ML16209A289
| ML16209A289 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 09/27/1996 |
| From: | Moulton J NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| TAC-M96277, TAC-M96278, TAC-M96279, NUDOCS 9610010278 | |
| Download: ML16209A289 (6) | |
Text
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-2v UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-001 Septenber 27, 1996 ORGANIZATION: Duke Power Company
SUBJECT:
SUMMARY
OF MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND DUKE POWER REPRESENTATIVES TO DISCUSS DEFICIENCIES IN OLRP-1001 (TAC NO. M96277, 96278, 96279)
On September 18, 1996, the Nuclear Regulatory Commission (NRC) staff met with representatives of the Duke Power Company to discuss the specific format and content deficiencies in their License Renewal Technical Information Report (OLRP-1001) for Oconee Nuclear Station, Units 1, 2, and 3 (0NS 1, 2 & 3) that prevent the NRC staff from beginning its review. By letter dated September 6, 1996, the staff informed Duke that OLRP-1001 did not contain adequate information for the staff to begin its review. The list of meeting attendees is contained in Attachment 1.
In the meeting, the staff provided Duke with specific areas where OLRP-1001 fell short of the staff's expectations. In summary, the staff stated that OLRP-1001 provided little explanation of the Duke methodology for scoping structures and components subject to an aging management review and provided little basis for their conclusions that aging effects were adequately managed.
The staff provided specific citations to the Nuclear Energy Institute's guideline regarding report deficiencies. The staff stressed to Duke that its list of deficiencies was intended to represent example areas where the report fell short and not a detailed request for additional information, the resolution of which would make the report acceptable to the staff in all respects. The list of format and content deficiencies discussed at the meeting is contained in Attachment 2.
In addition to the deficiencies contained in Attachment 2, the staff also informed Duke of its current thinking regarding report content concerning current licensing basis (CLB) design conditions as they relate to the intended functions of structures and components (SCs) requiring an aging management review for license renewal.
The staff stated that for licensees to ensure that an SC's intended function is maintained under all CLB conditions, licensees must articulate the design loading conditions associated with the intended functions of SCs subject to aging management review. Duke stated that this staff expectation appears to be a significant undertaking and that they would appreciate additional dialogue with the staff on this issue.
o NRC F IL.E CENTER COPY 9610010276 960927 PDR ADOCK 05000269 P
2 -
September 27, 1996 In conclusion, representatives from Duke Power expressed appreciation for the staff's feedback and expressed their desire to work with the staff to develop the appropriate format and content of Duke license renewal submittals. Duke stated that they intend to revise OLRP-1001 based on the staff's comments and are expected to contact the staff to discuss the schedule.
Original Signed By:
John P. Moulton, Project Manager License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket Nos.:
50-269, 50-270, and 287 Attachments:
- 1. Attendance List
- 2. Meeting Handout cc w/attachments:
See service list R. L. Gill, Duke Power DISTRIBUTION uattachments:
DISTRIBUTION w/o attachments:
Central File/Docket File FMiraglia, 0-12 G18 PUBLIC RZinuerman, 0-12 G18 PDLR RIF GHoLahan, 0-8 E2 MCase, 0-11 H21 AThadani, 0-12 G18 DLaBarge, 0-14 B21 BSheron, 0-7 D26 DISTRIBUTION via e-mail w/o attachments:
TMartin, 0-11 H21 JMitcheLL, EDO (JAM)
JCraig, RES (JWC1)
ACRS, T-2 E26 MMayfield, RES (MEM2)
Jora, RES (JPV)
MMaLsch, 0-15 B18 AMurphy, RES (AJM1)
RWessman, NRR (RHW)
TSpeis, T-10 F12 HBramer, NRR (HLB)
JStrosnider, NRR.(JRS2)
EJordan, T-4 D18 RCorreia, NRR (RPC)
GMizuno, OGC (GSM)
JMoore/EHoLLer, 0-15 B1 PDLR Staff SDroggitis, OSP (SCD)
OGC, 0-15 818 LShao, RES (LCS1)
FCherny, RES (FCC1)
DMathews, 0-10 H5 GBagchi, NRR (GXB1)
RJohnson, T-10 EIO
- RFrahRn, Jr., NRR (RKF)
DOCUMENT NAME:
A:MTGSEP96.BWG (JMoulton/LLM Disk)
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" =Copy with attachment/enclosure WN No copy FFJICE PMt:PD R D:PDLR.
DATE 9/,2. /96-9/ j96 OFFICIAL RECORD COPY
Duke Power Company Oconee Nuclear Station cc:
Mr. Paul R. Newton Mr. Ed Burchfield Duke Power Company, PB05E 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 Framatome Technologies.
P. 0. Box 629 Suite 525 Raleigh, North Carolina 27602 1700 Rockville Pike Rockville, Maryland 20852 Mr. G. A. Copp Licensing -
EC050 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 Mr. J. W. Hampton Atlanta, Georgia 30323 Vice President, Oconee Site Duke Power Company Max Batavia, Chief P. 0. Box 1439 Bureau of Radiological Health Seneca, South Carolina 27679 South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, South Carolina 29201 County Supervisor of Oconee County Walhalla, South Carolina 29621
AttachmentlI ATTENDANCE LIST NRC MEETING WITH DUKE POWER COMPANY FORMAT AND CONTENT DEFICIENCIES (OLRP-1001)
September 18. 1996 NAME ORGANIZATION
- 1.
P. T. Kuo NRC/NRR/DRPM/PDLR
- 2.
Paul Shemanski NRC/NRR/DRPM/PDLR
- 3.
- Winston W. C. Liu NRC/NRR/DRPM/PDLR
- 4.
Scott Newberry NRC/NRR/DRPM/PDLR
- 5.
-Debbie Ramsey Duke Power Company
- 6.
Robert Gill Duke Power Company
- 7.
-Greg Robison Duke Power Company
- 8.
Bill Horin Winston & Strawn
- 9.
Chuck Necjin Oak Technologies
- 10.
Tricia Heroux for EPRI
- 11.
Paul Newton Duke Power Company
- 12.
Ron Miranda GPU Nuclear
- 13.
Bob Borsum FT I
- 14.
Lynn Connor for STS
- 15.
Scott Flanders NRC/NRR/DRPM/PDLR
- 16.
Steve Hoffman NRC /NRR/DRPM/PDLR
- 17.
- 18.
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- 27.
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Attachnmt 2 OLRP-1001 FORMAT AND CONTENT DEFICIENCIES (September 18, 1996)
SCOPING, INTENDED FUNCTIONS, & AGING EFFECTS
- 1.
Section 2.3 of OLRP-1001 does not delineate the evaluation boundaries (NEI 4.1.1). The report implies that only Class 1 structures of the reactor building are in the scope.
- 2.
Section 2.3 appears to use commodity groupings (i.e. mechanical penetrations, electrical penetrations, anchors, embedments, etc...) but no discussion of the bases for their groupings are provided. (NEI 4.1.2). Also, not clear whether the Oconee knows exactly what SCs make up these commodity groups (i.e. number, location, etc...).
No reference made to documentation maintained on site that would contain such information. This is inherent in identification and listing of SCs subject to aging management review.
- 3.
While Section 2.2 describes the method for scoping it amounts to little more than "we look at our source documents and pull out the SCs that meet 54.4". In addition to a "description", NEI 4.4.1 and 6.2.2 requires a "justification" of the method. This implies a bit more detail as to how the process ensures all SCs required for an AMR are scoped in. For example: How are safety related SCs identified? How are non-safety that affect safety identified? How is site operating experience and generic industry operating experience factored into the process? How is the data documented and controlled onsite? What specific documents onsite contain your scoping processes and detailed results? In essence, you must provide the staff with enough information to provide reasonable assurance that your process is comprehensive enough to scope what is required.
- 4.
While Section 2.3 lists intended functions for the Rx Bldg, they are not uniquely assigned to each SC subject to an AMR. (NEI 4.4.1).
- 5.
Section 3.3 does not discuss the service environments of Rx Bldg SCs in assessing applicable aging effects. (NEI 6.2.3).
- 6.
Section 2.3 did not discuss industry operating experience. (NEI 4.2.1.1).
- 7.
Section 3.3 concludes that cracking or spalling was experienced on concrete surfaces but that there are no applicable aging effects for concrete.
No basis for this statement is provided. (NEI 4.2.1)
OLRP-1001 FORMAT AND CONTENT DEFICIENCIES (Cont'd)
AGING MANAGEMENT DEMONSTRATION
- 1.
The demonstrations provided in 3.3 do not relate aging effects to the impact on intended function under all design conditions. In fact, Section 3.3 makes no mention of what intended functions are being maintained. Rather it merely concludes that intended functions are maintained. (NEI 4.2.1.3).
- 2.
Section 3.3 states that the Rx Bldg Visual Inspection includes the key elements of 95-10 but does not specify what the elements are and how it meets them.
- 3.
No demonstration as per NEI 4.2.1.3 provided relative to Rx Bldg Civil Inspection Program. For example, as per NEI 4.2.1.2 and NEI 4.2.1.3:
What is the scope of the program? What parameters are inspected? What is the frequency of inspection, alert values, acceptance criteria, corrective actions, etc... that provide assurance that the aging effect will be detected and addressed before loss of SC intended function?
Merely stating that the intended function will be maintained by a program is not sufficient.
TLAA EVALUATION
- 1.
Topical Report, Section 1.4.1 simply provided a list of Oconee-specific TLAAs in Table 1.4-1. A discussion of the calculations and analyses that meet all 6 criteria of Part 54.3 is missing for each TLAA that was identified.
- 2.
Section 1.4.1, the timing for evaluation/submittal of TLAAs was not discussed (NEI 5.1.4).