ML17289A542
| ML17289A542 | |
| Person / Time | |
|---|---|
| Issue date: | 02/13/2018 |
| From: | Hackett E Office of Nuclear Regulatory Research |
| To: | Brian Holian Office of Nuclear Reactor Regulation |
| References | |
| Download: ML17289A542 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 13, 2018 MEMORANDUM TO: Brian E. Holian, Acting Director Office of Nuclear Reactor Regulation FROM: Edwin M. Hackett, Chairman /RA/
Committee to Review Generic Requirements
SUBJECT:
COMMITTEE TO REVIEW GENERIC REQUIREMENTS:
MINUTES OF MEETING NUMBERS 448, 449, and 451 Via memo dated September 8, 2017 (ADAMS No. ML17237C031), you requested the Committee to Review Generic Requirements (CRGR, the Committee) to review and endorse proposed draft Task Interface Agreement (TIA) entitled, Oconee Nuclear Station, Units 1, 2, and 3 - Final Response to Task Interface Agreement 2014-05, Design Analysis for Single Failure and the Integration of Class 1E Direct Current Control Cabling in Raceways with High Energy Cabling (ADAMS Accession No. ML17264A031).
Consistent with the request, the staff provided a discussion of the background and regulatory implications to the Committee in support of its formal meetings. On September 26, 2017, the CRGR held Meeting No. 448 with the staff to discuss the proposed TIA Response. NRR staff conducted the briefing and answered the Committees questions. The staffs presentation is available in ADAMS via Accession No. ML17258A012. Enclosure 1 provides the list of meeting attendees.
On October 24, 2017, the CRGR held Meeting No. 449 as a public meeting to gain additional insights and perspectives on the proposed TIA response with Duke Energy, the licensee for Oconee Nuclear Station Units 1, 2, and 3 (ONS). The licensee concluded that four positions outlined in the proposed TIA response constituted new or revised regulatory positions. These included: (1) Limitations on Crediting Cable Armor for Electrical Separation, (2) Changes in Application of Single Failure Criteria for Separate Cables, (3) Changes in Single Failure Considerations Regarding Equipment Quality Classification, and (4) Changes to the Timing of Single Failures for Emergency AC Power. The licensee emphasized that ONS continues to operate safely and that Protective Service Water (PSW) modifications have significantly improved plant safety. The licensee identified concerns with the application of the TIA response beyond the electrical cable configurations found in trench #3 (from the Keowee Hydro Station to transformer CT-4) and the PSW duct bank to other parts of the ONS design basis and to Duke Energys other operating facilities, McGuire and Catawba, which share some common licensing basis elements on armored cables. The licensee discussed that the use of armored cables has been an established part of the licensing basis since the approval of the original construction and operating license at ONS. The meeting presentations and transcript are available in ADAMS via Accession Nos. ML17333A157 and ML17333A088, respectively.
CONTACT: Nicholas J. DiFrancesco, RES 301-415-1115
2 In addition, on November 15, 2017, Duke Energy sent a letter (ADAMS No. ML17334A030) to the CRGR to clarify a response provided to the Committee on October 24, 2017. During the public meeting, the CRGR received no public comments and received no meeting feedback forms following the meeting.
Subsequently, the CRGR held meeting No. 451 with the NRC staff, on November 7, 2017, to discuss the concerns raised by the licensee. The CRGR identified revisions to the draft TIA response to focus application of the document to electrical cable configurations found in trench
- 3 and the PSW duct bank.
In considering the review of the draft TIA response and information presented at the three meetings with the licensee and NRC staff, the Committee found that the language in the TIA response could be enhanced to avoid potential misapplication of the staffs conclusions to other parts of ONSs design or licensing basis or to the McGuire and Catawba facilities. The Committee provided recommendations to NRR staff to revise the TIA response to (1) ensure the scope of the TIA response is narrowed to trench #3 and the PSW duct bank; (2) clarify consideration of the medium-voltage cable test report; (3) clarify that cable shielding does not provide equivalent protection to cable armoring in consideration of NRC accepted industry standards or provisions in the ONS licensing basis; and (4) clarify the limits on the TIA responses use and application.
CONCLUSIONS and RECOMMENDATIONS Following the review of the proposed TIA response and external interactions, the Committee identified a number of opportunities to ensure the language of the proposed TIA response appropriately focused the scope to the issues under review. The Committee endorsed the TIA response for issuance following staff-incorporated changes and found that the revised TIA response does not contain backfitting or new staff positions. The CRGR cautions that broad application of the proposed TIA response would not be appropriate and could result in unanalyzed backfits to the facility.
Enclosures:
Enclosure 1: List of Attendees for CRGR Meeting No. 448 Enclosure 2: List of Attendees for CRGR Meeting No. 449 Enclosure 3: List of Attendees for CRGR Meeting No. 451 Enclosure 4: List of References
ML17289A542 OFFICE RES/TA CRGR Tech Editor CRGR NAME N. DiFrancesco L. Cupidon J. Zabel E .Hackett DATE 1/18/18 2/5/18 2/2/18 2/13/18 CRGR MEETING No. 448 LIST OF ATTENDEES (September 26, 2017)
CRGR Members Edwin M. Hackett, Chairman Brian J. McDermott, NRR Scott W. Moore, NMSS Darrell Roberts, NSIR and RIII John D. Monninger, NRO Cathy L. Scott, OGC Les R. Cupidon, CRGR Staff NRC Staff Rich Harper, OCM/KLS Isaac Anchondo, NRR/DORL/LPL2-1 M.J. Ross-Lee, NRR/DE Mike Markley, NRR/DORL/LPL2-1 Theresa Clark, OEDO Nicholas J. DiFrancesco, RES/FO Roy Mathew, NRR/DE/EEOB Sharon Morris, NRR/DE/EEOB Nanette Valliere, OCM/SB Tony Gody, R-II/DRS Jonathan Bartley, R-II/DRS Mark Jeffers, R-III Thomas Koshy, RES/DE/ICEEB Kenn Miller, RES/DE/ICEEB Audrey Klett, NRR/DORL/LPL2-1 Jeanne Johnston, NRR/DORL/LSPB Eric Benner, NRR/DORL John Lubinski, NRR/DE Doug Broaddus, NRR/DORL Anne T. Boland, NRR/DORL ENCLOSURE 1
CRGR MEETING No. 449 LIST OF ATTENDEES (October 24, 2017)
CRGR Members Edwin M. Hackett, Chairman Public Brian J. McDermott, NRR Darani Reddick, Exelon Corporation Scott W. Moore, NMSS Jeff Sharkey, Southern Nuclear Darrell Roberts, NSIR and RIII Jerry Bonanno, Nuclear Energy Institute John D. Monninger, NRO Cathy L. Scott, OGC Deann R., Curtiss Wright*
Les R. Cupidon, CRGR Staff Alan Jelalian, Engineering Planning and Management (EPM), Inc.*
Licensee Staff Russell Thompson, Tennessee Valley Chris Wasik, Duke Energy Authority*
Todd Grant, Duke Energy Greg Richardson*
Ryan Greco, Duke Energy David Wilson*
Chris Nolan, Duke Energy Ed Burchfield, Duke Energy Scott Batson, Duke Energy David Cummings, Duke Energy Thomas C. Poindexter, Morgan Lewis for Duke Energy Ray Price Jr., Duke Energy Dean Hubband, Duke Energy NRC Staff Steven Arndt, NRR/DE Andrey Klett, NRR/DORL/LPL2-1 Tim Reed, NRR/DORL Tony Gody, R-II/DRS Samson Lee, NRR/DORL Shakur Walker, R-II/DRS Harry Barrett, NRR/DRA/APLA Eric Benner, NRR/DORL Mike Markley, NRR/DORL/LPL2-1 Roy Mathew, NRR/DE Kenn Miller, RES/DE Jesse Quichocho, NRR/DE/EEOB C.J. Fong, NRC/OCM/KLS Thomas Koshy, RES/ICEEB Theresa Clark, OEDO *Via teleconference John Lubinski, NRR/DE Mark Miller, R-II/DRS*
Gurcharan Matharu, NRR/EEOB*
Jonathan Bartley, R-II ENCLOSURE 2
CRGR MEETING No. 451 LIST OF ATTENDEES (November 7, 2017)
CRGR Members Edwin M. Hackett, Chairman Brian J. McDermott, NRR Scott W. Moore, NMSS Darrell Roberts, NSIR and RIII John D. Monninger, NRO Cathy L. Scott, OGC Les R. Cupidon, CRGR Staff NRC Staff John Lubinski, NRR/DE Kenn Miller, RES/DE/ICEEB Eric Benner, NRR/DORL Doug Broaddus, NRR/DORL Jessie Quichocho, NRR/DE/EEOB Hari Kodali, NRR/DE/EEOB Roy Mathew, NRR/DE/EEOB Mike Markley, NRR/DORL/LPL2-1 Steve Arndt, NRR/DE Eva Brown, NRR/DORL/LSPB Theresa Clark, OEDO Tim Reed, NRR/DORL/LSPB Samson Lee, NRR/DORL/LSPB Audrey Klett, NRR/DORL/LPL2-1 Kenneth Miller, RES/DE/ICEEB
- Via Phone Nicholas J. DiFrancesco, RES/FO ENCLOSURE 3
2 CRGR MEETING Nos. 448, 449, and 451 LIST OF REFERENCES Request for Review and Endorsement of the Oconee Nuclear Station, Units 1, 2, and 3 -
Response to Task Interface Agreement 2014-05, Design Analysis for Single Failure and the Integration of Class 1E Direct Current Control Cabling in raceways with High Energy Power Cabling (CAC NOS. MF4626, MF4627, AND MF4628), September 7, 2017 (ADAMS No.
NRC Slide Presentation to the Committee to Review Generic Requirements on Oconee Nuclear Station Cable Separation TIA, September 26, 2017 (ADAMS No. ML17258A012).
Oconee Nuclear Station - Transmittal of Revised Draft TIA 2014-05 Response Related to the Design Analysis for Single Failure and the Integration of Class IE Direct Current Control Cabling in Electrical Raceways with High Energy Power (CAC MF4626-MF4628), September 29, 2017 (ADAMS No. ML17264A032).
Revised September 2017 Draft Response to Task Interface Agreement 2014-05 to Licensee Re: Oconee Design Analysis for Single Failure/Integration of Class 1E Direct Current Control Cabling in Raceways with High Energy Power Cabling (CAC Nos. MF4626, MF4627, MF4628)
(ADAMS No. ML17264A031).
Oconee Nuclear Station - Duke Energy Presentation to the NRC Committee to Review Generic Requirements (CRGR), October 24, 2017 (ADAMS No. ML17333A157).
Transcript of October 24, 2017, Meeting with CRGR to Discuss Duke Energy Views Associated with a Revised Draft Task Interface Agreement Response (ADAMS No. ML17333A088).
Meeting Notice for CRGR meeting to Discuss Duke Energy Backfitting Views Associated with a Revised Draft Task Interface Agreement Response Regarding Oconee Nuclear Station, October 13, 2017 (ADAMS No. ML17296A497).
Letter from Thomas D. Ray of Duke Energy (Oconee Nuclear Station) NOS-2017-085 re Duke Energy Comments on the October 24, 2017 Public Meeting with NRC Committee to Review Generic Requirements (CRGR), November 15, 2017 (ADAMS No. ML17334A030).
ENCLOSURE 4