ML15261A212
| ML15261A212 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 11/16/1998 |
| From: | Joseph Sebrosky NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9811200264 | |
| Download: ML15261A212 (7) | |
Text
PSREGC'J 1
UNITED STATES NUCLEAR REGULATORY COMMISSION Z
WASHINGTON, D.C. 2055-00 November 16, 1998 LICENSEE:
Duke Energy Corporation (DUKE)
FACILITY:
Oconee Nuclear Station, Units 1, 2, and 3
SUBJECT:
SUMMARY
OF MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION (NRC) STAFF AND DUKE REPRESENTATIVES TO DISCUSS ELECTRICAL SCOPING FOR THE OCONEE LICENSE RENEWAL APPLICATION On October 22, 1998, representatives of Duke met with the NRC staff in Rockville, Maryland, to discuss the electrical scoping and screening process used in the Oconee license renewal application. A list of meeting attendees is provided in Enclosure 1. A copy of the presentation material discussed at the meeting is provided in Enclosure 2.
At the beginning of the meeting, Duke distributed copies of the engineering procedures that were used to develop the license renewal application in the electrical area. Duke provided an overview of the process to 'identify and list electrical components subject to or included in the aging management review. The overview was broken down into the following areas:
(1) scoping done in accordance with 10 CFR 54.4, (2) determinations of which electrical component types perform their function without moving parts or without a change in configuration or properties made in accordance with 10 CFR 54.21(a)(1)(i), and (3) determinations of which electrical components were subject to replacement based on a qualified life or specified time period in accordance with 10 CFR 54.21(a)(1)(ii).
Duke used the results of the structural scoping process that was done for license renewal as a starting point for the electrical scoping. Duke believed that they could use the structural scoping process because the electrical components are installed in, attached to, or otherwise supported by a structure. The only exception that Duke notes in its application is direct buried cables. The staff questioned this approach, because a problem in the structural scoping process would also invalidate the electrical scoping process. The staff was also concerned that electrical components could be missed using this approach. The staff stated that it would evaluate this approach during its review of the application and in future meetings with Duke.
Duke then described its process for complying with 10 CFR 54.21(a)(1)(i). Duke first identified all types of electrical components that were installed at Oconee, and then identified the basic functions of the lcria o mpoen ucpswitFinally, Duke deermind whic idhetriecasi component types performed their function without moving parts or a change in configuration or properties. Duke did not identify all component level functions. Once it was determined that a component was within scope, Duke did not believe that it was necessary to list all the functions the component performed. For example, once an electrical bus was identified to be within scope, Duke contended that it was not necessary to know if the bus was used to address fire protection concerns, safe shutdown concerns, etc. A list of all components that fell within the scope of the license renewal rule was provided in the handout given to the staff during the meeting. The staff indicated that it would review and discuss this list during future meetings with Duke.
9811200264 981116 PDR ADOCK 05000269 P
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November 16, 1998 Duke then discussed how it determined which electrical components are subject to replacement based on a qualified life or specified time period. During this discussion the staff asked Duke if it used performance or condition monitoring to remove items from the scope of the license renewal rule. Duke indicated that it had in one case which was for insulated cables and connections used for fire detectors. Duke contended that the statements of considerations for the license renewal rule allowed this component to be scoped out on the grounds that it would be replaced based on a performance or condition program. The staff questioned Duke's interpretation of the statements of considerations and stated that the treatment of the insulated cables and connections used for fire detectors would be discussed further in upcoming meetings.
There was then a general discussion of some of the electrical components that Duke considered not to be subject to an aging management review. Duke pointed out to the staff two potential controversial areas (i.e., fuses and uninsulated ground conductors). Duke considers both functions of a fuse (i.e., disconnect an electrical circuit at a predetermined current and duration, and maintain electrical circuit continuity during normal circuit operation) to be excluded from an aging management review. This position conflicts with the staffs guidance contained in a September 9,1997, letter to NEI. Duke also informed the staff that uninsulated ground conductors were excluded from an aging management review based on system function. Duke stated that there are no credible failures within the current licensing basis for the uninsulated ground conductors and, therefore, all failures would be hypothetical and outside the scope of the license renewal rule. The staff indicated that it would review these two areas further.
The staff also indicated that it would further evaluate Duke's position regrading insulated cables and connections included in the Oconee environmental qualification (EQ) program and its position regarding switchgear Duke contends that with a documented qualified life, insulated cables and connections included in the Oconee EQ program are a replacement item as described in 10 CFR 54.21(a))(ii) Therefore, insulated cables and connections included in the Oconee EQ program were not subject to an aging management review. Regarding switchgear, Duke considered switchgear to be outside the scope of the license renewal rule.
Duke defines switchgearin accordance with the IEEE definition that includes all pieces inside the cabinet as being part of the switchgear. The staff was concerned that items such as terminal boards inside the switchgear were therefore excluded from the scope of Duke's aging management review.
Enclosures:
t Assttey Joseph M. Sebrosky, Project Manager License Renewal Project Directorate Division of Reactor Program Management.
Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287
Enclosures:
As stated cc w/encls: See next page DISTRIBUTION:
See next page DOCUMENT NAME: G:\\SEBROSKY\\1 0-220CO. SUM OFFICE LA PDLR/DRPM:PM PRLRDRPM:PM DRCH:QMB PDLRD NAME L
rry JSebrosky SHoffman Latta lGrime DATE 11/1/98 11
/98 11 1/398 11V498 11 U98 OFFICIAL RECORD COPY
Distribution:
Hard copy PUBLIC Docket File PDLR RF M. EI-Zeftawy, ACRS T2E2 F. Miraglia D. Thatcher J. Roe P. Shemanski D. Matthews J. Vora C. Grimes T. Essig G. Lainas J. Strosnider G. Bagchi H. Brammer T. Hiltz G. Holahan S. Newberry C. Gratton L. Spessard R. Correia R. Latta J. Peralta J. Moore R. Weisman M. Zobler E. Hackett A. Murphy T. Martin D. Martin W. McDowell S. Droggitis PDLR Staff H. Berkow D. LaBarge L. Plisco C. Ogle R. Trojanowski M. Scott C. Julian R. Architzel J. Wilson R. Gill, Duke D. Walters, NEI
ATTENDANCE LIS(T NRC MEETING. WITH DUJKE OCONEE UNKITS 1. 2. ANDI 13 NAME NAME ORGANIZATION
- 1.
Dale Thatcher*
NRC/NRRIDE/EELB
- 2.
Paul Shemanski*
- 3.
Juan Peralta NRC/NRRJDR/HQB
- 4.
Robert Latta NRC/NRRJDRCH/HQMB
- 5.
Chris Gratton*
NRC/NRR/DSCpJHQMB
- 6.
Robert Pratto*
NRC/NRR/DRPM/PLR
- 7.
Joe Sebrosky NRC/NRR/DRPM/PDLR
- 8.
Steve Hoffman*
NRC/NRR/DRPM/PDLR
- 9.
Marian Zobler*
NRC/OGC
- 10.
Jit Vora*
- 11.
Paul Colaianni Duk e So e
- 12.
Altheia Wyche De Lien
- 13.
Lynn Connor S
earch As ci tes
- 14.
Mike Neal
- 15.
David Roth Vriia
- 16.
David Hostetler Virginia Power
- 17.
Michael Henig Virginia Power
- 18.
William Denny*
Ogdn
- Attended the meeting part of the time Enclosurei
f1Duke C7Energy.
Oconee License Renewal Scoping / Screening Process
- Electrical Components October 22, 1998 Paul Colaianni
I OCONEE PROCESS TO IDENTIFY & LIST ELECTRICAL COMPONENTS SUBJECT TO OR INCLUDED IN THE AGING MANAGEMENT REVIEW IPA Steps Identify All Types of Electrical Components Installed at Oconee
§54.21(a)(1)(I)
Identify the Basic Functions Determinations of Electrical Com onent T s
Determine Which Electrical Component Types Perform Their Function Without Moving Parts or Without A Change in Confi uration or Pro rties Divide Electrical Component Groups for the Pu oses of the A in Mana ement Review Scope Electrical Components
§54.4 Scoping Based on Their Installed Location Scope Electrical Components Based on Their S stem Function
§R4.21(a)(1)(ii)
Determine Which Electrical Components Review are Subject to Replacement Based on a ualified Life or S ecified Time Period List Electrical Components Subject to or Included in the AMR
Oconee Nuclear Station ense Renewal) cc:
Paul R. Newton, Esquire Duke Energy Corporation Mr. J. E. Burchfield
-422 S6uth Church Street Compliance Manager Mail Stop PB-05E Duke Energy Corporation Charlotte, North Carolina 28201-1006 Oconee Nuclear Site P. 0. Box 1439 J. Michael McGarry, Ill, Esquire Seneca, South Carolina 29679 Anne W. Cottingham, Esquire Winston and Strawn Ms. Karen E. Long 1400 L Street, NW.
Assistant Attorney General Washington, DC 20005 North Carolina Department of Justice P. O. Box 629 Mr. Rick N. Edwards Raleigh, North Carolina 27602 Framatome Technologies Suite 525 L. A. Keller 1700 Rockville Pike Manager - Nuclear Regulatory Licensing Rockville, Maryland 20852-1631 Duke Energy Corporation 526 South Church Street Manager, LIS Charlotte, North Carolina 28201-1006 NUS Corporation 2650 McCormick Drive, 3rd Floor Mr. Richard M. Fry, Director Clearwater, Florida 34619-1035 Division of Radiation Protection North Carolina Department of Senior Resident Inspector Environment, Health, and U. S. Nuclear Regulatory Commission Natural Resources 7812B Rochester Highway 3825 Barrett Drive Seneca, South Carolina 29672 Raleigh, North Carolina 27609-7721 Regional Administrator, Region II Gregory D. Robison U. S. Nuclear Regulatory Commission Duke Energy Corporation Atlanta Federal Center Mail Stop EC-12R 61 Forsyth Street, SW, Suite 23T85 P. 0. Box 1006 Atlanta, Georgia 30303 Charlotte, North Carolina 28201-1006 Virgil R. Autry, Director Robert L. Gill, Jr.
Division of Radioactive Waste Management Duke Energy Corporation Bureau of Land and Waste Management Mail Stop EC-12R Department of Health and P. 0. Box 1006 Environmental Control Charlotte, North Carolina 28201-1006 2600 Bull Street RLGILL@DUKE-ENERGY.COM Columbia, South Carolina 29201-1708 Douglas J. Walters County Supervisor of Oconee County Nuclear Energy Institute Walhalla, South Carolina 29621 1776 I Street, NW Suite 400 W. R. McCollum, Jr., Vice President Washington, DC 20006-3708 Oconee Site DJW@NEI.ORG Duke Energy Corporation P. 0. Box 1439 Chattooga River Watershed Coalition Seneca, SC 29679 P. 0. Box 2006 Clayton, GA 30525