ML15261A252
| ML15261A252 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 04/13/1999 |
| From: | Joseph Sebrosky NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9904160231 | |
| Download: ML15261A252 (7) | |
Text
April 13, 1999 LICENSEE:
Duke Energy Corporation (Duke)
FACILITY:
Oconee Nuclear Station, Units 1, 2, and 3
SUBJECT:
SUMMARY
OF APRIL 1, 1999, PHONE CALLS BETWEEN THE U.S.
NUCLEAR REGULATORY COMMISSION (NRC) STAFF AND DUKE REPRESENTATIVES TO DISCUSS THE OCONEE LICENSE RENEWAL APPLICATION On April 1, 1999, representatives of Duke had phone calls with the NRC staff in Rockville, Maryland, to discuss the Oconee license renewal application. The purpose of the phone calls was to discuss questions that the staff had regarding fire protection. Enclosures 1 contains the staff's questions. The Duke participants were Bob Gill, Greg Robison, Paul Colaianni, and Mike Semmler. The staff participants were Tanya Eaton and Joe Sebrosky.
Duke provided verbal answers to the questions that the staff asked. A summary of these answers can be found in the Duke response portion of Enclosure 1. The staff stated that if any additional information is required, it will identify the information in a future call, or in the safety evaluation report for the Oconee license renewal application.
A draft of this meeting summary was provided to Duke to allow them the opportunity to comment on the summary prior to issuance.
Joseph M. Sebrosky, Project Manager License Renewal and Standardization Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287
Enclosure:
As stated cc w/encls: See next page 10066 DISTRIBUTION: See next page DOCUMENT NAME:G:\\SEBROSKY\\4-1FIRE.WPD OFFICE LA SPLB/DSSA PM/RLSB/DRIP BC/RLSB/DRIP NAME lton TEaton JSebros CIGrimes DATE
/199 9
/J__
996/
19)9 OFFICIAL RECORD COPY 9904160231 990413 PDR ADOCK 05000269 F
DISTRIBUTION: Hard copy
\\IDocket-File PUBLIC RLSB RF EHylton N. Dudley, ACRS - T2E26 E-mail R. Zimmerman T.Eaton W. Kane D. Matthews S. Newberry C. Grimes C. Carpenter B. Zalcman J. Strosnider R. Wessman E. Imbro W. Bateman J. Calvo H. Brammer T. Hiltz G. Holahan T. Collins C. Gratton B. Boger R. Correia R. Latta J. Moore J, Rutberg R. Weisman M. Zobler M. Mayfield S. Bahadur J. Vora A. Murphy D. Martin W. McDowell S. Droggitis RLSB Staff R. Emch D. LaBarge L. Plisco C. Ogle R. Trojanowski M. Scott C. Julian J. Peralta J. Wilson C. Sochor R. Gill, Duke D. Walters, NEI
Oconee Nuclear Station (License Renewal) cc:
Mr. J. E. Burchfield Ms. Lisa F. Vaughn Compliance Manager Duke Energy Corporation Duke Energy Corporation 422 South Church Street Oconee Nuclear Site Mail Stop PB-05E P. 0. Box 1439.
Charlotte, North Carolina 28201-1006 Seneca, South Carolina 29679 Anne W. Cottingham, Esquire Ms. Karen E. Long Winston and Strawn Assistant Attorney General 1400 L Street, NW.
North Carolina Department of Justice Washington, DC 20005 P. 0. Box 629 Raleigh, North Carolina 27602 Mr. Rick N. Edwards Framatome Technologies L. A. Keller Suite 525 Manager - Nuclear Regulatory Licensing 1700 Rockville Pike Duke Energy Corporation Rockville, Maryland 20852-1631 526 South Church Street Charlotte, North Carolina 28201-1006 Manager, LIS NUS Corporation Mr. Richard M. Fry, Director 2650 McCormick Drive, 3rd Floor Division of Radiation Protection Clearwater, Florida 34619-1035 North Carolina Department of Environment, Health, and Senior Resident Inspector Natural Resources U. S. Nuclear Regulatory Commission 3825 Barrett Drive 7812B Rochester Highway Raleigh, North Carolina 27609-7721 Seneca, South Carolina 29672 Gregory D. Robison Regional Administrator, Region II Duke Energy Corporation U. S. Nuclear Regulatory Commission Mail Stop EC-12R Atlanta Federal Center P. 0. Box 1006 61 Forsyth Street, SW, Suite 23T85 Charlotte, North Carolina 28201-1006 Atlanta, Georgia 30303 Robert L. Gill, Jr.
Virgil R. Autry, Director Duke Energy Corporation Division of Radioactive Waste Management Mail Stop EC-12R Bureau of Land and Waste Management P. 0. Box 1006 Department of Health and Charlotte, North Carolina 28201-1006 Environmental Control RLGILL@DUKE-ENERGY.COM 2600 Bull Street Columbia, South Carolina 29201-1708 Douglas J. Walters Nuclear Energy Institute County Supervisor of Oconee County 1776 I Street, NW Walhalla, South Carolina 29621 Suite 400 Washington, DC 20006-3708 W. R. McCollum, Jr., Vice President DJW@NEI.ORG Oconee Site Duke Energy Corporation Chattooga River Watershed Coalition P. O. Box 1439 P. O. Box 2006 Seneca, SC 29679 Clayton, GA 30525
Fire Protection Questions Phone call of April 1, 1999 Staff question 1 The applicant highlighted components on the flow diagrams to show which components are within scope of license renewal. Then on a separate list in Table 2.5-25, they identify these components and their intended functions. Some of the components which were highlighted on the flow diagram, were not included on this list.
Example:
(a) Section 2.5.14.1 -Air Intake and Exhaust System (OLRFD -137D-1.3, Vol. 3) - The turbo charger turbine pump casing, which is within the scope of license renewal, is not identified as an intended function on Table 2.5-25.
Duke response Duke stated that the turbo charger is considered to be within scope of license renewal, however, an aging management review was not performed on this component. Duke considers the turbo charger to be part of the diesel generator. The diesel generator is excluded from an aging management review based on 10 CFR 54.4(a)(1)(i).
Staff question 2 On some flow diagrams, the highlighted portions on the flow diagrams did not include components which we think should be within the scope of license renewal, according to the SE's, which show licensee commitments to provide certain FP equipment.
Examples:
(a) Section 2.5.14.2 - Diesel Generator Fuel Oil System (OLRFD -135A-1.2, Vol. 3) -The purpose of this system is to supply fuel oil to each diesel engine injector for combustion and fuel cooling. The oil storage tank and the oil day tank are highlighted and shown as within the scope of license renewal, but the piping leading to the injectors is not.
Duke response Duke stated that the piping leading to the injectors is considered to be within scope of license renewal and therefore should have been highlighted on the drawing. However, an aging management review is not required on the portion of the piping for this system that was supplied by the diesel generator vendor. Duke considers the portion of the piping supplied by the vendor to be part of the diesel generator and therefore excluded from an aging management review based on 10 CFR 54.4(a)(1)(i). Duke stated that the drawings are only a reviewer aid. The text contained in Volume 1, 11, and Ill of its license renewal application is consistent with the position that an aging management review is not required on the portion of the diesel generator provided by the vendor.
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Staff question 2b Section 2.5.14.3 - Drinking Water System (OLRFD -126B-1.1, Vol. 3)- The SSF Water Storage Tank is not highlighted to show that it's within the scope of license renewal. Their April 28, 1983 SE, Section 2.4.4 shows this as a part of the SSF which is provided for this system. I don't understand why it is excluded from being within scope.
Duke response Duke stated that Note 5 of the drawing indicates that the SSF Water Storage Tank does not meet any of the scoping criteria of 10 CFR 54.4. The small portions of the drinking water system that were considered to be within scope of 10 CFR 54.4 met the criteria of 10 CFR 54.4 (a)(2). That is, a portion of the drinking water system is a non-safety-related system, whose failure could prevent satisfactory accomplishment of any of the functions identified in 10 CFR 54.4 (a)(1)(i), (ii) or (iii).
Staff question 2c Section 2.5.14.7 - SSF Aux. Service Water System (Sump) (OLRFD -133A-2.5, Vol. 3)- All portions of this system are included within the scope of license renewal except for the SSF bldg. sump. In the April 28, 1983 SE, Section 2.4.3, the sump is listed as a system within the SSF and according to scoping criteria, should be included within scope of license renewal.
Duke response Duke noted that a portion of the sump is within scope of license renewal. Duke stated that the portion that is within scope is described in response to RAI 3.5.14-4. Duke stated that the reason a portion of the piping is within scope is that it is needed to remain intact to prevent an external flood from impacting important equipment in the SSF.
Staff question 2d Section 2.5.11 - Reactor Coolant Pump Motor Oil Collection System (OLRFD -137D-1.3, Vol. 3)- Some piping lines connected to the RCP motor oil collection tank are not within the scope of license renewal. The staff suspects they are for maintenance, but since they concern the RCP Motor Oil Collection System, which is required by Appendix R under 50.48, we would like to verify that they should not be included.
Duke response Duke stated that the piping is not highlighted because it is only used for maintenance during refueling outages. The portion that is only used for maintenance is not required by 10 CFR Part 50 Appendix R, and therefore is not within scope of license renewal.
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Staff question 3 For Section 2.5.14.8, Starting Air System, drawing OLRFD-137D-1.1, has portions missing so that you can't tell what is included within the scope of license renewal. If you compare to OLRFD-1 37D-1.2, Volume 3, this is the Unit 2 drawing for the same system. But they are slightly different.
Duke response Duke stated that all the drawings were individually made using a plotter (i.e., they were not copies). The staff was supplied with 7 set of these drawings. Duke suggested that the staff look at another set of the drawings to determine if this was simply a plotter malfunction for this particular drawing. When the staff reviewed another set of drawings it showed the missing portions and the staff was able to determine what is included within the scope of license renewal.
Regarding the portion of the Starting Air System that is within scope of license renewal, Duke noted that the same methodology was used for this system as was used for the diesel fuel oil system discussed in question 2a above. That is, Duke considers the Starting Air System leading to the diesel generator to be within scope of license renewal, however, Duke considers the portion of the piping supplied by the vendor to be part of the diesel generator and therefore excluded from an aging management review based on 10 CFR 54.4(a)(1)(i).
Staff question 4 Fire detector insulated cables and connections are excluded from an AMR. The applicant response to NRC Question 2.2-4 (b) states that insulated cables and connections used for fire detectors (which are part of the fire detection system) are determined not to be subject to an AMR. But that all other insulated cables and connections in the Fire Detection System are included in the AMR. I am confused when they say "all other". We still do not understand why insulated cables are excluded from the scope of license renewal.
Duke response Duke stated that the insulated cables and connections for fire detectors are not subject to an aging management review based on their interpretation of the license renewal rule.
Specifically, Duke believes that the statements of considerations (SOC) for the rule allows the fire detection cables to be excluded from an aging management review based on performance or condition monitoring. Duke stated that because testing of the fire detection cables is continuously done any problems with the cable would be self revealing. Therefore, an aging management review is not required. Duke believes that their position is consistent with the SOCs for the license renewal rule regarding testing (60FR22478 second column, second paragraph).
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Staff question 5 If you look in Section 4.16 of the LRA, there are two programs which fall under the FP Program, that are credited in the aging management review. It says that there are many activities used to achieve defense-in-depth. However, they only list: Fire Barrier Inspections and Fire Water System Testing.
(a) Are these the only two programs that are credited for FP? See RAI Question 4.16-3.
(b) Anything in the SE's that show commitments to maintain the FP system in accordance with 50.48, are within the scope of license renewal and subject to AMR, unless shown otherwise.
For example, there is a carbon dioxide system in the SSF. Using the licensee's logic, since this is a FP system, it should be within scope and subject to an AMR, simply because it is in a FP SE. Yet, no programs are mentioned which demonstrate how aging is managed for this system. Other examples: fire dampers, floor drains, yard fire hydrant flow checks, FP service water pump, battery checks, etc..
Duke response Duke stated that there is not one system that performs the fire protection function at Oconee.
Instead Duke uses various systems to comply with 10 CFR 50.48 Appendix R. Duke stated that Section 3.5 of the license renewal application discusses the aging effects and the many programs used to manage aging.
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