ML043440110

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Summary of Meeting with Duke Energy Corporation to Discuss Appendix R Reconstitution and Transition to NFPA 805
ML043440110
Person / Time
Site: Oconee, Mcguire, Catawba, McGuire  Duke Energy icon.png
Issue date: 12/14/2004
From: Olshan L
NRC/NRR/DLPM/LPD2
To:
Duke Energy Corp
Olshan L N, NRR/DLPM, 415-1419
References
TAC MC5186, TAC MC5187, TAC MC5188
Download: ML043440110 (6)


Text

December 14, 2004 LICENSEE: Duke Energy Corporation FACILITY: Oconee Nuclear Station, Units 1, 2, and 3 McGuire Nuclear Station, Units 1 and 2 Catawba Nuclear Station, Units 1 and 2

SUBJECT:

SUMMARY

OF DECEMBER 6, 2004, MEETING TO DISCUSS APPENDIX R RECONSTITUTION AND TRANSITION TO NFPA 805 (TAC NOS. MC5186, MC5187, AND MC5188)

On December 6, 2004, the Nuclear Regulatory Commission (NRC) met with Duke Energy Corporation (Duke) in Rockville, Maryland to discuss two topics: Appendix R reconstitution and transition to National Fire Protection Association (NFPA) 805 (i.e.,10 CFR 50.48(c)). The list of attendees is provided in Attachment 1. The handouts provided by Duke are included in Attachments 2 and 3.

The purpose of the first topic was to inform the NRC of Dukes effort to reconstitute its Appendix R licensing and design basis and develop a dialog to discuss potential issues on fire induced multiple spurious actuations, credit for manual actions, and additional armored cable fire testing. Dukes goal for reconstitution is to bring clarity and clean up design and licensing issues, improve documentation quality and completeness, and improve safety. Duke discussed its methodology that includes a large effort to trace safe shutdown cables and develop a fire probabilistic risk assessment for each unit. It was noted a large number of exemptions may result if a station does not transition to the 50.48(c) licensing basis.

The second topic of discussion was Dukes issues with transitioning to the 50.48(c) licensing basis. Duke noted it does not have full management buy-in or funding at this time for transition.

Duke sees transition as a method for both cleaning up its licensing basis and assuring its fire risk is acceptable. Its preliminary transition schedule would start Oconee mid-to-late 2005, McGuire mid-2006 to early 2007, and Catawba in late 2007. This schedule is in conjunction with the reconstitution schedule. Three main technical issues remain: (1) fire-induced multiple spurious circuit failure, (2) manual action transition, and (3) the risk evaluation requirement in the plant change control process. The NRC staff noted that these issues will need to be more comprehensively addressed in the draft Regulatory Guide that is currently out for public comment.

Duke has outstanding unresolved issues and self assessment issues for which it would like enforcement discretion under the interim enforcement policy. Duke would like to declare its intent to transition to 50.48(c), but delay the start of the transition to meet the schedule noted above. The NRC staff noted that the present policy does not allow enforcement discretion for

existing issues past January 16, 2005, but the NRC staff is seeking Commission approval to extend this discretion to the end of next year. The NRC has not fully considered the impact of allowing such a delay.

/RA/

Leonard N. Olshan, Project Manager Project Directorate II-1 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, 50-287, 50-369, 50-370, 50-413, and 50-414

ML043440110 NRC-001 OFFICE PDII-1/PM PDII-1/LA PDII-1/SC NAME LOlshan CHawes JNakoski DATE 12/13/04 12/10/04 12/14/04 MEETING TO DISCUSS APPENDIX R RECONSTITION AND NFPA 805 DECEMBER 6, 2004 MEETING ATTENDEES NRC R. Dipert D. Frumkin R. Gallucci J. Hannon A. Klein P. Law J. Nakoski L. Olshan C. Payne (by phone)

S. Peters P. Qualls R. Radlinski S. Weerakkody A. Wong S. Wong DUKE H. Barrett D. Brewer G. Davenport R. Gambrell D. Goforth D. Henneke R. Johansen G. McAninch J. Oldham OTHER F. Emerson, Nuclear Energy Institute J. Ertman, Progress Energy Attachment 1

McGuire Nuclear Station Catawba Nuclear Station Oconee Nuclear Station cc:

Ms. Lisa F. Vaughn Mr. Richard M. Fry, Director Duke Energy Corporation Division of Radiation Protection 422 S. Church St. NC Dept. of Env., Health, & Nat. Resources Mail Code - PB05E 3825 Barrett Dr.

P.O. Box 1244 Raleigh, NC 27609-7721 Charlotte, NC 28201-1244 Ms. Karen E. Long County Manager of Mecklenburg County Asst. Attorney General 720 E. Fourth St. NC Department of Justice Charlotte, NC 28202 P.O. Box 629 Raleigh, NC 27602 Mr. C. Jeffrey Thomas, Manager Regulatory Compliance Mr. R. L. Gill, Jr., Manager McGuire Nuclear Station Nuclear Regulatory Issues & Industry Duke Energy Corporation Affairs 12700 Hagers Ferry Road Duke Energy Corporation Huntersville, NC 28078 526 S. Church St.

Mail Stop EC05P Anne Cottingham, Esq. Charlotte, NC 28202 Winston and Strawn 1400 L St., NW NCEM REP Program Manager Washington, DC 20005 4713 Mail Service Center Raleigh, NC 27699-4713 Senior Resident Inspector U.S. Nuclear Regulatory Commission Mr. T. Richard Puryear 12700 Hagers Ferry Road Owners Group (NCEMC)

Huntersville, NC 28078 Catawba Nuclear Station Duke Energy Corporation Mr. Peter R. Harden, IV, Vice President 4800 Concord Road Customer Relations and Sales York, SC 29745 Westinghouse Electric Company 6000 Fairview Road, 12th Floor Mr. Lee Keller, Manager Charlotte, NC 28210 Regulatory Compliance Catawba Nuclear Station Dr. John M. Barry Duke Energy Corporation Mecklenburg County 4800 Concord Road Department of Environmental Protection York, SC 29745 700 N. Tryon St.

Charlotte, NC 28202 NC Municipal Power Agency Number 1 1427 Meadowwood Boulevard P.O. Box 29513 Raleigh, NC 27626-0513

McGuire Nuclear Station Catawba Nuclear Station Oconee Nuclear Station cc:

County Manager of York County Mr. B. G. Davenport, Manager York County Courthouse Regulatory Compliance York, SC 29745 Oconee Nuclear Site Duke Energy Corporation Piedmont Municipal Power Agency 7800 Rochester Highway - MS ONO3RC 121 Village Dr. Seneca, SC 29672 Greer, SC 29651 Mr. Dhiaa Jamil Saluda River Electric Vice President P.O. Box 929 Catawba Nuclear Station Laurens, SC 29360 Duke Energy Corporation 4800 Concord Road Henry Porter, Assistant Director - DWM York, SC 29745 Bureau of Solid and Hazardous Waste Dept of Health & Env. Control Mr. G. R. Peterson, Vice President 2600 Bull St. McGuire Nuclear Station Columbia, SC 29201-1708 Duke Energy Corporation 12700 Hagers Ferry Road NC Electric Membership Corporation Huntersville, NC 28078 P.O. Box 27306 Raleigh, NC 27611 Mr. Ronald A. Jones, Vice President Oconee Nuclear Station Senior Resident Inspector Duke Energy Corporation U.S. Nuclear Regulatory Commission 7800 Rochester Highway 4830 Concord Road Seneca, SC 29672 York, SC 29745 Ms. Mary Olson Manager, LIS Director of the Southeast Office NUS Corporation Nuclear Information and Resource Service 2650 McCormick Dr., 3rd Floor 729 Haywood Road, 1-A Clearwater, FL 34619-1035 P.O. Box 7586 Asheville, NC 28802 Senior Resident Inspector U.S. Nuclear Regulatory Commission Henry Barron, Group Vice President 7812B Rochester Highway Nuclear Generation & Chief Nuclear Officer Seneca, SC 29672 P.O. Box 1006-EC07H Charlotte, NC 28201-1006 Mr. Michael A. Schoppman Framatome ANP 1911 N. Ft. Myer Dr.

Suite 705 Rosslyn, VA 22209