In the prioritization of Issue 22, "Inadvertent Boron Dilution," it was found that inadvertent boron dilution events during cold shutdown operation do not constitute a significant risk to the public. Further work by DSI confirmed this assertion and the issue was deemed to be resolved without additional requirements. Based upon these
findings, it was recommended that SRP[1] Section 15.4.6 be considered for deregulation.[2]
As was verified by the studies associated with the resolution of Issue 22, the public risk from inadvertent boron dilution events during cold shutdown operations under current requirements is insignificant. As a result, some
of the conservatism included in SRP[3] Section 15.4.6 may be unduly excessive. Studies may be justified to investigate the results of deregulation and its effect upon public risk. In such studies, consideration must also be given to the potential for worker injury, should an inadvertent criticality event occur during work on the refueling deck with the reactor vessel head removed.
To prevent an increase in the likelihood of an inadvertent criticality due to a boron dilution event which is considered an unacceptable state under any circumstances, even at minimal public risk, this issue was a DROPPED from further consideration.
[1] NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," U.S. Nuclear Regulatory Commission, (1st Ed.) November 1975, (2nd Ed.) March 1980, (3rd Ed.) July 1981.
[2] Memorandum for T. Speis from H. Denton, "Closeout of Generic Issue No. 22, 'Inadvertent Boron Dilution Events (BDE),'" October 15, 1984. [8410310592]
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