ML20029E534
| ML20029E534 | |
| Person / Time | |
|---|---|
| Issue date: | 12/20/1989 |
| From: | NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | |
| Shared Package | |
| ML20028G717 | List: |
| References | |
| REF-GTECI-B-56, REF-GTECI-EL, TASK-B-56, TASK-OR NUDOCS 9405190045 | |
| Download: ML20029E534 (19) | |
Text
_-.
6 BRIEFING FOR THE COPNITTEE TO REVIEW GENERIC REQUIREENTS (CRGR)
PROPOSED FINAL PlJLE ON STORAGE OF SPENT FUEL IN NRC-APPROVED CASKS AT NUCLEAR POWER REACTOR SITES BY DIVISION OF REGULATORY APPLICATIONS OFFICE OF NUCLEAR REGULATORY RESEARCH i
BILL MORRIS X23750 SHER BAHADUR X23775 FNBB Room 6110 BILL PEARSon X23764 DECEMBER 20,1989 N
CRGR MEETING 176 PDR to Enclosure 2
l l
l l
l l
l l
BACKGROUND LEGAL EASIS SECTION 133 0F THE NUCLEAR WASTE POLICY ACT OF 1982 (NWPA) milch SAYS ESTABLISH PROCEDURES FOR' LICENSING NRC-APPROVED TECHNOLOGY BY RULE.
NOVEMBER 9,1988 PRESENTED PROPOSED RULE FOR t
CRGR REVIEW l
j l
C0fHITTEE REQUESTED BRIEFIfG ON l
ACC0ffANYING CERTIFICATE OF i
i COMPLIANCE Ato REGULATORY l
GUIDES DECEMBER 114,1988 PRESENTED FOR CRGR REVIEW A l
SAMPLE CERTIFICATE OF i
l COMPLIANCE AND Th0 IMPLEMENTING REGULATORY GUIDES j
CortITTEE RECCofiEtiDED IN FAVOR OF ISSUING THE PROPOSED RULE
. 2
_0VEPVI&! 0F THE RULE THE RULE WILL PE&ilT ONSITE STORAGE OF SPENT FUEL WDER GENERAL LICENSE IN AN NRC-APPROVED DRY STORAGE CASK.
THE LICENSEE WILL HAVE TO DEMONSTRATE THAT:
-No UNREVIEWED SAFE 7Y QUESTIONS WERE INVOLVED; 4 TECHNICAL SPECIFICATION CHANGES ARE REQUIRED
-THE SECURITY PLAN HAS BEEN REVIEWED AND MODIFIED IF NEEDED; AND
--THE FUEL IS STORED IN COMPLIANCE WITH THE CASK'S CERTIFICATE OF COWLIANCE.
THE RULE APPLIES TO'ALL POWER REACTOR LICENSEES.
THE SAFETY REQUIREMENTS OF 10 CFR PART 72 REMAINS IN EFFECT.
i 3
PUBLIC COM9fiS PUBLISHED THE PROPOSED RULE FOR PUBLIC C0ft1Et6S ON MAY 5, 1989 RECEIVED 273 PUBLIC CGtiEf6 LETERS; THE STAFF IDENTIFIED 50 SPECIFIC C0ft1ENTS.
THREE C0t! Elds OF SPECIAL INTEREST CAN BE IDENTIFIED AS FOLLOWS:
-RULE WILL ELIMINATE PUBLIC INPUT FOR STORAGE
--CASK DESIGN SHOULD BE C0ffATIBLE WITH THE DOE REQUIREMENTS FOR TRANSPORTATION AhTJ STORAGE
--TEOiNOLOGIES OTHER THAN DRY CASKS SHOULD ALSO BE CONSIDERED
- ALL C0ft1ENTS HAVE BEEN ADDRESSED IN THE STATEMENT OF CONSIDERATION, AND CAUSED ONLY MINOR CHANGES IN THE FINAL RULE.
I i
lh _
... ~.
't OiANGES IN THE FINAL RULE i
IN ADDITION TO MINOR EDITORIAL / CLARIFYING MODIFICATIONS, THE FOLLCHING CHANGES HAVE BEEN IfCORPORATED IN THE FINAL RULE:
THE SEARCH REQUIREMENTS FOR FIREARMS AND EXPLOSIVES IS RELAXED TO THE PAT-DOWN SEARCH IN LIEU OF DETECTION EQUIPMENT.
AN APPLICATION FOR REAPPROVAL OF A CASK DESIGN SHOULD BE SUBMITTED AT LEAST 30 DAYS PRIOR TO ITS EXPIRATION DATE.
THE EXISTING CERTIFICATE OF COMPLIANCE WOULD REMAIN EFFECTIVE LNTIL THE CCtNISSION t%KES A FINAL DETERMitMTION.
)
i 5
ASSESSMENT OF OVER-PRESSURIZING A STORAGE DUE TO LOADING OF " FRESH" SFENT FUEL j
This assessment aodresses the potential for over pressurizing a s storage cask caused by loading fuel that has not cooled the minimum n
uel Resultant fuel pin temperatures are estimated and the potential cons are also assessed.
" overloaded" cask condition are discussed. Finally, potential indicatio equences S yr cooled fuel) was used as the basis for this assessmentThe CASTOR V/
assumed to be loaded entirely with 1 year cooled fuel and 150 day co The cask was e.
between the primary and secondary lid seals press e space exceedthedesignpressureofthgseals(8bar), temperatures (basedofthe In order to ideal gas law) greater that 3960 fuel melting would be expected (>4500C wguld be reggired.At such temperatures F or 2482 C).
For a cask loaded entirely with one year cooled spent fuel, the decay heat of the assem would be about 5 times the design heat load of a cask with 5 year c This would rgsult in estimated peak fuel rod cladding temperatures i e
uel.
range of 900 - 1400 C.
At these temperatures, one would expect n the depressurization of the fuel rods through pinhole defects accompan gap release of fission products to the cask cavity.
e y the cooled fuel, the decay heat load would be about 10 times the des Similarly, for 150 day the cask and gesult ig estimated peak fuel rod cladding temper tr range of 1100 - 1900 C.
a ures in the grain boundary release of fission products to the cask cavity cask cavity pressure (assuming all fuel rods are depressurized) wo At 1900 C the 7 bar; less than the 8 bar design pressure of the seals out j
There are indicators that will be monitored, other than direct m the cuk temperature, that should alert the licensee of a highl easurement of cask condition.
fuel, cask surface dose rates would be greater than for th y " overloaded" For example, a cask loaded with 1 year cooled fuel would have a tota s gn bases fuel.
surface dose rate (n + y) approximately 3 times greater than for a cask with the design basis 5 year cooled fuel.
would most likely be detected during cask vacuum emperatures, detectors in the fuel handling building exhaust system y radiation monitoring systems would alert the licensee to loss of cask confinement Further, seal A heat transfer and shielding performance test was conducted on a CASTOR V/21 cask.
heat rates near 1 kW and the remaining eight assemblies ha approximately 1.8 kW (26 months cooled).
ecay heat rates heat transfer test indiceted:for the cask was approximately 28 kW (
The results of the high decay heat (1.8 kW) outer assemblies."None of the peak temperatures occ In general, the cask heat transfer Attachment UAJJ6*h#
2 oerformance was concluded to be exceptionally good because the pea temperatures in helium, when the cask was dissipatin
{
topical report prepared by GNS."less than that specified for the c g approximately 28kW,-was n the cask "The total dose rates along most of the cask sides are less than The overall shielding performance of the CASTOR-V/21 cask was mrem /hr.
the intended design goal good and met strength than fuel considered in the GNS topical report.".. even thougn test provided additional confidence in the cask thermal and shieldi The performance.
evaluation models and information about the degree of conserva ng to safely store some inadvertently mis-loaded s n
es beyond the design or operating limits of the cask.
at are Based on the above assessment, there is reasonable assurance th entirely loaded with. fuel cooled less than a year could be expecte the spent fuel and that a highly mis-loaded cask would have suffi i indicators to alert the licensee of a potential problem c ent 1
.m.
~
,., ~..
....m.,
i to the Minutes of CRGR Meetina No. 176 Prooosea Revision 3 to Reaulatory Guide 1.0. " Diesel Generator Reliability" December 20, 1990 TOPIC I
A. Serkiz (RES) and W. Minners (RES) presented for CRGR review a revised proposal for Revision 3 to Regulatory Guide 1.9, " Diesel Generator Reliability."
This proposed backfit action (i.e., imposition of new EDG reliability program requirements, in connection with resolution of the static, blackout issue), was i
reviewed earlier by CRGR at Meeting No. 171.
The Commit: ae made a number of recommendations for modification of the package at the time.
The package had been revised by RES in response to those recommendations.
Responses to questions
'j and comments on backfitting had been included.
The proposed regulatory guide had been made consistent with the then current draft industry standards (Enclosure F to the transmittal memorandum), although it still contained its own (different) description of the basic recommendations in Sections C3-C6.
i Briefing slides used by the staff in their presentation to the Committee are provided as an attachment to this enclosure, i
BACKGROUND i
The revised package was transmitted by a memorandum dated December 13, 1989 from E. Beckjord to E. L. Jordan.
The revised package included:
{
1.
Enclosure A
" Response to CRGR Comments," dated 11/29/89.
- 2. - Working Draft, dated 11/18/89, of Rev. 3 to Reg. Guide 1.9.
3.
Enclosure C - Draft Generic Letter, dated 12/13/89.
4.
Enclosure D - Revised Backfit Analysis, dated 12/13/89, for proposed i
resolution of GSI B-56.
5.
Enclosure E - Draft Federal Register Notice, dated 12/13/89, for proposed resolution of GSI B-56.
6.
Enclosure F - NUMARC 8700, Draft Appendix 0, dated November 6, 1989.
1 CONCLUSIONS / RECOMMENDATIONS The Committee did not complete its review of this matter but identified a number of issues which the staff agreed to address.
Specific agreements and comments are provided below:
1.
Following discussions related to guidance proved in NUMARC's revised Appendix D (Enclosure F to the transmittal memorandum) and Regulatory
1 Guide 1.9, Rev. 3 (Enclosure B to the transmittal memorandum), the Committee reacned a consensus that NUMARC's Appendix 0 provided acceptable guidance for monitoring EDG reliability and an EDG reliability program, provided that licensees committed to implementing such a program and
)
monitoring procedures.
Appendix D could be adopted by reference in the
' Regulatory Guide (as an industry standard).
Sections C.3, C.4, C.S and
{
C.6 would be reduced in size through reference to Appendix D.
The RES staff tentatively agreed, subject to the understanding that a thorough review of the Appendix D would be needed to verify the accept-ability of Appendix D as formally submitted.
Final determination of the contents of the Reg Guide, generic letter, Federal Register Notice would l
then be made.
2.
The consensus discussed in item 1 above was subject to the condition that NUMARC agree with the approach, adopt the draft standard.as a final j
stanoard and make the final standard available to the public.
3.
The Committee reached a consensus that the generic letter transmitting the guide would not need to cite 10 CFR 50.54f if NUMARC would get industry agreement and have licensees. submit letters committing to the industry standard.
i It was agreed that NRR would contact NUMARC to' initiate pursuit of this approach.
If the commitments were not forthcoming the generic letter should cite 10 CFR 50.54f.
4.
The CRGR considered issuance of the regulatory guide to be a backfit, (regardless of whether or not licensees committed to the industry standard as discussed in item 3 above) since' issuance of the guide would apply a new staff position to operating plants.
i i
5.
With regard to backfitting, it was recognized that the conclusions on substantial safety improvement and cost justification had been made for the overall generic issue in connection with issuance of the blackout rule.
This regulatory guide revision was considered a necessary final step although additional explanation for this action was needed.
The backfit discussion in the proposed generic letter and the proposed backfit analysis should be revised accordingly.
6.
The CRGR indicated that it would review the revised regulatory guide at a future meeting and would at least circulate the revised generic letter to the members.
Further, it would review the basis for the action (backfit discussion and backfit analysis) at a future meeting.
7.
It was noted that the industry standard was more detailed than normal regulatory guidance and NRC inspectors should not focus on the finer details in the standard.
It was agreed that NRR should provide i
appropriate guidance to the inspectors for this area in accordance with normal procedures.
8.
On page 9 of the proposed guide, footnote 3 should be removeo and reference to INPO should be removed from footnote 2.
L I
i I
RESOLUTION OF GSi B-56 I
I i
PRESENTATION TO THE COMMITTEE l
TO REVIEW GENERIC REQUIREMENTS i
1 j
CRGR Meeting No.176 i
December 20, 1989 in
!i
?
iH is
- 2 i
A.W. Serkiz RES/DSIR/RPSIB g
MS NL/N 314 EXT. 23942
l REVISED B-56 SUBMITTAL
- Follow-up to CRGR Meeting No.171, 10/11/89
- Backfit questions and. comments have been addressed (Enclosures A,D & E)
- RG 1.9, Rev. 3 has been revised per i
CRGR comments and is consistent with NUMARC's Appendix D.
- A 50.54(f) letter will be used for implementation (Encl. C)
- Tech Specs will be revised as appropriate for compliance with Regulatory Positions C.3 and C.5.
- - - - - - - -i
B-56 BACKFIT OVERVIEW REGUi_ATORY POSITION RG 1.9, Rev. 3 REQMTS C.1 Design Considerations RGs 1.100 & 1.9, Rev. 2, with some relaxations.
C.2 EDG Testing RG 1.108, updated definitions, relaxation of testing reqmts'.
--__ = - - - - - - -
C.3 EDG Reliability Goals BACKFIT - conformance with and Monitoring 10 CFR 50.63 & RG 1.155 C.4 Record Keeping Same as RG 1.108, NUMARC, INPO Guidance and consistent with C.3 & C.6 C.5 Reporting Criteria BACKFIT - notification and reporting reqmts. Information content consistent with INPO guidelines and LER contents.
C.6 EDG Reliability BACKFIT - conformance with 4
Program 10 CFR 50.63, RG 1.155 and NUMARC's Appendix D.
_ - _ =
BACKFIT - submittal of changes TECH SPEC Revisions requested.
l l'
CONCLUDING ACTIONS
- Issue 50.54(f) Letter.
NRR Action.
l
(
l
,---..m,.,,
,,,,w,,e,_,._,,
,,,-g-.p.
.,,g4,..,
l l
ENCLOSURE C 12-19-89 PM Update w/ Tech Spec Reqats PROPOSED GENERIC LETTER (REFERENCE GSI B-56)
PURPOSE AND BACKGROUND!
This generic letter is being sent to all licensees of operating nuclear power plants and to all construction permit holders who currently rely upon EDGs to comply with 10 CFR 50.63, to determine whether licensees will voluntarily implement the recommendations of Regulatory Guide 1.9, Revision-3, for monitoring EDG reliability and implementing an EDG reliability program.
The Staff has issued Regulatory Guide 1.9, Revision 3,
" Selection, Design, Qualification, Testing and Reliability of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants." This revision integrates into a single I
document guidance on emergency diesel generator (EDG) selection, design, qualification and testing previously dealt with in i
Regulatory Guide 1.108, Regulatory Guide 1.9, Revision 2, and Generic Letter 84-15, for purposes of complying with General
^
Design Criteria 17 and la of CFR Part 50, Appendix A.
j In addition, this revision provides detailed guidance on monitoring EDG reliability levels and reviewing EDG reliability programs, for purposes of complying with 10 CFR 50.63, " Station Blackout."
3 j
10 CFR 50.63 requires that all LWR nuclear power plants be able i
to withstand and recover from a station blackout.
j The reliability of EDGs used as onsite emergency AC power sources is one of four primary considerations listed in Section 50.63 for assessing the ability of the plant to withstand station blackout.
i The Staff provided initial guidance for monitoring and i
maintaining EDG reliability for compliance withfSection 50.63 in i
Regulatory Position 1.2 of Regulatory Guide 1.155, " Station j
Blackout" which recommends that reliable operation of onsite i
emergency AC power sources should be ensured by a reliability program designed to maintain and monitor the reliability of each power source over time for assurance that selected reliability i
levels are being achieved.
Regulator i
Reliability Goals and Calculations," y Positions C.3,"EDG and C.6," Emergency Diesel Generator Reliability Program," of Regulatory Guide 1.9, Revision 3 provide more detailed guidance for monitoring EDG i
reliability levels, define an EDG reliability program and will be used by the staff to evaluate existing programs for EDGs at all i
plants.
i 1
4 5
. The nuclear power industry has developed an industry document NUMARC 8700, Appendix D (Revision of 11-6-89), which provides guidance to utilities implementing EDG reliability programs and EDG monitoring.
that it is in large part identical to Regulatory Positions C 3The St and C.6 of Regulatory Guide 1.9, Revision 3.
Table 1 of Regulatory Guide 1.9, comparison between Regulatory Guide 1.9, Revision 3 and theRevis relevant sections of NUMARC 8700, Appendix D.
those sections of Appendix D referenced in Table 1 to be an The Staff finds acceptable means of implementing the recommendations contained in Regulatory Positions C.3 and C.6. According to NUMARC-8700 all licensees relying upon EDGs to comply with Paragraph 50.G3 are committed to implement Appendix D of NUMARC 8700.
Imolementation of Reculatory Positions C.3 and C.S of Reculatory Guide 1.9.
diesel cenerator test schedules and recortina recuirements a specified in the olant technical snecifications. Attachment 1 is an eramole of an acceptable means for modifyine plant technical speci fications.
REOUESTED ACTIONS TO BE TAKEN BY ADDRESSES:
In order to determine whether any operating license or should be modified, construction permits for facilities covered by this request suspended or revoked, you are required, pursuant to Section 182 of the Atomic Energy Act and 10 CPR 50.5 4 (f),
letter a statement as to whether you have an EDG relia program and a means for monitoring EDG reliability levels which complies with the recommendations of Regulatory Positions C 3 and C.6 of Regulatory Guide 1.9, Revision 3 attained by implamenting the sections of NUMARC 8 Where compliance with which are referenced in Table 1 of the regulatory guide, your statement should identify with specificity what sections of the NUMARC document you intend to comply with.
have such a program, but intend to comply with Regulatory If you do not now Positions C.3 and C.6, implementation whereby compliance with Regulatory Positions and C.6 will be achieved not more than 270 days from the date of this letter.
program which complies with Regulatory Positions C.3 an statement shall identify the portions of these Regulatory the Positiona which you do not intend to comply with and provid supporcing justification. Also, existina olant Technical e
Specificatiens should be reviewed to ensure consistency with Reculatory lositions C.3 and C.S.
such Tech Spec revisions is to be orovided with this submittal toand a sc j
the NRC.
This information should be submitted to the NRC
)
under oath and affirmation.
, signed The licensee should retain all
i l
t i
i l
-3 j
i documentation supporting this statement consistent with the
{
records retention program for their facility.
l BACKFIT' DISCUSSION I
l' In Regulatory Guide 1.9, Rev.
3, the actions proposed by the NRC 3
staff in Regulatory Positions C.3, QxE and C.6 to monitor EDG i
reliability levels, reportina reauirements and to review EDG i
reliability programs represent new staff positions and are considered a backfit in accordance with NRC procedures. This q
}
backfit is a cost-justified safety enhancement.. Therefore a i
backfit analysis of the type described in 10CFR 50.109(a) (3) and 10CFR 50.109 (c) was performed and a determination was made that l
there will be a substantial increase in overall protection of the j
public health and safety and that the costs are justified in view of this increased protection.
The analysis and i
determination will be made available in the Public Document Room I
with the minutes.of the-171st and 173rd meetings of the Committee to Review Generic Requirements.
' PAPERWORK REDUCTION ACT REOUIM WNTS J_
i This request is covered by Office of Management and Budget Clearance Number 3150-0011, which expires The l
estimated average burden hours is 120 person-hours per license response, including assessment of'the new recommendations, i
searching data sources, gathering and analysing data, and the l
required reports.
These estimated average burden hours pertain j
only to these identified response-related matters and do not 1
include the time for actual implementation of requested' actions.
j Estimates of implementation of an EDG' reliability program are reported in NUREG-1109.
Comments on the accuracy of this i
estimate and suggestions to reduce.the burden may be directed to j
the U.S. Office of Management and Budget, Executive Office Building, Washington, D.C. 20503, and to the Nuclear Regulatory j
commission, Records and Reports Management Branch, Office of Administration and Resources Management, Washington, D.C.
j 20555.
i If you have any questions on this matter, please contact your 4
i project manager.
1 i
i i
t i
i
,-,,,-.,...._.n..a,
..,,nn...
n a,,..-w,,
i PROPOSED SAMPLE TS TO BE ATTACHED TO THE GL (NRR/RES POSITION ON TESTING) 2 ELECTRIC POWER SYSTEf4S 4.8.1.1.3 Reports - All diesel generator failures, valid or non-valid, shall be reported to the Commission pursuant to Specification 6.9.1.
If a mild or a strong action level is declared, take actions and prepare a report as per.
Regulatory Position C.5 of Regulatory Guide 1.9,.Rev. 3.
l I
I l
l 1
i
=
ELECTRIC POWER SYSTEMS I
i f
6 TABLE 4.8-1 DIESEL GENERATOR TEST SCHEDULE 1
)
Number of Failure in Last 25 Valid Tests
- Test Freauency i
j at 3 At least once per 31 days i
2:4 At least once per 7 days **
but no less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> i
4 b
i i
- Criteria for determining number of failures and valid cemands shall be in i
accordance with Regulatory Position C.2.1 of Regulatory Guide 1.9, Rev. 3, where the number of demands and' failures is determined on a per diesel
]
generator basis.
l
- This test frequency shall be mai t in a ned until seven consecutive failure i
free start and load-run demands have been performed.
If subsequent to the seven failure free tests one or more additional failures occur.such that there are again four or more failures in the last 25 tests, the i
testing interval shall again be reduced as noted above and maintained j
until seven consecutive failure-free tests have been performed.
~
4 a
l l
ij
[.
ELECTRIC POWER SYSTEMS l
l:
TABLE 4.8-2
{
RELIABILITY PROGRAM MONITORING I
DEMAND FAILURE i
TARGET COMBINATIONS RELIABILITY LEVEL (ALL EDGS)
REMEDIAL ACTI0fts
.95*
3/20 or 5/50 or 8/100 Declare Mild Action Level
.975**
3/20 or 4/50 or 5/100 and take actions defined or in Figure 1 of Regulatory 3/20 on the same Guide 1.9, Rev. 3 Emergency Diesel Generator t
(EDG)
.95 5/20 and 8/100 Declare Strong Action Level
.975 4/50 and 5/100 and take actions defined or in Figure 1 of Regulatory 4/25 on the same Guide 1.9, Rev. 3 EDG If an EDG has 5 failures in the last 25 demands, consideration shall be given to determining if an overhaul of that EDG is necessary based on the nature of re-occurring failures and level of degraded reliability.
If a major overhaul is undertaken then following such major overhaul, seven consecutive failure-free j
tests shall be successfully completed prior to returning that EDG to normal monthly surveillance test frequency.
- For plants in emergency ac-(EAC) Groups A, B and C as per l
Table 2 of Regulatory Guide 1.155.
- For plants in emergency ec (EAC) Group D as per Table 2 of Regulatory Guide 1.155.
-...~.- -.......- - - - - - -