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Summary of 990511 Meeting with NRC & Util in Rockville,Md to Discuss Licensee Renewal Application.List of Meeting Attendees,Issues to Be Discussed & Issues Found in Meeting Notice Encl
	ML15261A257
Person / Time
Site:	Oconee
Issue date:	05/19/1999
From:	Joseph Sebrosky; NRC (Affiliation Not Assigned)
To:	; NRC (Affiliation Not Assigned)
References
	NUDOCS 9905210124
	Download: ML15261A257 (18)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 19, 1999 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 REGARDING SCOPING FOR THE OCONEE LICENSE RENEWAL APPLICATION On May 11, 1999, representatives of Duke met with the Nuclear Regulatory Commission (NRC) staff in Rockville, Maryland, to discuss the Oconee license renewal application. A list of meeting attendees is provided as Enclosure 1. The meeting notice provided a list of issues to be discussed at the meeting. Enclosure 2 contains the list of issues found in the meeting notice.

Duke's presentation materials discussed at the meeting are provided as Enclosure 3.

The purpose of the meeting was to discuss the scoping process that Duke used to comply with 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2).- Duke provided a brief history of the issue. The NRC originally questioned aspects of the effort in RAI 2.2-6 that Duke responded to in a February 17, 1999, letter. A technical meeting was held on March 11, 1999, to further discuss the scoping issue. The March 11, 1999, meeting resulted in a revision to Duke's response to RAI 2.2-6 that provided an explanation of the scoping events set used for the license renewal mechanical scoping. Following the revision, the scoping issue remained open, leading to the May 11, 1999, meeting.

Duke then provided steps in defining the issue. Slides 5, 6, 7, 8, 9, 10, and 11 of Enclosure 3 provide the terminology and Oconee design and licensing basis background regarding this issue.

Duke stated that the term "design basis events" means something different to Oconee and the NRC staff. In 1991, as part of the overall creation of the design basis document (DBD) set, Duke recognized the need to standardize the approach to resolving future NRC regulations that would use the term "design basis event." This eventually led to the Oconee Safety Related Designation Clarification (OSRDC) project. The OSRDC project confirmed and documented that the Oconee updated final safety analysis report (UFSAR) Chapter 15 events constitute Oconee's own unique set of design basis events. In addition, the OSRDC project documented an additional set of events beyond the design basis events that should be considered for possible inclusion when defining the scope of a regulatory issue.

Slide 12 of Enclosure 3 provides a diagram of the Oconee "scoping events" set. Duke stated that the "scoping events" set included UFSAR chapter 15 events, natural phenomena criteria, post-Three Mile Island emergency feedwater design basis scenarios, and turbine building flood mitigated by the standby shutdown facility. There are 26 events that Duke considers "scoping events" that were used in the mechanical scoping area to comply with 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2). Duke also stated that it reviewed an additional 32 events for possible inclusion into the set of scoping events. Duke determined that none of the additional 32 events needed to be considered for purposes of scoping in accordance with 10 CFR 54.4 (a)(1) and 10 CFR 54.4(a)(2).

9905210124 990519 PDR ADOCK 05000269 PPO May 19, 1999 For clarity, the staff suggested that these "scoping events" could be referred to as "design basis events for license renewal." In addition, the staff noted that, as part of an inspection effort, it would like to explore why the 32 additional events were not considered to be within scope of the license renewal rule. Duke expressed concern that the staff was asking them to name every event that was considered and not just the events that were actually used to comply with 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2). The staff stated that it needed to be able to substantiate that the events that Duke used are sufficient for compliance with the license renewal rule. The following action items were identified as a result of this meeting:

1.

Duke agreed to supplement its response to the staff's request for additional information (RAI) 2.2-6, to include a description of the process used to identify events for Oconee license renewal scoping consistent with the presentation that was given to the staff.

During the meeting, Duke referred to these events as "scoping events." For clarity, the staff suggested that these "scoping events" could be referred to as "design basis events for license renewal." Duke should provide an explanation as to how the 26 events identified during the meeting are sufficient to satisfy 10 CFR 54.4(a)(1) and 54.4(a)(2).

2.

Once the information identified in item 1 above is provided, the staff will determine whether additional inspection activities will be needed to verify that there is reasonable assurance that the Oconee systems, structures and components that are within scope of the license renewal rule have been captured by Duke's process.

A draft of this meeting summary was provided to Duke to allow them the opportunity to comment on the summary prior to issuance.

Original Signed By 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

Enclosures:

As stated (3) cc w/encls: See next page DISTRIBUTION:

See next page

see previous concurrence DOCUMENT NAME:G:\\RLSB\\SEBROSKY\\5-11 SUM.WPD OFFICE LA RLSB/DRIP:PM IQMB/DIPM RLSB/DRIP:BC D P NAME EHylton JSebrosky TQuay CDGrimeh D

ew DATE 5/12/99*

6/1099 6/ 11/99 G/1999

/9 OFFICIAL RECORD COPY

-2 The staff stated that it understands Duke's "scoping events" to be "design basis events for license renewal." In addition, the staff noted that, as part of an inspection effort, it would like to explore why the list of 32 additional events were not considered to be within scope of the license renewal rule. Duke expressed concern that the staff was asking them to name every event that was considered and not just the events that were actually used to comply with 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2). The staff stated that it needed to be able to substantiate that the events that Duke used are sufficient for compliance with the license renewal rule. The following action items were identified as a result of this meeting:

1.

Duke agreed to supplement its response to the staff's request for additional information (RAI) 2.2-6, to include a description of the process used to identify events appropriate for Oconee license renewal scoping consistent with the presentation that was given to the staff. During the meeting, Duke referred to these events as "scoping events." The staff understands these to be "design basis events for license renewal." Duke should provide an explanation as to how the 26 events identified during the meeting are necessary and sufficient to satisfy 10 CFR 54.4(a)(1) and 54.4(a)(2)

2.

Once the information identified in item 1 above is provided, the staff will determine whether additional inspection activities will be needed to verify that there is reasonable assurance that the Oconee systems, structures and components that are within scope of the license renewal rule have been captured by Duke's scoping process.

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

Enclosures:

As stated (3) cc w/encls: See next page DISTRIBUTION:

See next page DOCUMENT NAME:G:\\SEBROSKY\\5-11 SUM.WPD OFFICE LA )

RLSB/DRIP:PM IQMB/DIPM RLSB:BC NAME n

JSebrosky TQuay ClGrimes DATE j

fl99 j1/1/99

/ /99

/ /99 OFFICIAL RECORD COPY

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. 0. Box 1439 P. 0. Box 2006 Seneca, SC 29679 Clayton, GA 30525

Distribution: Hard copy,

:P-UBL1 Except for the attendees list in Enclosure 1, an advance copy of the handouts to this meeting summary was sent directly to the PDR on 5/12/99 EHylton Docket File RLSB RF N. Dudley, ACRS - T2E26 E-mail R. Zimmerman 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 210 010

ATTENDANCE LIST MAY 11, 1999, NRC MEETING WITH DUKE REGARDING OCONEE SCOPING NAME ORGANIZATION Mike Tuckman Duke Energy Greg Robison Duke Energy Rounette Nader Duke Energy Ed Burchfield Duke Energy Dave Matthews NRR/DRIP Chris Grimes NRR/DRIP/RLSB Steve Hoffman NRR/DRIP/RLSB Joe Sebrosky NRR/DRIP/RLSB P. T. Kuo NRR/DRIP/RLSB Hai-Boh Wang NRR/DRIP/RLSB Bob Prato NRR/DRIP/RLSB Bruce Boger NRR/DIPM Ted Quay NRR/DIPM/IQMB Dan Dorman NRR/DIPM/IQMB R. M. Latta NRR/DIPM/IQMB David LaBarge NRR/DLPM/PD II Goutam Bagchi NRR/DE/EMEB Paul Shemanski NRR/DE/EEIB Bruce Mallett NRC/Region II/DRS Caudle Julian (via phone)

NRC/Region II/DRS Ed Girard (via phone)

NRC/Region il/DRS Billy Crowley (via phone)

NRC/Region il/DRS Lawrence Chandler NRC/OGC Marian Zobler NRC/OGC Janice Moore NRC/OGC Robert Weisman NRC/OGC Noel Dudley ACRS Mark Wetterhahn Winston & Strawn Lisa Vaughn Duke Law Department Will Kenworthy GSI Lynn Connor DSA Colleen Amoruso NUS information Services Doug Walters Nuclear Energy Institute

May 11, 1999 Meeting Topics Description of the Problem The Oconee Nuclear Station Application for Renewed Operating License, ORLP-1001, Section 2.2.1.1(a), states the following with respect to the identification of systems, structures, and components within the scope of license renewal:

"Because Oconee was licensed before terms such as 'safety-related' were more precisely defined by the NRC, a list of the Oconee safety-related systems, structures, and components, in and of itself, will not meet the intent of §54.4(a)(1).

Because the criteria in §54.4(a)(1) are the scoping criteria for many modern-day, regulatory-required programs, Oconee conducted a design study that validated all functions required for the successful mitigation of Oconee design basis events and identified the systems and components relied upon to complete those functions."

In response to this statement, the staff generated RAI 2.2-6 requesting additional information on the Oconee design study identified in ORLP-1001. In addition, the staff met with representatives from Duke Energy Corporation (Duke), on March 11, 1999, to obtain additional insights into the methodology used by Duke to meet the requirements of 10 CFR 54.21(a)(2) for identifying the structures and components requiring an aging management review. Specifically, the staff requested that Duke describe its methodology for identifying the Oconee systems, structures, and components (SSCs) within the scope of Part 54, based on the following requirements:

"Plant systems, structures, and components that are within the scope of this part are (1) Safety-related systems, structures, and components which are those relied upon to remain functional during and following design-basis events (as defined in 10 CFR 50.49 (b)(1)) to ensure the following functions (i)

The integrity of the reactor coolant pressure boundary; (ii)

The capability to shut down the reactor and maintain it in a safe shut-down condition; or (iii)

The capability to prevent or mitigate the consequences of accidents that could result in potential offsite exposure comparable to the guidelines in

§50.34(a)(1) or §100.11 of this chapter, as applicable.

(2) All nonsafety-related systems, structures, and components whose failure could prevent satisfactory accomplishment of any of the functions identified in paragraphs (a)(1)(i), (ii), or (iii) of this section.

(3) All systems, structures, and components relied upon on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the

Commission's regulations for fire protection (10 CFR 50.48), environmental qualification (10 CFR 50.49), pressurized thermal shock (10 CFR 50.61),

anticipated transients without scram (10 CFR 50.62), and station blackout (10 CFR 50.63)."

Paragraph (b)(1) of § 50.49, "Environmental qualifications of electric equipment important to safety for nuclear power plants," states that "Design basis events are defined as conditions of normal operation, including anticipated operational occurrences, design basis accidents, external events, and natural phenomena for which the plant must be designed to ensure functions (b)(1)(i)

(A) through (C)1 of this section."

Since the design study conducted by Duke only validated those functions required for the successful mitigation of Oconee design basis events identified in Chapter 15 of the Oconee Updated Final Safety Analysis Report (UFSAR), it is unclear whether all functions required for the successful mitigation of the design basis events set forth in Oconee's current licensing basis have been identified as required by the rule. Furthermore, since the Duke methodology may not have identified all the systems, structures, and components required under 10 CFR 54.4(a)(1),

the potential exists for this deficiency to also affect the scoping requirement of 10 CFR 54.4(a)(2) for nonsafety-related SSCs.

Accordingly, Duke must either amend its application to specify a process for identifying all events in the Oconee current licensing basis meeting the definition of "design basis events" in 10 CFR 50.49(b)(1) or provide justification for its position that the set of design basis events for Oconee meeting that definition is identified in Chapter 15 of the Oconee Updated Final Safety Analysis Report. In order to assist the staff in evaluating Duke's response to this issue, Duke should specifically list the design basis events relied on for scoping under 10 CFR 54.4(a)(1).

Design Basis Events Outside of Chapter 15 of the UFSAR The staff contends that DBEs are not limited to Chapter 15 of the UFSAR. The staff believes that events such as fire, floods, storms, or earthquakes represent DBEs. These events are not explicitly considered in the review of anticipated operational occurrences and postulated accidents in Chapter 15 of the UFSAR, but could result in potential offsite exposures comparable to the applicable guideline exposures set forth in 10 CFR 50.34(a)(1) or 10 CFR 100.11. The staff notes that Duke explicitly considers DBEs beyond Chapter 15 events in Nuclear Directive 209 "10 CFR 50.59 Evaluations."

For example, Duke considers the following events as accident/events not included in Oconee's UFSAR Chapter 15: spent fuel pool accidents, loss of main feedwater, main feedwater line break, loss of control room event, loss of instrument air, missiles, pipe rupture, fire event, internal building floods, natural phenomena, loss of lake keowee, loss of intake structure, and loss of decay heat removal. Duke needs to reconcile the list of DBEs contained in Nuclear Directive 209 with the list of DBEs that were considered in the license renewal scoping review in accordance with 10 CFR 54.4 or provide justification for not doing so.

1 The functions identified in § 50.49(b)(1)(i) (A) through (C) are identical to those identified in § 54.4(a)(1) (i) through (iii).