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POLICY ISSUE
INFORMATION
SECY-00-0140
June 23, 2000
FOR: | The Commissioners |
FROM: | William D. Travers Executive Director for Operations |
SUBJECT: | REEVALUATION OF THE PRESSURIZED THERMAL SHOCK RULE (10 CFR 50.61) SCREENING CRITERION |
To summarize staff work to revisit the technical basis of the Pressurized Thermal Shock Rule and describe the staff's intended approach to reassess the rule's screening criterion.
In the late 1970s, the staff identified an issue concerning the integrity of embrittled pressurized water reactor (PWR) pressure vessels that involved a rapid cooldown of the inside wall of the vessel, accompanied by either sustained high reactor coolant system pressure or a subsequent repressurization of the system. The identification of this issue, termed pressurized thermal shock (PTS), resulted in the development of a proposed rule. This proposed rule was provided to the Commission in SECY-82-465 (Pressurized Thermal Shock) and received subsequent Commission approval. The Pressurized Thermal Shock Rule, 10 CFR 50.61, was established in 1983 as an adequate protection rule. The rule included a specified numerical value of a materials parameter (RTPTS) which would be used as a screening criterion, above which licensees would be required to demonstrate that their pressure vessels could be operated safely (Section 2 of the attachment summarizes key elements of the rule). RTPTS is a measure of the material toughness of the vessel at the end of its licensed life and the ability of the vessel materials to withstand a PTS event.
The screening criterion (i.e., acceptable value of RTPTS ) was set, in part, based on judgements regarding what frequency of vessel failure due to PTS was acceptable. The frequency of a through-wall crack, which was taken to be equivalent to reactor vessel failure and core damage, was estimated in SECY-82-465 to be in the range of 6x10-6 to 1x10-5 per reactor year. If a licensee determines that the screening criterion is to be exceeded, and no "reasonably practicable" programs for reducing the neutron fluences experienced by the vessel were found, then the rule requires the performance of a plant-specific safety analysis. Regulatory Guide 1.154 describes one acceptable method for performing this analysis. This method is a probabilistic analysis involving extensive thermal-hydraulic and fracture mechanics calculations. If the plant-specific analysis results in a through-wall crack frequency less than 5x10-6 per reactor year, then plant operation could continue. It is important to note that in establishing the screening criterion, a detailed assessment of containment performance during PTS events was not made.
Since the rule was established, the staff has accumulated considerable experience with application of the rule and regulatory guide and performed extensive research on the key technical issues underlying the rule. With respect to the regulatory guide, this experience has shown that it is difficult to use. Analyses performed as part of this research suggested that the rule could have conservatism which could be reduced while still providing reasonable assurance of adequate protection to public health and safety. As such, the staff initiated a program in
1999 to revisit the technical bases for the PTS Rule, and, if appropriate, to propose a revision to the rule and the regulatory guide. This revisitation and possible rule revision are intended to:
Since the PTS rule was established, the Commission also has established new guidance which, while not directed specifically at PTS events, is germane to setting the acceptable frequency of core damage from PTS events and thus to the PTS screening criterion. Most recently, a draft framework has been developed for applying this guidance to risk-informed changes to the technical requirements of Part 50, as described in SECY-00-0086 (Status Report on Risk-Informing the Technical Requirements of 10 CFR 50 (Option 3)). As discussed below, the staff intends to use this framework to reassess the PTS screening criterion.
In the past several years, the staff has completed a considerable amount of research pertinent to the analysis of PTS events. This research includes work on the size, density, and location of flaws in the vessel, the effects of neutron irradiation on materials, and methods for performing probabilistic fracture mechanics calculations. Section 3 of the attachment summarizes this research. In 1999, the staff initiated a program to apply this research to revisit the technical basis and, if appropriate, to propose a revision to the PTS Rule. This program has the following key elements (which are discussed in more detail in Section 4 of the attachment):
By present schedules, this program will be completed in early FY2002.
A considerable amount of guidance on the use of risk assessment in regulation has been established since the PTS rule was established. This guidance is provided in the Regulatory Analysis Guidelines, the Safety Goal and PRA Policy Statements, Regulatory Guide 1.174, and other documents. The staff has used this guidance to develop a draft framework, described in SECY-00-0086, for risk-informing the technical requirements of Part 50.
As also described in SECY-00-0086, the staff intends to test and update, as needed, this framework using regulations associated with hydrogen control (10 CFR 50.44) and with special treatment requirements. The staff now intends to reevaluate the PTS Rule's screening criterion using the SECY-00-0086 framework, and use this reevaluation as a third test. This framework includes consideration of containment performance and offsite risk via the use of a large early release frequency guideline. As noted above, containment performance was not assessed in detail during the development of the original rule. In work completed so far on reevaluating the screening criterion, the staff has identified two particular issues which will require further evaluation:
The staff will provide updates to the Commission on the progress in the reevaluation of the rule's technical basis and the issues noted above as key milestones are completed. Policy issues identified will be brought to the Commission on an expedited basis for resolution.
The resources needed to develop the technical basis for a potential modification of the PTS rule are included in the FY2000 RES budget and the proposed FY2001 RES budget. These budgets include a limited amount of funding to assess containment performance, as noted above. However, if extensive new accident or radioactive release analyses are found to be necessary and feasible, additional resources will have to be prioritized using the Planning, Budgeting, and Performance Management (PBPM) process. NRR resources to perform the subsequent rulemaking, if approved by the Commission, will be considered in the FY2002 budget for rulemakings, according to the priority of this rule change relative to other rulemaking activities. RES funds to provide technical support for this rulemaking are included in the RES FY2002 budget.
The Office of General Counsel has reviewed this paper and has no legal objections. The Office of the Chief Financial Officer has reviewed this paper for resource implications and has no objections. The staff is providing the ACRS with periodic briefings on the overall program to revisit the PTS Rule technical basis and the approach being taken with respect to the staff's reassessment of the screening criterion.
/RA/
William D. Travers |
CONTACTS: | M. Cunningham, RES 415-6189 M. Mayfield, RES |
Attachment: | Pressurized Thermal Shock Rule Analysis Requirements and Acceptance Criteria, Related Improvements in Analysis Methods and Data, and Staff Plans to Revisit the Rule's Technical Basis |
The Pressurized Thermal Shock (PTS) Rule, 10 CFR 50.61 (Ref. 1), establishes agency requirements on the ability of the reactor vessel in pressurized water reactors (PWRs) to withstand events in which the vessel is both rapidly overcooled (thermally shocked) and pressurized (or repressurized). These accidents have the following characteristics:
The rule establishes a series of steps which must be performed by PWR licensees in order to permit operation of the facility. The initial step involves a deterministic evaluation of materials properties, and a comparison of the vessel's RTPTS with the screening criterion. If the RTPTS value exceeds the screening criterion, a more general safety analysis or annealing of the vessel may be performed. Regulatory Guide 1.154 (Ref. 2), which includes the use of probabilistic methods, was written to provide one acceptable method for performing this safety analysis. These evaluations and related acceptance criteria are discussed in Section 2 below.
Since the rule was established, the staff has performed a considerable amount of research which has improved the capability to perform the evaluations required or permitted by the PTS rule. This research is summarized in Section 3. The staff's program to revisit the technical basis for the rule, using the results of this research and experience in rule implementation, is described in Section 4.
The PTS Rule describes a process for determining the acceptability of operation of the reactor vessel. Specifically, the rule includes the following requirements:
Regulatory Guide 1.154 describes one acceptable method for performing the plant-specific safety analysis described in paragraph (b)(4) of the rule. Some important characteristics of this analysis are:
Regulatory Guide 1.154 also describes an acceptance guideline for this safety analysis. Specifically, the guide indicates that if the mean frequency of a through-wall crack is less than 5x10-6 per reactor year, then continued operation of the facility "would be acceptable to the staff."
It should be noted that experience in use of the guide (for Yankee Rowe) has shown that it is very difficult to use. Without significant revision, the staff does not believe that licensees will use the guide.
In late 1989 and early 1990, NRC staff and the licensee for the now decommissioned Yankee Rowe plant conducted an intensive evaluation of the pressure vessel for that plant (Ref. 4). The staff had identified previously a high level of embrittlement for the pressure vessel; both the licensee and staff turned to Regulatory Guide 1.154 to help determine what regulatory actions needed to be taken. During the course of that evaluation, the staff and industry identified a number of shortcomings and limitations in the regulatory guide method. Chief among these was the technical basis for the fabrication flaw distributions used in the probabilistic fracture mechanics analyses. The Yankee Rowe evaluation, as well as the earlier evaluations that had formed the basis for the rule and regulatory guide, demonstrated that the way flaws were modeled, using 1970's non-destructive examination (NDE) data, and the resulting predicted flaw distribution (Ref. 5), dominated the uncertainty in the calculated probability of vessel failure. Other variables were also shown to be important, including variables in the embrittlement estimation methods, the fracture toughness curves, and the pressure and temperature estimates obtained from thermal hydraulics calculations.
Using its experience from the Yankee Rowe analysis, the staff initiated a research program to specifically reassess the properties of reactor vessels and their impact on PTS risk. Key elements of this research are discussed below. These research results are being used to reconsider the PTS screening criterion, RTPTS, discussed in paragraphs (b)(1) and (b)(2) of the rule, and the safety analysis method discussed in paragraph (b)(4) and in Regulatory Guide 1.154.
One of the results of the staff's technical work underlying the PTS rule (Ref. 6-8) was that the flaw related data (flaw size distribution, flaw location, and flaw density [number of flaws per unit volume of the material]) had the greatest level of uncertainty of the input data developed for these studies. Since the completion of the rule, NRC has supported research to establish a better technical basis for estimating the flaw distributions in the vessel beltline materials. The objective of this research has been to determine the number, location, and sizes of flaws in the vessel material. Key research in this has included:
EPRI has also performed NDE tests on some of these reactor vessel beltline materials. Their data are being further processed and will be made available soon for the staff's review.
Embrittlement correlations are used to predict the increased embrittlement over the life of the vessel due to neutron irradiation. Traditionally used correlations, described in Regulatory Guide 1.99, Revision 2 (Ref. 10), are based on analysis of Charpy v-notch impact-energy test data available in mid-1980's. Since then, a significantly larger body of additional Charpy surveillance data have become available, and the understanding of embrittlement mechanisms has advanced. Under NRC funding, the embrittlement correlations have been improved, and recently published by Modeling and Computing Services and the University of California at Santa Barbara (Ref. 11). Further refinement in the embrittlement correlations is now being performed under NRC funding to include more recent embrittlement data, effect of long irradiation exposure time at vessel normal operating temperatures, and statistical uncertainties in the predicted shift in RTNDT (nil-ductility fracture-mode transition temperature).
In the presence of a crack, a material's resistance to fracture is represented by a property called fracture toughness. The toughness values of reactor vessel ferretic steel materials in the present Section XI of the ASME Boiler and Pressure Vessel Code (Ref. 12) are based on 1970's test data that were developed at various temperatures in the brittle-to-ductile fracture-mode transition temperature range (Ref. 13). These tests were conducted under predominantly brittle fracture conditions as per ASTM E-399 test standard (i.e., linear elastic fracture mechanics (LEFM) valid tests in which the loading induced crack-tip plastic zone is very small relative to the test specimen dimensions). To predict catastrophic, sudden brittle fracture (with very little or no plastic deformation) in reactor vessel beltline materials under PTS loading conditions, brittle crack-initiation toughness (KIc) and crack-arrest toughness (KIa) are used in performing fracture mechanics analysis. These fracture toughnesses are presented in the ASME Code as a function of normalized temperature (T-RTNDT), and are deterministic lower-bound curves that are based on limited databases (171 data for KIc, and 50 for KIa, Ref. 13). Since the development of these ASME fracture toughness curves in the 1970's, additional ASTM E-399 standard based (LEFM-valid) test data have become available for vessel materials. Under NRC funding at Oak Ridge National Laboratory (Ref. 14), these additional test data have been identified to extend the original ASME fracture toughness databases (Ref. 13), and to develop rigorous statistical distributions for KIc and KIa. These statistical toughness models are presently being refined to decompose the uncertainties into epistemic (state of knowledge) and aleatory (randomness) components that can be used in overall uncertainty analysis to be performed in the PTS Rule re-evaluation. This additional work is being carried out at the University of Maryland under NRC funding for the probabilistic uncertainty aspects, and the micro-mechanical physical basis modeling under EPRI funding.
Statistical distributions for plant-specific material chemistry (nickel, copper) and initial RTNDT (RTNDTo) need to be developed to represent the local variability of plate and weld materials used in determining the shift in RTNDT due to irradiation embrittlement effects. This work is now being performed by NRC staff.
Accurate calculation of fluence values in the reactor vessel beltline region is crucial for determining the effect of irradiation embrittlement on fracture toughness of the vessel materials. Fluence calculations and the uncertainties in the end of license fluence values for each of the plants that are being studied in the PTS Rule reevaluation will be based on up-to-date information of the plant's cycle-by-cycle fuel loading history and the draft regulatory guide DG-1053 proposed method (Ref. 15). This work is now being carried out at Brookhaven National Laboratory under NRC funding.
A new version of NRC's probabilistic fracture mechanics (P.M.) analysis computer code, FAVOR (Fracture Analysis of Vessels -- Oak Ridge), has been under development at Oak Ridge National Laboratory under NRC funding (Ref. 16) to investigate brittle fracture in PWR vessels under thermo-mechanical transient loading conditions, such as PTS. A number of significant improvements have been made in the code, and some others are presently being made, so that it can be used to perform the more realistic PFM analysis to be performed in the PTS rule reevaluation. Notable among these are:
In 1999, the staff initiated a program to revisit and improve the realism of the technical basis of the PTS Rule, using the results of the research described above and experience in implementation of the rule. The key elements of this program, and dates for completion, are shown in Figure 1 and summarized below. As may be seen, this work is scheduled to be completed in early FY2002.
The element provides information on the types of event sequences which could lead to PTS events, and the frequencies of these sequences. In this element, the staff will review previous PTS risk studies, review more recent PRAs and operational events to identify new sequences, provide an updated set of potentially challenging sequences, group these sequences into sets having similar thermal hydraulic characteristics, and estimate the frequencies (including estimates of uncertainties) of occurrence of these sets of sequences.
The task of the thermal hydraulics work is to provide the reactor vessel down comer temperature and pressure boundary conditions for each potentially important group of event sequences, using state-of-technology computer models. The boundary conditions of interest are time-dependent system pressure, fluid temperature in the down comer, and the convective heat transfer coefficient from the fluid to the wall. Estimates of the uncertainties in these values will be provided.
As discussed in Section 3 above, the models and data used in probabilistic fracture mechanics have been significantly improved in the past several years. In particular, the fracture mechanics models, the embrittlement database and embrittlement correlation, inputs for flaw distributions, and the probabilistic fracture mechanics (PFM) computer code have been refined. The principal focus of the probabilistic fracture mechanics element of the staff's work is to provide estimates of the probabilities of through-wall cracks for each of the sets of event sequences and thermal hydraulic conditions identified in previous elements including uncertainties. A major objective of this analysis is to determine the synergistic impact of these fracture-technology refinements together with updated PRA and TH systems analysis results on the probabilities of through-wall cracking failure of the reactor vessel.
In parallel with the development of revised technical information on PTS events and their frequencies and consequences, the staff is reassessing the basis for the "acceptable" frequency of such events.
The frequency of a through-wall crack will be estimated for four selected plants, considering all event sequences and their frequencies, thermal hydraulic information, and PFM information. This frequency will be considered the same as the frequency of vessel failure and core damage. A simple analysis (involving less than six staff-months of effort and discussed in more detail below) of the impact of such vessel failures on containment performance during PTS events will also be performed as part of this element. Uncertainties in these frequencies will be estimated. The results from this work will be used to develop insights regarding the PTS risk for all plants potentially vulnerable to this event.
As part of the integrated assessment of PTS, the staff intends to perform a scoping analysis to identify and assess the technical issues and risk implications of the
impact of reactor vessel failure (due to PTS) on containment integrity. Consistent with the intent of the staff to use the SECY-00-0086 framework, this analysis
would principally focus on the potential for PTS accidents to result in large early releases of radioactive material, including potential failures of penetrations due
to PTS-induced motion of the reactor coolant system. The staff intends to make maximum use of available technology, including the results of the NRC severe
accident research which resolved key containment integrity issues. A key aspect of the approach would be the development of a PTS containment event tree and
the integrated analysis of vessel failure and concomitant blowdown conditions. This is the approach that the staff successfully used for demonstrating
containment integrity under severe accident loading conditions that were originally thought could lead to an early containment failure, e.g., direct containment
heating,-mode (steam explosion-induced) containment failure, and containment liner meltthrough. Insights gained from these past efforts
have shown that consistent treatment of the thermal-hydraulic and severe accident phenomena and containment structural response yields potential additional
benefits in an integrated risk assessment. To the extent possible in this scoping study, improved analytical methods developed for thermal hydraulic and severe
accident analysis will also be used. However, should the assessment of the timing and magnitude of fission product release become very resource and time
intensive, alternative approaches to resolve this issue will be considered. One alternative approach could be to limit the frequency of vessel failure due to PTS to
1x10-6 per reactor year in order to meet established guidelines for large early release frequency.
The staff will develop recommendations for new values of the RTPTS, using the estimates of through-wall crack frequency and the reassessment of the probabilistic aspects of the screening criterion, including containment performance.
The information created and assembled in previous tasks will be integrated into a form which could support a new version of the rule. When completed, this material will be provided to the Commission with a recommendation on proceeding with rulemaking.
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