ML020220034
| ML020220034 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, Catawba, McGuire  |
| Issue date: | 01/17/2002 |
| From: | Rani Franovich Division of Regulatory Improvement Programs |
| To: | Tuckman M Duke Energy Corp |
| Franovich R, NRR/RLSB, 415-1868 | |
| References | |
| -nr | |
| Download: ML020220034 (9) | |
Text
January 17, 2002 Mr. M. S. Tuckman Executive Vice-President Nuclear Generation Duke Energy Corporation PO Box 1006 Charlotte, NC 28201-1006
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE MCGUIRE NUCLEAR STATION, UNITS 1 AND 2, AND CATAWBA NUCLEAR STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (LRA)
Dear Mr. Tuckman:
By letter dated June 14, 2001, Duke Energy Corporation (Duke) submitted for Nuclear Regulatory Commission (NRC) review an application, pursuant to 10 CFR Part 54, to renew the operating licenses for the McGuire Nuclear Station, Units 1 and 2, and Catawba Nuclear Station, Units 1 and 2. The NRC staff is reviewing the information contained in this license renewal application and has identified, in the enclosure, areas where additional information is needed to complete its review. Specifically, the enclosed request for additional information (RAI) is from the following sections of the LRA:
Section 2.1, Aging Management of Electrical and Instrumentation and Controls Appendix B, Section B.2, Program and Activity Attributes Please provide a schedule by letter, or electronic mail for the submittal of your response within 30 days of the receipt of this letter. Additionally, the staff would be willing to meet with Duke prior to the submittal of the response to provide clarification of the staffs request for additional information.
Sincerely,
/RA/
Rani L. Franovich, Project Manager License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos. 50-369, 50-370, 50-413 and 50-414
Enclosure:
As stated cc w/encl: See next page
Mr. M. S. Tuckman Executive Vice-President Nuclear Generation Duke Energy Corporation PO Box 1006 Charlotte, NC 28201-1006
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE MCGUIRE NUCLEAR STATION, UNITS 1 AND 2, AND CATAWBA NUCLEAR STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION
Dear Mr. Tuckman:
By letter dated June 14, 2001, Duke Energy Corporation (Duke) submitted for Nuclear Regulatory Commission (NRC) review an application, pursuant to 10 CFR Part 54, to renew the operating licenses for the McGuire Nuclear Station, Units 1 and 2, and Catawba Nuclear Station, Units 1 and 2. The NRC staff is reviewing the information contained in this license renewal application and has identified, in the enclosure, areas where additional information is needed to complete its review. Specifically, the enclosed request for additional information (RAI) is from Section 2.1, Aging Management of Electrical and Instrumentation and Controls, and Appendix B, Section B.2, Program and Activity Attributes.
Section 2.1, Aging Management of Electrical and Instrumentation and Controls Appendix B, Section B.2, Program and Activity Attributes Please provide a schedule by letter, or electronic mail for the submittal of your response within 30 days of the receipt of this letter. Additionally, the staff would be willing to meet with Duke prior to the submittal of the response to provide clarification of the staffs request for additional information.
Sincerely,
/RA/
Rani L. Franovich, Project Manager License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos. 50-369, 50-370, 50-413 and 50-414
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION:
See next page
- See previous concurrence Document Name: C:\\Program Files\\Adobe\\Acrobat 4.0\\PDF Output\\Duke RAI - Scoping Methodol~.wpd OFFICE PM:RLEP:DRIP LA:DRIP SC:RLEP:DRIP BC:RLEP:DRIP NAME Rfranovich
- EGHylton
- PTKuo CIGrimes DATE 01/ 16 /2002 01/16 /2002 01/16/2002 01/17/2002 OFFICIAL RECORD COPY
McGuire & Catawba Nuclear Stations, Units 1 and 2 Mr. Gary Gilbert Regulatory Compliance Manager Duke Energy Corporation 4800 Concord Road York, South Carolina 29745 Ms. Lisa F. Vaughn Duke Energy Corporation 422 South Church Street Charlotte, North Carolina 28201-1006 Anne Cottington, Esquire Winston and Strawn 1400 L Street, NW Washington, DC 20005 North Carolina Municipal Power Agency Number 1 1427 Meadowwood Boulevard P. O. Box 29513 Raleigh, North Carolina 27626 County Manager of York County York County Courthouse York, South Carolina 29745 Piedmont Municipal Power Agency 121 Village Drive Greer, South Carolina 29651 Ms. Karen E. Long Assistant Attorney General North Carolina Department of Justice P. O. Box 629 Raleigh, North Carolina 27602 Ms. Elaine Wathen, Lead REP Planner Division of Emergency Management 116 West Jones Street Raleigh, North Carolina 27603-1335 Mr. Robert L. Gill, Jr.
Duke Energy Corporation Mail Stop EC-12R P. O. Box 1006 Charlotte, North Carolina 28201-1006 Mr. Alan Nelson Nuclear Energy Institute 1776 I Street, N.W., Suite 400 Washington, DC 20006-3708 North Carolina Electric Membership Corporation P. O. Box 27306 Raleigh, North Carolina 27611 Senior Resident Inspector U.S. Nuclear Regulatory Commission 4830 Concord Road York, South Carolina 29745 Mr. Virgil R. Autry, Director Dept of Health and Envir Control 2600 Bull Street Columbia, South Carolina 29201-1708 Mr. C. Jeffrey Thomas Manager - Nuclear Regulatory Licensing Duke Energy Corporation 526 South Church Street Charlotte, North Carolina 28201-1006 Mr. L. A. Keller Duke Energy Corporation 526 South Church Street Charlotte, North Carolina 28201-1006 Saluda River Electric P. O. Box 929 Laurens, South Carolina 29360 Mr. Peter R. Harden, IV VP-Customer Relations and Sales Westinghouse Electric Company 6000 Fairview Road - 12th Floor Charlotte, North Carolina 28210 Mr. T. Richard Puryear Owners Group (NCEMC)
Duke Energy Corporation 4800 Concord Road York, South Carolina 29745 Mr. Richard M. Fry, Director North Carolina Dept of Env, Health, and Natural Resources 3825 Barrett Drive Raleigh, North Carolina 27609-7721 County Manager of Mecklenburg County 720 East Fourth Street Charlotte, North Carolina 28202 Michael T. Cash Regulatory Compliance Manager Duke Energy Corporation
McGuire Nuclear Site 12700 Hagers Ferry Road Huntersville, North Carolina 28078 Senior Resident Inspector U.S. Nuclear Regulatory Commission 12700 Hagers Ferry Road Huntersville, North Carolina 28078 Dr. John M. Barry Mecklenburg County Department of Environmental Protection 700 N. Tryon Street Charlotte, North Carolina 28202 Mr. Gregory D. Robison Duke Energy Corporation Mail Stop EC-12R 526 S. Church Street Charlotte, NC 28201-1006 Mary Olson Nuclear Information & Resource Service Southeast Office P.O. Box 7586 Asheville, North Carolina 28802 Paul Gunter Nuclear Information & Resource Service 1424 16th Street NW, Suite 404 Washington, DC 20036 Lou Zeller Blue Ridge Environmental Defense League P.O. Box 88 Glendale Springs, North Carolina 28629 Don Moniak Blue Ridge Environmental Defense League Aiken Office P.O. Box 3487 Aiken, South Carolina 29802-3487
Request for Additional Information (RAI)
McGuire Nuclear Station, Units 1 and 2, and Catawba Nuclear Station, Units 1 and 2 2.1 Scoping and Screening Methodology 2.1-1 In LRA Section 2.1.1.1, Safety Related Structures, Systems, and Components, Duke appropriately states that plant systems, structures, and components within the scope of license renewal are those that satisfy the scoping criteria in §54.4(a)(1). Scoping criterion (a)(1)(iii) refers to the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposures comparable to the guidelines in §50.34(a)(1), §50.67(b)(2), or §100.11 of this chapter, as applicable.
During the audit, however, the staff noted that the Duke Specifications governing scoping methodology for McGuire and Catawba currently cite superseded regulatory text in establishing the scoping criteria to be used in identifying Catawba and McGuire structures, systems, and components in accordance with §54.4(a)(1) requirements.
Specifically, these specifications cite the following criterion in reference to
§54.4(a)(1)(iii): The capability to prevent or mitigate the consequences of accidents that could result in potential off-site exposures comparable to the 10 CFR Part 100 guidelines.
Therefore, the staff requests the applicant to provide a written evaluation that addresses the impact, if any, of not having explicitly considered in its scoping methodology for Catawba and McGuire those structures, systems, or components that are relied upon to ensure the capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposures comparable to the guidelines in §50.34(a)(1),
§50.67(b)(2), or §100.11 of this chapter, as applicable, consistent with the facilities CLB.
2.1-2.a and 2.1-2.b - Scoping of Structures and Components that Meet 10 CFR 54.4(a)(2)
Criteria An applicant has two options when performing its scoping evaluation for non-safety-related piping systems that have a spatial relationship with safety-related systems, structures or components (SSCs) such that their failure could adversely impact the performance of an intended safety function: a mitigative option or a preventive option.
Mitigative option: With the mitigative option, the applicant must demonstrate that plant mitigative features (e.g., pipe whip restraints, jet impingement shields, spray and drip shields, seismic supports, flood barriers, etc.) are provided to protect safety-related SSCs from a failure of non-safety-related piping segments. When evaluating the failure modes of non-safety-related piping segments and the associated consequences, age-related degradation must be considered. The staff notes that pipe failure evaluations typically do not consider age-related degradation when determining pipe failure locations. Rather, pipe failure locations are normally postulated based on high stress.
Industry operating experience has shown that age-related pipe failures can, and do, occur at locations other than the high-stress locations postulated in most pipe failure analyses. Therefore, to utilize the mitigative option, an applicant should demonstrate that the mitigating devices are adequate to protect safety-related SSCs from failures of non-safety-related piping segments at any location where age-related degradation is plausible. If this level of protection can be demonstrated, then only the mitigative features need to be included within the scope of license renewal, and the piping segments need not be included within the scope.
Preventive option: if an applicant cannot demonstrate that the mitigative features are adequate to protect safety-related SSCs from the consequences of non-safety-related pipe failures, then the applicant should utilize the preventive option, which requires that the entire non-safety-related piping system be brought into the scope of license renewal and an AMR be performed on the system piping. An applicant may determine that, to ensure adequate protection of the safety-related SSC, a combination of mitigative features and non-safety-related piping segments must be brought within scope.
2.1-2.aThe staff requests that the applicant identify whether the mitigative option, the preventive option, or a combination, is used to identify non-safety-related piping systems that, if they failed, could adversely impact the performance of an intended safety function. For each non-safety-related piping system that would normally be included within the scope of license renewal, but is excluded because mitigative features have been credited for protecting safety-related SSCs from the failure of the non-safety-related piping system, please identify (1) the mitigative feature(s) that is credited for protection; (2) the hazard (e.g., failure mechanisms and postulated failure locations) for which the mitigative feature(s) is providing protection; and (3) a summary discussion (including references, such as reports, analyses, calculations, etc.) of the basis for the conclusion that the mitigative feature(s) is adequate to protect safety-related SSCs.
2.1-2.bThe staff requests that the applicant identify whether the mitigative option, the preventive option, or a combination, is used to identify non-safety-related non-safety-related systems, structures or components (other than piping) that, if they failed, could adversely impact the performance of an intended safety function. For these other non-safety-related systems, structures or components, an applicant can exercise the mitigative option, the preventive option, or a combination, to address the scoping issue.
For each non-safety-related systems, structures or components identified as meeting the 54.4(a)(2) scoping criterion, list which option or combination of options is being credited. For those non-safety-related systems, structures or components that exercise the mitigative option, please identify (1) the mitigative feature(s) that is credited for protection; (2) the hazard (e.g., failure mechanisms and postulated failure locations) for which the mitigative feature(s) is providing protection; and (3) a summary discussion (including references, such as reports, analyzes, calculations, etc.) of the basis for the conclusion that the mitigative feature(s) is adequate to protect safety-related SSCs.
2.1-3 LRA Appendix B, Aging Management Programs and Activities, Section B.2, Program and Activity Attributes, and Subsection B.2.2, Attribute Definitions, states that the applicant relies on the corrective action process as implemented through Nuclear System Directives NSD 208, Problem Investigation Process, and NSD 223, Trending of PIP Data, to satisfy the corrective actions, confirmation process, and administrative controls attributes of the aging management programs that will be implemented at Catawba and McGuire for the period of extended operation.
Consistent with guidance in SRP-LR, Appendix A.2, Quality Assurance for Aging Management Programs (Branch Technical Position IQMB-1), license renewal applicants can rely on the existing requirements in 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to satisfy these program elements/attributes. However, the Catawba/McGuire LRA does not establish or identify the role of the aforementioned Nuclear System Directives with respect to the applicants 10 CFR Part 50, Appendix B, quality assurance program in effect at these facilities.
Therefore, the staff requests the applicant to confirm that NSDs 208 and 223 govern the applicants corrective action program, which is subject to the requirements of 10 CFR Part 50, Appendix B, quality assurance program. The staff requests the applicant to confirm that this same corrective action program is credited for structures, systems, and components whose aging will be managed by an aging management program at Catawba and McGuire during the period of extended operation. In conformance with 10 CFR 54.21(d) requirements, the staff also requests the applicant to identify and describe this role as a commitment in the UFSAR supplements for Catawba and McGuire.
2.1-4 The audit team determined that the procedures reviewed in combination with the review of a sample of scoping and screening products provided adequate evidence that the scoping and screening process was conducted in accordance with the requirements of 10 CFR 54.4, Scope, and 10 CFR 54.21, Contents of Application Technical Information. However, the team also concluded that the applicant needs to describe the process it intends to implement to capture the scoping and screening process upon which the applicant will rely during the period of extended operation at Catawba and McGuire to satisfy the requirements of 10 CFR 54.35, Requirements During the Term of Renewed License. As such, the staff requests the applicant to describe the process it intends to implement to capture the scoping and screening process upon which the applicant will rely during the period of extended operation at Catawba and McGuire to satisfy the requirements of 10 CFR 54.35, Requirements During the Term of Renewed License.
DISTRIBUTION:
HARD COPY RLSB RF E. Hylton E-MAIL:
PUBLIC J. Johnson W. Borchardt D. Matthews C. Carpenter C. Grimes B. Zalcman J. Strosnider (RidsNrrDe)
E. Imbro G. Bagchi K. Manoly W. Bateman J. Calvo C. Holden P. Shemanski S. Rosenberg G. Holahan B. Boger D. Thatcher G. Galletti B. Thomas J. Moore R. Weisman M. Mayfield A. Murphy W. McDowell S. Droggitis N. Dudley RLEP Staff R. Martin C. Patel C. Julian (RII)
R. Haag (RII)
A. Fernandez (OGC)
J. Wilson M. Khanna C. Munson R. Elliott
Division of Regulatory Improvement Programs COVER PAGE DATE:
January 15, 2002
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE CATAWBA NUCLEAR STATION, UNITS 1 AND 2, AND MCGUIRE NUCLEAR STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION ORIGINATOR:
Rani Franovich SECRETARY:
S. Chey
!!!DRIP ROUTING LIST!!!
NAME DATE 1.
R. Franovich
/ /02 2.
E. Hylton
/ /02 3.
P. T. Kuo
/ /02 4.
C. Grimes
/ /02 DOCUMENT NAME:
C:\\Program Files\\Adobe\\Acrobat 4.0\\PDF Output\\Duke RAI -
Scoping Methodol~.wpd ADAMS ACCESSION NUMBER: ML DATE ENTERED: / /02 FORM 665 ATTACHED and filled out: YES NO COMMITMENT FORM ATTACHED: YES NO