ML15112A253
| ML15112A253 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 09/23/1998 |
| From: | Labarge D NRC (Affiliation Not Assigned) |
| To: | Mccollum W DUKE POWER CO. |
| References | |
| TAC-M99912, TAC-M99913, TAC-M99914, NUDOCS 9809250278 | |
| Download: ML15112A253 (5) | |
Text
September 23, 199 SMr, W. R. McCollum Vice President, Oconee Site Duke Energy Corporation P. 0. Box 1439 Seneca, SC 29679
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS (LIMITING CONDITIONS FOR OPERATION 3.8.3 AND 3.8.4) - OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 (TAC NOS. M99912, M99913 AND M99914)
Dear Mr. McCollum:
The NRC staff is in the process of reviewing your October 28, 1997, application for license amendments that proposed the conversion of the Oconee Nuclear Station, Units 1, 2, and 3, Technical Specifications (TS) to the Improved Standard Technical Specifications (ISTS).
During the review process, the staff has found it necessary to request additional information concerning Limiting Conditions for Operation (LCO) Sections 3.8.3 and 3.8.4. Based upon conversations with members of your staff, we understand that you will be able to respond to the enclosed questions by October 16, 1998. Should you be unable to submit your response by October 16, 1998, please contact me at 301-415-1472 to reschedule the submittal of the questions.
Sincerely, ORIGINAL SIGNED BY:
PDR ADOCK 05000269 David E. LaBarge, Senior Project Manager Project Directorate 11-2 Division of Reactor Projects -1/11 Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287
Enclosure:
Request for Additional Information cc w/encl: See next page Distribution:
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p UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-001 September 23, 1998 Mr. W. R. McCollum Vice President, Oconee Site Duke Energy Corporation P. 0. Box 1439 Seneca, SC 29679
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - CONVERSION TO IMPROVED STANDARD TECHNICAL SPECIFICATIONS (LIMITING CONDITIONS FOR OPERATION 3.8.3 AND 3.8.4) - OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 (TAC NOS. M99912, M99913 AND M99914)
Dear Mr. McCollum:
The NRC staff is in the process of reviewing your October 28, 1997, application for license amendments that proposed the conversion of the Oconee Nuclear Station, Units 1, 2, and 3, Technical Specifications (TS) to the Improved Standard Technical Specifications (ISTS).
During the review process, the staff has found it necessary to request additional information concerning Limiting Conditions for Operation (LCO) Sections 3.8.3 and 3.8.4. Based upon conversations with members of your staff, we understand that you will be able to respond to the enclosed questions by October 16,1998. Should you be unable to submit your response by October 16, 1998, please contact me at 301-415-1472 to reschedule the submittal of the questions.
Sincerely, David E. LaBarge, Senior Project Manager Project Directorate 11-2 Division of Reactor Projects -1/Il Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287
Enclosure:
Request for Additional Information cc w/encl: See next page
Oconee Nuclear Station cc:
Mr. Paul R. Newton Mr. J. E. Burchfield Legal Department (PBO5E)
Compliance Manager Duke Energy Corporation Duke Energy Corporation 422 South Church Street Oconee Nuclear Site Charlotte, North Carolina 28201-1006 P. 0. Box 1439 Seneca, South Carolina 29679 J. Michael McGarry, Ill, Esquire Winston and Strawn Ms. Karen E. Long 1400 L Street, NW.
Assistant Attorney General Washington, DC 20005 North Carolina Department of Justice Mr. Rick N. Edwards P. O. Box 629 Framatome Technologies Raleigh, North Carolina 27602 Suite 525 1700 Rockville Pike L. A. Keller Rockville, Maryland 20852-1631 Manager - Nuclear Regulatory Licensing Manager, LIS Duke Energy Corporation NUS Corporation 526 South Church Street 2650 McCormick Drive, 3rd Floor Charlotte, North Carolina 28201-1006 Clearwater, Florida 34619-1035 Mr. Richard M. Fry, Director Senior Resident Inspector Division of Radiation Protection U. S. Nuclear Regulatory North Carolina Department of Commission Environment, Health, and 7812B Rochester Highway Natural Resources Seneca, South Carolina 29672 3825 Barrett Drive Raleigh, North Carolina 27609-7721 Regional Administrator, Region II U. S. Nuclear Regulatory Commission Mr. Steven P. Shaver Atlanta Federal Center Senior Sales Engineer 61 Forsyth Street, S.W., Suite 23T85 Westinghouse Electric Company Atlanta, Georgia 30303 5929 Carnegie Blvd.
Suite 500 Virgil R. Autry, Director Charlotte, North Carolina 28209 Division of Radioactive Waste Management Bureau of Land and Waste Management Department of Health and Environmental Control 2600 Bull Street Columbia, South Carolina 29201-1708 County Supervisor of Oconee County Walhalla, South Carolina 29621
Request for Additional Information Oconee Nuclear Station Units 1. 2. and 3 Conversion to Improved Standard Technical Specifications Limiting Conditions for Operation (LCO) Sections 3.8.3 and 3.8.4 DC Source Requirements LCO 3.8.3, Note 3, states:
The additional 125 VDC (volts direct current) Vital l&C
[instrumentation and control] sources required by LCO 3.8.3 Part b, or Part c are not required to be connected to the Unit's Distribution System.
Oconee Unit 1 requires three of the four Unit 1 and Unit 2 125 VDC Vital I&C Sources to be operable. If one Unit 1 or Unit 2 source were inoperable, the additional sources required by LCO 3.8.3 Part b would be both Unit 3 sources. The application of Note 3 is that the Unit 3 sources need not be connected to the unit's (Unit 3) Distribution system which, as identified in LCO 3.8.8, is the unit's panelboards. If Unit 3 were shut down with all panelboards required by LCO 3.8.9 supplied power from Unit 1 sources, then one could argue that the Unit 3 sources need not be connected to any panelboard as stated in the note. Nevertheless, this condition would not satisfy LCO 3.8.4, which presumably would require one required operable source to be connected to something (at least one required panelboard) in the shutdown unit. If Unit 3 were operating, Note 3 is contrary to the requirement that a required source shall not be the only source to two or more panelboards, which would be the case for both Unit 1 sources that supply backup power to Unit 3 panelboards.
On the other hand, assume that a Unit 3 source is inoperable and that both Unit 1 and Unit 2 sources are operable. In this scenario, one might elect to classify either a Unit 1 or a Unit 2 source as a nonrequired source, and thereby apply Note 3 as to not require that source to be connected to the unit's (Unit 1, not the unit of the source, which could be Unit 2) panelboards.
But if a Unit 1 or Unit 2 source is not connected to any Unit 1 panelboard, this alone should constitute a condition where that source is not operable with respect to the three of four sources operable requirement for an operating unit.
Question:
- 1. In light of the above discussion and Note 3, what establishes what a source must be connected to, in order to satisfy the five of six and four of six operability requirements?
LCO 3.8.4 states:
125 VDC Vital I&C power source(s) shall be OPERABLE to support the 125 VDC Vital I&C power panelboards(s) required by LCO 3.8.9, "Distribution Systems-Shutdown" and shall include at least one of the unit's 125 VDC power sources.
-2 Questions:
- 1. If one of the shutdown unit's sources were inoperable:
- a. Would cross tying the unit's distribution centers be an acceptable means to support all the panelboards required by LCO 3.8.9, to satisfy LCO 3.8.4? If not, what Technical Specification (TS) provision prohibits it?
- b. What is the maximum and minimum number of panelboards that could be required to be operable to satisfy LCO 3.8.9?
c.. Could a cross-tied unit source be the only source to all panelboards required by LCO 3.8.9? If not, what TS precludes this configuration?
- d. Can a source from another unit be the only source to a panelboard required to be operable in accordance with LCO 3.8.9?
- e. If both panelboards associated with the operable shutdown unit's source are required to be operable in accordance with LCO 3.8.9, must they both be connected to that operable source, or could one be provided power only from another unit's source?
- f. If the shutdown unit's operable source is a required source for an operating unit, is there any limit on the number of panelboards in the shutdown unit that are connected to that source and have no backup from another unit? If so, what is that limit and what TS enforces this limit?