommy Errington Mississippi Power E Light Ron Clauson Florida Power Corporation Charles B. Brinkman CE C. L. Kling CE William Benjamin Commonwealth Edison Co.

Denny Kreps CE Villiam E. Burchill CE A. E. Scherer CE Richard C. L. Qlson Baltimore Gas It Electric Co.

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ENCLOSURE 2 from R. H. Bucholz (GE) to S. Hanauer, "ATWS Generic Analyses-I'etter Content of December 1979 Submittal", dated September 5, 1979.

Letter from D. H. Taylor (BLM) to S. Hanauer, "B8W Commitments for ATWS", dated September 13, 1979.

Letter A. E. Scherer (CE) to S. Hanauer, "NRC Request for Generic ,

ATWS Information", dated August 31, 1979.

Letter L. 0. DelGeorge (BMR 3 Owners representative) to S. Hanauer, "ATWS BMR/3 Plants and Vermont Yankee - Generic Analysis Supplement",

dated August 28, 1979.

Letter T. N. Anderson (W) to S. Hanauer, "ATWS", dated August 24, 1979.

50-317 altinore Gas 6 Electric Company 50-318 CC:

Jan s A. Biddison, Jr. ttr. R. M. Douglass, Hanaoer G neral Counsel gual ity Assurance Depart>rent G and E Building Room 923 Gas 5 Electric Building Charles Center P. 0. Box 1475 Bal timore, tlaryl and 21203 Bal tirrare, Maryland .21203

. George F. Trowbridge, Esquire Shaw,. Pittman, Potts and Trowbridge 1800 N Street, tt,tt.

Washington, D. C. 20036

. ttr. R. C. L. Olson Baltimore Gas and'Electric Company Room 922 - G and E Building Post Office Box 1475 Bal timore, Maryland 21203 fir. Leon B. Russell, Chief Enqineer Calvert Cliffs I!uclear Power Plant Gas and Electric Company altinore Lusoy, ttaryland 20657

" Bechtel Power Corporation ATTH: tlr..J. C. Judd Chief Nuclear Engineer 15740 Shady Grove Road Gaithersburg, ttaryland 20760 Combustion Engineering, Inc.

ATTN: Nr. P. W. Kruse, Hanager Engineering Services Post Of fice Box 500 t"indsor, Connec ticut 06095 Cal vert County Library Prince Frederick, Maryland 20678