ML16141A911
| ML16141A911 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 04/27/1995 |
| From: | Wiens L NRC (Affiliation Not Assigned) |
| To: | Hampton J DUKE POWER CO. |
| References | |
| TAC-M90156, TAC-M90157, TAC-M90158, NUDOCS 9505020222 | |
| Download: ML16141A911 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-W001 April 27, 1995 Mr. J. W. Hampton Vice President, Oconee Site Duke Power Company P. 0. Box 1439 Seneca, SC 29679,
SUBJECT:
FATIGUE ANALYSES FOR REACTOR COOLANT PRESSURE BOUNDARY ATTACHMENT PIPING (TAC NOS. M90156, M90157, AND M90158)
Dear Mr. Hampton:
During a visit to the Oconee plant on March 8 and 9, 1994, the NRC staff identified an apparent noncompliance with a licensing basis requirement.
Specifically, the Oconee Final Safety Analysis Report (FSAR) states that the reactor coolant pressure boundary piping including the attachment piping to the first isolation valve, is required to be designed to USAS B31.7, Class I standards. However, the staff identified that the reactor coolant loop attached piping was designed to USAS B31.7, Class II standards. Since USAS B31.7, Class II requirements refer to the design criteria from the USAS B31.1 piping code, the reactor coolant system attached piping did not have fatigue analyses.
In an August 30, 1994 letter, the staff requested that you provide a response to the apparent noncompliance.
You provided the requested response in a letter dated October 3, 1994. You concluded that a noncompliance does not exist based on 1) applicable codes and standards at the time Oconee's construction permit was granted, and 2) excerpts from the Oconee FSAR.
With respect to the first item, the language of 10 CFR 50.55a in effect at the time the operating license was issued, specifies applicable codes depending on the date when the piping or fitting was ordered. Insofar as we could determine, the FSAR was silent concerning the date of ordering. Your response did not discuss the dates of order of the actual piping of concern, but did identify the construction permit date. We note that USAS B31.7 was not in effect when the Oconeelconstruction permit was granted on November 6, 1967.
With respect to the second item, you referred to the following wording contained in FSAR Section 3.2.2.2, "Piping classes A through C meet the intent of USAS B31.7 Nuclear Piping Code (February 1968) and Addenda (June 1968) with the exception of those portions of the code which lack adequate definition for complete application."
This statement seems to imply that portions of USAS B31.7 contained insufficient detail for application.
9505020222 950427 3
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Mr. J. W. Hampton
-2 However, the fatigue requirements for Class I systems were well defined -in USAS B31.7 and those provisions.were-used to analyze the main loop. Also, Section 3.2.2.1 of the Oconee FSAR'contain's a definition of a USAS B31.7, Class I system. The definition contains the following statement, "The class includes connecting piping out to and including-the first isolation valve."
On the basis of this statement, we conclude that a nonconformance with the FSAR criteria does exist at Oconee.
As stated above, we conclude that the reactor coolant system attached piping systems out to the first isolation valve that have not been analyzed to the USAS 831.7 Class I criteria constitute a nonconformance with the FSAR criteria. Therefore, Duke Power Company should perform an evaluation of these systems to demonstrate compliance with the FSAR criteria. You are requested to provide a schedule for the performance of these analyses or additional justification for not performing such analyses within 60 days of the date of this letter. If you have questions regarding this matter, contact me at (301) 415-1495.
This requirement affects nine or fewer respondents, and therefore, it is not subject to the Office of Management and Budget review under P.L.96-511.
Sincerel y, Original signed by:
L. A. Wiens, Senior Project Manager Project Directorate 11-2 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270 and 50-287 cc:
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Mr. J. W. Hampton
-2 However, the fatigue requirements for Class I systems were well defined in USAS B31.7 and those provisions were used to analyze the main loop. Also, Section 3.2.2.1 of the Oconee FSAR contains a definition of a USAS B31.7, Class I system. The definition contains the following statement, "The class includes connecting piping out to and including the first isolation valve."
On the basis of this statement, we conclude that a nonconformance with the FSAR criteria does exist at Oconee.
As stated above, we conclude that the reactor coolant system attached piping systems out to the first isolation valve that have not been analyzed to the USAS B31.7 Class I criteria constitute a nonconformance with the FSAR criteria. Therefore, Duke Power Company should perform an evaluation of these systems to demonstrate compliance with the FSAR criteria. You are requested to provide a schedule for the performance of these analyses or additional justification for not performing such analyses within 60 days of the date of this letter. If you have questions regarding this matter, contact me at (301) 415-1495.
This requirement affects nine or fewer respondents, and therefore, it is not subject to the Office of Management and Budget review under P.L.96-511.
Sincerely, L. A. Wiens, Senior Project Manager Project Directorate 11-2 Division of Reactor Projects-I/Il Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270 and 50-287 cc:
See next page
Mr. J. W. Hampton Duke Power Company Oconee Nuclear Station cc:
A. V. Carr, Esquire Mr. Ed Burchfield Duke Power Company Compliance 422 South Church Street Duke Power Company Charlotte, North Carolina 28242-0001 Oconee Nuclear Site P. 0. Box 1439 J. Michael McGarry, III, Esquire Seneca, South Carolina 29679 Winston and Strawn 1400 L Street, NW.
Ms. Karen E. Long Washington, DC 20005 Assistant Attorney General North Carolina Department of Mr. Robert B. Borsum Justice B&W Nuclear Technologies P. 0. Box 629 Suite 525 Raleigh, North Carolina 27602 1700 Rockville Pike Rockville, Maryland 20852-1631 Mr. G. A. Copp Licensing -
ECO50 Manager, LIS Duke Power Company NUS Corporation 526 South Church Street 2650 McCormick Drive, 3rd Floor Charlotte, North Carolina 28242-0001 Clearwater, Florida 34619-1035 Dayne H. Brown, Director Senior Resident Inspector Division of Radiation Protection U. S. Nuclear Regulatory Commission North Carolina Department of Route 2, Box 610 Environment, Health and Seneca, South Carolina 29678 Natural Resources P. 0. Box 27687 Regional Administrator, Region II Raleigh, North Carolina 27611-7687 U. S. Nuclear Regulatory Commission 101 Marietta Street, NW. Suite 2900 Atlanta, Georgia 30323 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