ML15112A540

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Forwards RAI Re Licensee 970828 Submittal of Amends to Plant TS to Modify Emergency Condenser Circulating Water Sys. Response Requested within 30 Days of Ltr Receipt
ML15112A540
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 12/22/1997
From: Labarge D
NRC (Affiliation Not Assigned)
To: Mccollum W
DUKE POWER CO.
References
TAC-M99487, TAC-M99488, TAC-M99489, NUDOCS 9801060001
Download: ML15112A540 (6)


Text

December 22, 199*

Mr. W. R. McCollum Distribution:

HBerkow LBerry Vice President, Oconee Site Dke-tFiIe; OGC DLaBarge Duke Energy Corporation PUBLIC :

ACRS RWessman P. 0. Box 1439 PD 11-2 Rdg.

JJohnson, RII GBagchi Seneca, SC 29679 BBoger COgle, RII

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - EMERGENCY CONDENSER CIRCULATING WATER SYSTEM UPGRADE AMENDMENT - OCONEE NUCLEAR STATION UNITS 1, 2, AND 3 (TAC NOS. M99487, M99488, AND M99489)

Dear Mr. McCollum:

By letter dated August 28, 1997, Duke Energy Corporation submitted amendments to the Oconee Nuclear Station Units 1, 2, and 3 Technical Specifications to modify the Emergency Condenser Circulating Water System. During our review, we have discovered the need for additional information as described in the enclosure. We request that you respond to this need within 30 days of receipt of this letter.

Sincerely, ORIGINAL SIGNED BY H. BERKOW FOR:

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 DOCUMENT NAME: G:\\OCONEE\\OCO99487. RAI To receive a copy of this document, indicate in the box:

" = Copy without attachment/enclosure "E" = Copy wi attachment/enclosure "N" = No copy OFFICE PD I-y PDII-21 EMEL.L PD NAME DL W e:cn LBerry RWess an 't Bagchi Hoer DATE 2/ 1jr/97

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1 aJDo197 OFFICIAL RECORD COPY (

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9801060001 971222 PDR ADOCK 0500O269

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to,~ REG~j'C UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 22, 1997 Mr. W. R. McCollum Vice President, Oconee Site Duke Energy Corporation P. 0. Box 1439 Seneca, SC 29679

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - EMERGENCY CONDENSER CIRCULATING WATER SYSTEM UPGRADE AMENDMENT - OCONEE NUCLEAR STATION UNITS 1, 2, AND 3 (TAC NOS. M99487, M99488, AND M99489)

Dear Mr. McCollum:

By letter dated August 28, 1997, Duke Energy Corporation submitted amendments to the Oconee Nuclear Station Units 1, 2, and 3 Technical Specifications to modify the Emergency Condenser Circulating Water System. During our review, we have discovered the need for additional information as described in the enclosure. We request that you respond to this need within 30 days of receipt of this letter.

Sincerely, avid E. LaBarge, Senior ProjeiManager roject 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 28242 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. Robert B. Borsum P. 0. 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 28242-0001 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 Atlanta Federal Center 61 Forsyth Street, S.W., Suite 23T85 Atlanta, Georgia 30303 Max Batavia, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, South Carolina 29201 County Supervisor of Oconee County Walhalla, South Carolina 29621

Request for Additional Information Oconee Nuclear Station Proposed Amendments to Technical Specifications Upgraded Emergency Condenser Circulating Water System The section and page numbers referred to in the following questions correspond to those in, Technical Justification, of the submittal dated August 28, 1997.

1.

Seismic qualification of equipment in the Oconee Nuclear Station is addressed in the Oconee Updated Final Safety Analysis Report (UFSAR). For seismic qualification of safety-related mechanical equipment, the UFSAR states that components may be qualified either by test or analysis, or based on tests of similar equipment. An example of this would be similar type pumps.

In Section 4.2, Duke Energy Corporation stated that the seismic qualification of the equipment (e.g., the Essential Siphon Vacuum (ESV) pumps and motors) was established using GIP-2, as supplemented by the staffs SSER No. 2, dated May 22, 1992. This is not acceptable since this approach is not a licensing basis for the Oconee Nuclear Station. Provide information to justify that all equipment in this system has met the UFSAR requirement for seismic qualification of mechanical and electrical equipment.

2.

Regarding the second paragraph of Section 4.1, describe the criteria and basis by which a QA-1 reinforced concrete foundation located just north of the Condenser Circulating Water (CCW) intake dike and a QA-4 pre-engineered structural steel building were seismically qualified. Also, discuss any differences in seismic qualification criteria between QA-1 vs. QA-4 items. Indicate if this criteria is consistent with that of the UFSAR and if not, discuss the basis for the discrepancies between them.

3.

Referring to the second paragraph on page 7, discuss how and to what criteria were the Radwaste Facility (RWF) trench, ESV System cable trench, and ESV System dike trench seismically qualified and indicate if the criteria is consistent with that of the Oconee UFSAR.

4.

Referring to Section 4.6, page 11, discuss how and to what criteria all ESV piping and components necessary to support Emergency Condenser Circulating Water (ECCW) siphon flow were seismically qualified and the basis for using the outdated power piping code ANSI B31.1. Provide key examples of the engineering evaluations that were implemented to achieve the seismic qualification. Also, provide a discussion of how and to what criteria the ESV System was designed to withstand Oconee's Maximum Hypothetical Earthquake (MHE) and provide the same information for the ESV building used to house the portion of the ESV System that is seismically qualified for an MHE.

-2 Also, discuss how and to what criteria cable supports/trays related to the ESV System were seismically qualified including a discussion of their 11/1 considerations.

5.

With respect to the last paragraph of Section 4.6, page 13, provide a summary discussion of the 10 CFR 50.59 evaluation that led to the conclusion that no potential for flooding of the trench due to overflow of the Keowee dam exists based on a low spot elevation of 810 ft.

6.

Regarding Section 5.2, discuss how and to what criteria the Siphon Seal Water System and all new piping and components necessary to support ECCW siphon flow were seismically qualified and indicate how the criteria used compares with that of the Oconee UFSAR.

7.

Referring to Section 6.0, page 16, discuss the basic approach and criteria used in reclassifying existing systems and equipment that are required to function to maintain the ECCW siphon to the Low Pressure Service Water (LPSW) pumps suction as QA-1 items and give key examples of how and what kind of engineering evaluations were used in upgrading some of the systems to meet seismic design criteria. Explain in greater detail about the statement that reclassification does not imply backfitting to meet all safety-related design criteria, etc. Discuss the justification for reclassifying a non-QA-1 item to a QA-1 item without introducing substantive steps to enhance the item's margin of safety against loss of function including that which results from an MHE. Also, discuss how and to what criteria newly constructed structures that directly support equipment required to function to maintain the ECCW siphon to the LPSW pumps suction were seismically qualified. Provide the same information for existing structures that support the aforementioned equipment, including the CCW intake structure, the turbine building, and Radwaste Facility trench.

8.

With respect to the second from the last paragraph on page 17, discuss what kind of quality assurance standard and seismic design criteria would be applied for future changes or modifications of those existing interfacing structures, which are presently designated as Class 2/QA-4.

9.

With respect to paragraphs 3 and 5 on page 18, discuss if any seismic requalification to upgrade to Seismic Category I would be implemented for those control functions that need to keep valves open to maintain the flow paths to the ECCW siphon and are reclassified as QA-1 accordingly. If not, provide the justification for not requalifying them seismically.

10.

Regarding Section 6.2, Design Criteria, page 19, discuss in detail as to how and what engineering evaluations are to be implemented to upgrade the CCW pumps, the CCW piping, and others to meet seismic qualification criteria and discuss a few examples of such seismic qualification cases. Also, explain what kind of reviews and basis thereof were carried out to verify that the valves and piping mentioned above and the control for the CCW pump discharge valves are capable of meeting seismic qualification criteria.

-3

11.

With respect to the fourth paragraph of page 20, discuss in greater detail as to how and the basis for carrying out an engineering evaluation that ensured that UFSAR Section 3.7.3.9 was met. Also, give key examples of some of the piping that were seismically upgraded.