ML17195A658
| ML17195A658 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley, Millstone, Dresden, Nine Mile Point, Palisades, Wolf Creek, Callaway, Rancho Seco, 05000000 |
| Issue date: | 10/26/1984 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8411060146 | |
| Download: ML17195A658 (9) | |
Text
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MEMORANDUM FOR:
FROM:
SUBJECT:
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 OCT 2 6 1984 Harold R. Denton, Director Office of Nuclear Reactor Regulation Darrell G. Eisenhut, Director Division of Licensing PLANT-SPECIFIC BACKFITTING TRACKING SYSTEM Enclosed is the monthly status report on plant-specific backfits through August 1984 prepared by DL.
Table 1 shows the status of backfitting issues for both ORs and OL applicants.
TABLE 1 ORs oLs TOTAL ISSUES IDENTIFIED 14 20 0
Issues in Staff Negotiation 6
9 Process 0
Issues Resolved Prior to 7
4 Appeal Process 0
Issues PendinJ 1st Level 0
2 Appeal (AD/DL 0
Issues Pending 2nd Level 0
0 Appeal (D/DL) 0 Issues Pending D/NRR Decision 0
0 Level 0
Issues Resolved by Appeal/Level 1/DD 5/AD Since January 1984, 17 backfitting issues have been resolved and 17 remain open.
The enclosed Table 2 provides a description of each open issue.
The NRR interim procedures do. not specifically address treatment of requirements identified by the licensee as backfits. However, DL typically handles this case using the same procedures for requirements identified by the staff as backfits. That is, when the staff issues a requirement.which it believes is within the scope of current regulations, the licensee may appeal that requirement as an unwarranted backfit just as it can choose to do with a staff-issued backfit. If the issue is determined a backfit at any appeal
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Haro.ld R. Denton
.. : level, the staff must provide justification and a technical basis supporting the.requirement.
The appeal process continues, addressing the technical aspects of the issue.
We expect that the process of making th~ backfit determination and providing justification would be completed within 45 days.
We are d~vel6ping proposed modifications to the interim procedures to reflect*
mo~e ~ccurately the appeal process.
Enclosure:
Frank Miraglia/fo?f.i; *,_
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Darrell G. Eisenh~t, bi;e~ctor*'.
Division of LicensiQg
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Table 2
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DlSTRIBUTION
- 1 Central File
,.,.*; NRC PDR
.ORAB Rdg DEisenhut DCrutchfield
- GHo 1 ahan. *
- PTremblay
.*PREVIOUS CONCURRENCE SEE DATE ORAB:DL*
ORAB:DL*
PTremblay:dm. JZwolinski 9/12/84.
10/~0/84 C:.ORAB:DL*
GHolahan 10/09/84
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AD/SA:DL*
DCrutchfield 10/ /84
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f TABLE 2 PLANT-SPECIFIC BACKFITTING.STATUS SA-83 DRESDEN 2 Issue:
The staff transmitted an SER to the licensee indicating that seal purge and vent valves should Re-closed.
The staff 1s findings including technical basis were contained in its letter to the licensee dated 11/4/83.
Status:
The licensee disagreed with the requirement.
The licensee in their letter of 12/21/83 presented ~justification of its position which addressed valve operability procedures.
The staff transmitted a report on 3/2/84 to the licensee; the licensee responded:with an evaluation on 5/3/84.
EQB is evaluating the response.
An appeal meeting has not been established.
SA-83 PALISADES Issue:
The staff identified the issue in its 1/82 integrated assessment for SEP that a single failure of an MSIV could cause both steam generators to blowdown inside containment.
The staff concluded that appropriate MSIV modifications are necessary because: -
(1) decay heat removal without an isolated steam generator is an even'twhich goes beyond the Design Basis Accident for Palisades and further indicating that decay heat removal under such circumstances cannot be ensured, (2) there have been several MSIV failures at the Palisades plant indicating that the postulated single failure has a fairly high probability of occurrence.
Status:
The licensee requested in their letter of 8/15/83 that this modification be deferred for about one year, so that they could confinn critical assumptions in their PRA and study alternative corrective actions to increase reliability for decay heat removal using the secondary side. The staff accepted interim plant operation in our SER of 8/14/83 until the licensee submits their PRA during 9/84.
An appeal meeting has not been established.
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The staff in a 9/26/83 letter to the licensee raised a major issue regarding internally generated missles.
Specifically, we requested the licensee to ascertain if the potential exists, in the AFWS, for internally generated missiles to be the source of possible failure.
The SRP requires that effects of internal missiles should be evaluated in conjunction with single active failures.
Status:
A walkdown of the AFWS to identify components which could be susceptible to a single internally generated missile was originally scheduled with the licensee during 2/84.
The licensee in preparation for the walkdown had a contractor evaluate the effects of postulated internally generated missiles on the AFWS.
This report was submitted on 5/3/84. The staff completed its review on 8/31/84 and decided that a walkdown was not necessary.
- However, the staff submitted questions to the licensee which they are in the process of answering which will detennine the next action *.
L-83 NINE MILE POINT 2 Issue:
The staff identified in ~ts review process that the applicant should use Hydrometeorology Reports 51 and 52 to establish Probable Maximum Precipitation (PMP).
The staff's position on using these updated reports was sent to the applicant on 2/3/84.
Status:
The applicant presented their case for detennining PMP on the basis of the earlier Hydrometeorology Report 22, which is easier to conform to, during a 5/11/84 meeting including NOAA and the National Weather Service with the staff *. The staff advised the applicant in its 7 /19/84 letter that this remains an open issue as identified in our 5/15/84 SER and that the applicant can appeal the staff's position. The applicant has not indicated if they intend to appeal.
L-84 BEAVER VALLEY 2 Issue:
Status:
The staff identified in our 2/84 draft SER that the applicant should provide cable spreading room fire protection in accordance with CMEB BTP 9.5-1 which requires the primary fire suppression to be an automatic water system.
The applicant in their letter of 5/30/84 stated that they believe their co, fire suppression system meets the intent of CMEB BTP 9.5-1 and complies with 10 CFR 50, Appendix R requirements *. The staff and applicant are in the process of scheduling an appeal meeting for October 1984.
L-84 BEAVER VALLEY 2 Issue:
The staff identified in our 5/14/84 draft SER that the applicant ~hould demonstrate that the spent fuel cooling system is capable of maintaining water temperature at or below 140°F when the pool is completely filled with nonnal discharges assuming one cooling train has failed.
Status:
The applicant in their letter of 6/15/84 stated that they believe this position goes beyond. the acceptance criteria contained. in the SRP.
Internal staff negotiations detennined that the applicant should submit an analysis for staff consideration in resolutjon of this issue. The applicant was infonned of this decision by telephone on 8/3/84.
L-84 BEAVER VALLEY 2 Issue:
The staff transmitted, on 9/19/83 questions 430.97, and 430.100 addressing the requirement that the compressed air starting system design for the emergency diesel generators should include air dryers for removal of entrained moisture.
Status:
The applicant's letter of 6/15/84* stated that they believe this is a backfit item since the initial air starting system design was approved during the CP stage of review.
The staff is reviewing this issue to decide the appropriateness of our requirement.
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L-84 BEAVER VALLEY 2 Issue:
The staff identified in our 2/84 draft SER that the applicant's steam generator level control design does not meet IEEE-279 which is required since SG level function is included in the FSAR (Ch. 15) analysis.
Status:
The applicant in their letter of 5/30/84 stated that compliance with IEEE:.279 is not required since core protection is maintained even if all staff postulated failures occur.
Subsequently, in a letter dated 6/8/84 the applicant states that they should not be required to justify the steam generator level control function as a safety feature.
An analysis demonstrating the function's capability to serve as a safety feature was included with the 6/8/84 submittal. The staff is reviewing this analysis.
L-84 BEAVER VALLEY 2 Issue:
The staff identified in our~2/84 draft SER that the applicant should modify the circuit design of certain motor-operated valves, such as those for their cold leg accumulator isolation, since a short or relay failure could constitute a nondetectable failure and thus violate the single failure criterion_
Status:
The applicant in their letter of 6/15/84 maintained that the existing design complies with IEEE-279 in that the valves are administratively controlled and monitored to ensure no protective action is required. The staff is reviewing this issue and depending upon the results of this review, this issue remains open.
L-84 BEAVER VALLEY 2 Issue:
The staff transmitted on 9/19/83 questions 430.66 and 430.68 to the applicant addressing the requirement that the applicant should modify their design of the lighting and communications systems to meet Class lE requirements.
Status:
The applicant in their letter of 6/25/84 stated that they believe this position goes beyond SRP acceptance criteria which was used in the review of their FSAR.
The staff is
. reviewing this issue and depending upon the results of this review, this issue remains open.
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The staff transmitted on 8/31/83 questions 240.1 and 240.8 to the'applicant containing. the staff's position that the applicant should use the latest publications available, Hydrometeorological Reports 51 and 52, to determine probabl~ maximum precipitation (PMP) values and to evaluate site damage.
Status:
The applicant in their letter of 5/30/84 maintained that such a change in evaluation criteria goes beyond applicable SRP evaluation criteria. The staff and applicant are in the process of scheduling an appeal meeting for October 1984.
L-84 BEAVER VALLEY 2 Issue:
The staff transmitted on 9/19/83 question 430.119 containing our position that the applicant should provide a low level alarm for the rocker aim lube oil reservoir on the emergency diesel generators. in accordance with SRP 9.5.7.
Status:
The applicant in their letter of. 6/25/84 maintained that this is a new interpretation of the SRP since its design is standard. Also this engine manufacturer was previously app_roved by the NRC.
Ttre staff is reevaluating this issue.
OR-84 MILLSTONE 2 Issue:
The staff identified in our 1~/30/83 SER that the licensee should perform an accident analysis on phenomena such as steam line breaks and steam generator tube ruptures with and without loss of offsite power as required by GDC-17.
Status:
The licensee has performed this analysis but it has not been submitted to the staff. The licensee expects to send this, along with a Westinghouse analysis addressing thermal mixing, by mid-September 1984. This information is expected to satisfy staff concerns which should preclude a request for an appeals meeting.*
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The staff identified in our 12/30/83 SER that the licensee should ensure that the hydrogen purge system valves receive a closure signal from a radiation monitor.
Status:
The licensee requested an appeals meeting in their letter of 4/15/84. Prior to arranging this meeting, the licensee sent an analysis on 7/13/84 justifying their position. The staff has reviewed the analysis and submitted questions to the licensee. A response from the licensee is expected in mid-September 1984 which could lead to the resolution of this issue.
OR-84 MILLSTONE 2 Issue:
The staff identified that the licensee should submit Technical Specifications on limiting overtime in our letter dated 11/28/83. This is a NUREG-0737 requirement.
Status:
The licensee suggested in their letters of 5/2/84 and 7/2/84 that the Technical Specifications be modified by referencing their Administrative Procedures.
The staff has requested that the licensee propose wording for the modification of their Tech Specs.
The staff also has a pending Order requiring the licensee to submit a schedule for submitting the requested Tech Specs.
The licensee has not formally appealed this action, but might.
L-84 WOLF CREEK Issue:
During a fire protection audit at the site on 7/30/84, the staff identified a concern about the ability of the plant operators to obtain safe shutdown from outside the control room.
Status:
In response to this concern, the applicant provided information that the isolation capabilities of the SNUPPS design had been approved as documented in SSER 3. However, as a result of the inspection, the.staff determined the SSERs were in error and the applicant would need to take corrective action. The applicant met with the staff to appeal our position on 8/14/84. It was concluded that an appeal decision was not necessary.
The applicant will v.:-.-
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submit further information for staff review in September 1984.
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During a fire protection audit at Wolf Creek 1 on 7/30/84, the staff identified a concern about the ability of the plant operators to obtain safe shutdown from outside the control room.
This concern applies also to Callaway since both facilities are SNUPPS designs.
Status:
In response to this concern, the applicant provided information that the isolation capabilities of the SNUPPS design had been approved as documented in SSER 3. However, as a result of the inspection, the staff determined the SSERs were in error and the applicant would need to take corrective action. The applicant met with the staff to appeal our position on 8/14/84. It was concluded that an appeal decision was not necessary.
The applicant will submit further information for staff review in September 1984.
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