ML15112A586
| ML15112A586 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 03/02/1998 |
| From: | Labarge D NRC (Affiliation Not Assigned) |
| To: | Mccollum W DUKE POWER CO. |
| References | |
| TAC-M99487, TAC-M99488, TAC-M99489, NUDOCS 9803060049 | |
| Download: ML15112A586 (8) | |
Text
Mr. W. R. McCollum March 2, 1998 Vice President, Oconee Site Duke Energy Corporation P. 0. Box 1439 Seneca, SC 29679
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - EMERGENCY CONDENSER CIRCULATING WATER SYSTEM (TAC NOS. M99487, M99488, AND M99489)
Dear Mr. McCollum:
During our review of your submittal dated August 28, 1997, and additional information supplied by letters dated January 1 and February 19, 1998, related to proposed Technical Specification changes to incorporate modifications to the Emergency Condenser Circulating Water System, the staff has determined that additional information is necessary to complete our review. We request you respond to the enclosed questions as soon as possible.
Sincerely, ORIGINAL SIGNED BY:
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
Enclosures:
As stated cc w/encl: See next page Distribution:
Docket File JZwolinski LPlisco, RII PUBLIC HBerkow COgle, RII PD 11-2 Rdg.
LBerry D.Jeng DLaBarge P.Y. Chen OGC K. Manoly ACRS To receive a copy of this document, indicate in the box:"C" = Copy without attachmentlenclosure "E" = Cop with attachmentlenplosure "N" = No copy OFFICE PM:PDIl
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NRp REG&Z UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 2, 1998 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 (TAC NOS. M99487, M99488, AND M99489)
Dear Mr. McCollum:
During our review of your submittal dated August 28, 1997, and additional information supplied by letters dated January 1 and February 19, 1998, related to proposed Technical Specification changes to incorporate modifications to the Emergency Condenser Circulating Water System, the staff has determined that additional information is necessary to complete our review. We request you respond to the enclosed questions as soon as possible.
Sincerely, David E. LaBarge, Senior Project Manager Project Directorate 11-2 Division of Reactor Projects - II Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287
Enclosures:
As stated 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, III, 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. 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 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 Upgraded Emergency Condenser Circulating Water (ECCW) System
- 1.
According to Section 3.9.2.2 of the Oconee Updated Final Safety Analysis Report (UFSAR), the methods for seismic qualification of safety-related mechanical equipment are analysis and/or testing. Section 3.10.2 of the UFSAR also states that the methods and procedures used for seismic qualification of instrumentation and electrical equipment are testing and/or analysis. GIP-2 is not included in the licensing basis for seismic qualification of equipment at the Oconee plants. In your submittals dated August 28, 1997, and January 22, 1998, you stated that some equipment associated with the modification of the ECCW System were qualified by using GIP-2. The staff finds that the qualification of equipment using the GIP-2 methodology is not in conformance with the licensing basis and, therefore, is not acceptable. In addition, as stated in the staffs SSER No. 2, on the GIP-2, the staff considers the GIP-2 method not a seismic qualification method, and that its incorporation into the FSAR is contingent upon (1) issuance of the staffs final, plant-specific SER resolving USI A-46 at the facility, and (2) adequately addressing all aspects of unreviewed safety questions as specified in 10 CFR 50.59. This is also explained in our letter to the Seismic Qualification Utility Group dated November 26, 1997, which is attached. Furthermore, the high pressure service water pump suction filters installed in the ECCW system are not covered by GIP-2, and the staff believes it is questionable that the filters can be qualified using GIP-2. If an experience-based approach is desired, a licensee may, on a case-by-case basis, follow the guidance of NRC Regulatory Guide 1.100, Revision 2, for equipment seismic qualification. For this evaluation, the staff requests that the following additional information be provided:
- a.
Specific demands (in terms of G's or response spectra) based on UFSAR design response spectra for each of the components listed in the table included in the response to Request No. 1 in your January 22, 1998, letter.
- b.
Details and documentation on the seismic qualification for the following components:
(1)
ESV Pump (2)
High Pressure Service Water Pump Suction Filter (3)
Various Electrical components required for the new system (4)
Condenser Circulating Water Crossover Valves
- 2.
Referring to your response to Request No. 2 in your letter of January 12, 1998, provide relevant summaries of the 10 CFR 50.59 evaluation completed or being prepared that provide the bases for (1) classifying the reinforced concrete foundation and the pre engineered structural steel building (ESV building) as seismic Class 2 structures, and (2) replacing the American Institute of Steel Construction, Inc. (AISC), Steel Construction Manual, Allowable Stress Design, 6th Edition with the AISC 9th Edition.
- 3.
Regarding your response to Request No. 5 in your letter of January 12, 1998, provide a scaled plan-view sketch covering the general vicinity of the dam, the protective dikes, and the new trench structure as well as the reduced fetch distance discussed that would further augment and support your narrative justifications included in the response.
Attachment:
Letter dated November 26, 1997 Enclosure
- ,tREG(,4 UNITED STATES NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D.C. 20555-0001 November 26, 1997 Mr. Neil Smith, Chairman Seismic Qualification Utility Group C/o MPR Associates, Inc.
320 King Street Alexandria, VA 22314
Dear Mr. Smith:
The Seismic Qualification Utility Group (SQUG) recently sent two letters to the U.S.
Nuclear Regulatory Commission (NRC). The first letter, dated October 6, 1997, is entitled "Guidelines for Adoption and Use of GIP [Generic Implementation Procedure] as Licensing Basis for A-46 Plants" and the second letter, dated October 22, 1997 is entitled "Examples of Enhanced Safety Based on the Overall Effect of a Cliange." Both letters were central to the focus of a public meeting held on October 30, 1997, between members of the NRC staff and representatives of the SQUG. At that meeting the staff committed to providing the SQUG with a written response to the two letters that would outline the staff's position relative to the incorporation of the GIP methodology into a plant's licensing basis. Enclosed please find the NRC staffs response to the two letters.
Sincerely,
[original signed by]
John F. Stolz, Director Project Directorate 1-2 Division of Reactor Projects - I/Il Office of Nuclear Reactor Regulation
Enclosure:
NRC Staff Response cc w/encl:
Mr. R. Kassawara, EPRI Program Manager 3412 Hillview Avenue P. 0. Box 10412 Palo Alto, CA 94304 Attachment
NRC STAFF RESPONSE: INCORPORATION OF THE GENERIC IMPLEMENTATION PROCEDURES INTO THE LICENSING BASIS This is in response to two letters the Seismic Qualification Utility Group (SQUG) recently sent to the NRC. The first letter, dated October 6, 1997, is entitled "Guidelines for Adoption and Use of GIP as Licensing Basis for A-46 Plants" and the second letter, dated October 22, 1997, is entitled "Examples of Enhanced Safety Based on the Overall Effect of a Change." Both letters were central to the focus of a public meeting held on October 30, 1997, between members of the NRC staff and representatives of SQUG to discuss SQUG's proposed guidelines for incorporating the Generic Implementation Procedure (GIP) into the licensing basis for USI A-46 plants. This meeting was the third in a series of meetings between the NRC and SQUG on this subject; the first and second meetings were held on August 14, and September 4, 1997, respectively. (Meeting Summaries have been issued separately.)
The October 6, 1997, letter provides the SQUG interpretation of the provisions of GIP-2, as accepted and supplemented by NRC SSER No. 2 (dated May 22, 1992), and the requirements of applicable regulations pertaining to changing a plant's licensing basis. The letter provides the SQUG position on the use of the provisions of 1 0 CFR 50.59 and the licensing amendment process and reflects SQUG's belief that the 50.59 process is the appropriate process to implement the change. The SQUG requests NRC concurrence with the positions stated in the attachment to the October 6, 1997 letter. The October 22, 1997, letter, provides a summary of five examples portrayed by SQUG as illustrating where NRC accepted the use of new methodologies that improved plant safety on an overall basis. The staff has considered these examples and concluded that they do not address all of the issues associated with adopting the GIP as a licensing basis.
During the October 30,1997 meeting, the NRC staff provided its views on SQUG's October 6, 1997, letter and committed to provide its views in writing. The NRC staff position is provided in this correspondence which constitutes the staff reply to the October 6, 1997, letter.
The staff does not agree with SQUG's positions stated in the October 6, 1997, letter regarding the use of the 50.59 process. Neither the staff nor SQUG can draw a generic conclusion regarding a finding that no unreviewed safety question (USQ) is involved if the GIP is adopted into the licensing basis for USI A-46 plants. This determination must be made by individual licensees, consequently the staff does not agree with the approach proposed by SQUG.
The provisions of 10 CFR 50.59 allow licensees the discretion to make changes to their facilities (or procedures) without prior NRC approval. Specifically, 10 CFR 50.59, in paragraph (a),
states that the holder of a license authorizing operation of a production or utilization facility may make changes in the facility as described in the safety analysis report (SAR), make changes in procedures as described in the SAR, and conduct tests or experiments not described in the SAR without prior commission approval unless the proposed change, test, or experiment involves a change to the technical specifications (TS) incorporated in the license, or involves an USO. With regard to A-46, the staff provided its position regarding 10 CFR 50.59 in Section 1.2.3 of the May 22, 1992 SER. Specifically the staff "recognizes that a licensee may revise its licensing basis in accordance with 10 CFR 50.59 to reflect the acceptability of the USI A-46 Enclosure
-2 (GIP) methodology for verifying the seismic adequacy of electrical and mechanical equipment covered by the GIP. The staffs approval of the implementation of the GIP does not relieve the licensees from the requirement to address all aspects [emphasis added] of unreviewed safety questions as specified in 10 CFR 50.59." (The staff notes that SQUG's October 6, 1997, letter, did not address this portion of the staff SER).
As stated during the October 30, 1997 meeting, and as recognized on page 4 in the staffs SER, "the implementation of the GIP-2 approach for USI A-46 plants provides safety enhancement, in certain aspects, [emphasis added] beyond the original licensing basis." The primary safety enhancements realized from implementing the USI A-46 resolution via the application of GIP-2, are attributed to the walkdown of equipment and associated resolution of identified discrepancies in the safe shutdown path. There are design related aspects in the GIP-2, however, that may not be as conservative as specific licensing basis requirements delineated for the qualification of new equipment in USI A-46 plants. Each licensee is free to conduct an analysis of the applicability of the GIP to the licensing basis in the FSAR using the provisions of 10 CFR 50.59, but the analysis cannot simply conclude that there is no USQ merely on the basis that the GIP methodology, taken as a whole, represents an improvement. Since each A 46 plant FSAR may contain specific or unique commitments, each licensee must review the various aspects of the GIP methodology against the various related aspects of the plant licensing basis and determine, after reviewing the specific aspects, if the adoption of the GIP involves an USQ. If the licensee concludes that a USQ is involved, adoption of the GIP into the licensing basis would require the licensee to seek an amendment under the provisions of 10 CFR 50.90. Consistent with the staffs May 22, 1992, SER, the staff intends to reach closure on USI A-46 implementation at a facility prior to approving an amendment to incorporate the GIP into the licensing basis (should one be proposed) for that facility.
As an example of the above staff position, the staff considered the situation where equipment damping is specified in a plant's FSAR and the licensee seeks to make an evaluation under the provisions of 10 CFR 50.59. If the FSAR contains specific equipment damping values that are less than those permitted by the GIP, the licensee must review the aspects affected by the change and make its own determination regarding whether or not an USQ exists at its facility.
An analogous situation (discussed with SQUG during the October 30, 1997, meeting) involved the application of seismic demand criteria.
If a licensee determines that a license amendment is the viable means to approach the GIP-2 incorporation into the licensing basis, an application should be submitted requesting the desired change. To facilitate the staffs evaluation, the application should contain: 1) identification of areas in the GIP (e.g., criteria, procedures, methodologies) that the licensee proposes to incorporate in the FSAR; 2) aspects of the GIP where the proposed change is less conservative than the FSAR criteria specified for that particular aspect (e.g., non-safety vs. safety equipment); 3) identification of the plant's components and equipment to which the GIP will be applicable; and 4) justification to support the adequacy of the proposed change. Referencing appropriate portions of the licensee's USI A-46 submittal and the staffs plant-specific SER is suggested. The staffs review of amendment requests should be facilitated by the review effort already expended on the licensee's USI A-46 program.
-3 In summary, neither the staff nor SQUG can reach a generic conclusion regarding the appropriate means to incorporate the GIP-2 into a facility's licensing basis. The determination is based primarily on the specifics in the licensing basis for the particular facility. We believe that a constructive dialogue between the staff and the lead plants proposing to amend their licenses will be productive in establishing acceptable ground rules for other USI A-46 licensees that conclude an amendment is the appropriate process for incorporating the GIP in the plant's licensing basis.