ML17309A230

Forwards Evaluation of SEP Topic III-03.C,inservice Insp of Water Control Structures.Program Does Not Comply W/Reg Guide 1.127 & Must Be Modified

ML17309A230
Person / Time
Site:	Ginna
Issue date:	02/22/1982
From:	Crutchfield D Office of Nuclear Reactor Regulation
To:	Maier J ROCHESTER GAS & ELECTRIC CORP.
References
RTR-REGGD-01.127, RTR-REGGD-1.127, TASK-03-03.C, TASK-3-3.C, TASK-RR LSO5-82-02-090, LSO5-82-2-90, NUDOCS 8203010148
Download: ML17309A230 (11)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O. C. 20555 February 22, 1982 Docket Ho. 50-244 LS05 02-090 Mr. John E. Haier Vice President Electric and Steam Production Rochester Gas 3 Electric Corp.

89 East Avenue Rochester, Hew York 14649

SUBJECT:

EVALUATION OF SEP TOPIC III-3.C, IHSERVICE INSPECTION OF WATER CONTROL STRUCTURES - R.

E.

GIHNA NUCLEAR POWER PLANT UNIT 1 The Rochester Gas and Electri'c letter (Maier to Crutchfield) dated October 12, 1981 submitted SEP Topic III-3.C for NRC review.

Enclosed is our' evaluation of this topic.

In summary, the staff concludes that the'resent inspection, program for water control structures at the R.E.

Ginna plant does not conform with the intent of Regulatory Guide 1.127 and should be modified to incorporate the recommendations identified in the evaluation..

Please inform HRC within 30 days of the action to be taken regarding this topic.

Sincerely,

Enclosure:

As stated cc w/enclosure':

See next page Dennis M. Cru ch 'e

, Ch' Operating Reactors Branch No.

5

'Division of Licensing bg0 l )]pL'h

Ginna Docket Ho. 50-244 Rev'. 2/8/82 Mr. John E. Maier CC Harry H. Yoigt, Esquire

LeBoeuf, Lamb, Leiby and MacRae 1333 New Hampshire Avenue, N.

W.

Suite 1100 Washington, D. C.

20036 Mr.. Michael Slade 12 Trailwood Circle R'ochester, New York 14618 Ezra Bialik Assistant Attorney General Environmental Protection Bureau New York State Department of Law 2 World Trade Center New York, New York 10047 Resident Inspector E. Ginna Plant c/o U. S.

NRC 1503 Lake'oad

Ontario, New York 14519

Director, Bureau of Nuclear Operations State of New York Energy Office Agency Building 2 Empire State Plaza

Albany, New York 12223 Rocheste~

Public Library 115 South Avenue Rochester, New York 14604 Supervisor of the Town of Ontario 107 Ridge Road West

Ontario, New York 14519 N

Dr. Emmeth A. 'Luebke

'Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission'ashington, D. C.

20555.

Or. Richard F. Cole Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.

20555 U. S. EnvironmentalProtection Agency Region II Office ATTN:

Regional Radiation Representative 26 Federal Plaza New York, New York 10007 Herbert Grossman, Esq.,

Chairman Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Ronald C. Haynes, Regional Administrator Nuclear Regulatory Commission, Region I Office of Inspection and Enforcement 631 Park Avenue King of Prussia, Pennsylvania 19406

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Systematic Evaluation. Program Topic Assessment Topic III-3.C - Inservice Inspection of Water Control Structures R,E. Ginna Nuclear Power Plant

.Docket Number 50-244 I.

INTRODUCTION PURPOSE OF REVIEW

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The purpose of this review is to evaluate the assumptions, conclusions, and completeness of documentation in responses by the Rochester Gas and'lectric Corporation

{RGEE) for systematic evaluation program (SEP) Topic III-3,C'(Inservice Inspection of Mater Control Structures) for the R. E. Ginna Nuclear Power Plant.

It includes'ndependent analyses by the Franklin Research Center (FRC) needed to clarify or resolve issues.

The Nuclear Regulatory Comiiission (NRC) is reviewing this and other safety topics within the SEP and intends to coordinate an integrated assessment of plant 'safety after completibn of the review of all applicable safety topics and design basis events (DBEs).

GENERIC BACKGROUND The SEP was established to evaluate the safety of ll of the older nuclear power plants.

An important element of the evaluation is to. judge the plants by current licensing criteria with respect to 137 selected topics, several..

of which relate to hydrologic assessments of the site.

In a letter dated January 14, 1981 (1), the NRC agreed to the SEP Owners Group's proposed redirection of the SEP whereby each licensee would select any 60~~. of the SEP topics and submit 'evaluations of these for a.review by the NRC staff.

Evaluations of tooics not selected by a licensee were the NRC's responsibility.

The Licensee

{RGSE) chose to submit an evaluation for Topic III-3.C in accordance with the SEP guidelines.

'I PLANT<<SPECIFIC BACKGROUND In a letter to the NRC dated October 12, 1981 (2),

RGEE submitted its evaluation of Topic III-3.C., comparing the water control structure inspection program for the R.E. Ginna Nuclear Plant wjth criteria currently used by the NRC staff. for licensing. new facilities..

This report reviews the submitted documentation a'nd assesses the adequacy 'of. the LIcensee's evaluation.

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REVIEW CRITERIA The reference criteria used for this topic were 'based on the Codh of Federal Regulations, Title 10, Part 50 (10 CFR50), Section 50.36, and Appendix A (General Design Criteria 1, 2 and 44),

and

10CFR100, including Appendix A.

Pertinent r'egulatory positions are identified in the following Regulatory Guides:

1.127 Inspection of Water-Control Structures Associated with Nuclear Power Plants (3) 1.27 Ultimate Heat Sink for Nuclear Power Plants (4) 1.28 guality Assur ance Program Requirements (Design 5 Construction)

(5) 1.132 Site Investigations for Foundations of Nuclear Power Plants (7)

. The specific criteria against which the Licensee's submittal was evaluated are given in Regulatory Guide 1.127.

III.

RELATED SAFETY TOPICS AND INTERFACES

'he, settlement of structures and buried equipment are reviewed under Topic II-4.F.

Other interface topics include II-4.E, "Dam Integrity"; III-6, "Seismic Design Considerations";

XVI, "Technical Specifications"; III-3.A, "Effects of High Mater Level on Structures";

IX-3, "Station Service and Cooling Water Systems";

II-3.B, "Flooding Potential an'd Protection Requirements";

II-3.B.1, "Capability of Operating Plant to Cope with Design Basis Flooding Conditions";

and II-3.C, "Safety Related Mater Supply (Ultimate Heat Sink)".

IV.

REVIEW GUIDELINES In general, the review process was conducted in accordance with the procedures described in Standard Review Plan, NUREG-0800.

Pertinent reference documents not cited in SRP are included in part V "Topic Evaluation".

Y.

TOPIC EYALUATION In the following evaluation, pertinent elements of the inservice inspection

'program for water. control structures at the R. E. Ginna Nuclear Plant are compared with the. regulatory positions stated in Regulatory Guide'.127.

SAFETY RELATED WATER CONTROL STRUCTURES The following water control structures and components associated with the R. E. Ginna site were identified by the Licensee (2) as requiring surveillance.

in accordance with applicable Commission rules and Regulatory Guide 1.127.

A; Cooling Water System Struct'ures The identified cooling water system structures were. those relateo to the availability and protection of the ultimate heat sink (UHS).

They included the intake structure.and tunnel, discharge

canal, trash rack, and traveling screens.

According to the NRC evaluation of SEP Topic II-3.C, "Safety Related Water Supply (Ultimate Heat Sink)" (8), the UHS for the Ginna plant is Lake Ontario.

Water is conveyed from the intake crib (elevation 217.0 ft msl) to.

'the Screenhouse (intake structure) through a

buried conduit.

The seismic capability of UHS structures and conveyances is reviewed under SEP Topic III-6, We concur with the Licensee's selection of the intake structure,

tunnel, discharge

canal, trash rack, and traveling scr eens as cooling water system structures necessary to provide coolant water during safe shutdown of the reactor:

B.

Flood Control Structures The flood control structures identified by the Licensee (2) include the revetment and gates.

The function of the revetment is to prevent Cloodin'g of safety-related equipment due to adverse conditions, such as wave runup, resulting from storms and seiches on Lake Ontario.

The revetment was designed to protect the plant from the consequences of a probable maximum surge (PMS) of Lake Ontario.

Its cap stones'1:-'".ve a minimum elevation of 261 ft msl.

The NRC with the assistance of the Corps of Engineers (13), reviewed the condition of the revetment on November 13, 1981 (9) and concluded the following:

a.

the revetment is sound and stable at this time b.

the revetment should be monitored/inspected for degradation, c.

an initial survey should be conducted to provide a baseline against

'hich vertical and horizontal movement of the revetment can be evaluated.

We concur with the Licensee's selection of the revetment and flood gates as safety-related flood protection structures and acknowledge the l

necessity of their inclusion, in'he inservice inspection program.

However, the Licensee did not,recognize the need to inspect flood protection features associated with a probable maximum flood (PNF) of Deer Creek.

It has been demonstrated in several reviews by both the Licensee (10) and the

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NRC (ll) that a

PHF event (the current NRC evaluation criteria) results in flood water exceeding plant grade.

Subsequent evalua.ions of the occurrence of the highest flood which does not interfere with safe plant shutdown depended'on assumptions of appropriate culvert diameters and streambed cross-section topography.

Since the present plant design does not conform to standards suggested in Regulatory Guide 1.59, "Design 8"sis Floods for Nuclear Reactor Sites" the present runoff characteristics of Deer Creek must be maintained to minimize, as much as

possible, backwater effects resulting from flood runoff.

Specifically, upper basin topography must be protected from erosion and slumping, while downstream areas must be capable of discharging high flows of water without choking at culvert entrances and contricted or wooded areas.

Therefore, the stream runoff channel, known formally as Deer, Creek, should be recognized as a safety-related water control structure whose integrity for discharging flood waters should be maintained.

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~ 5-The following targets for observations shovld be added to the Inservice 4

Inspection Program for the Deer Creek wa'tershed:

clogging of culverts by

debris, slump conditions, soil.creep, and bed load movement.

This inspection should be performed annually and also following severe 'rains 'which cause flooding.

Also, the wooded area downstream of the visitors center m'ust be

.initially cleaned out (deadfalls>>

heavy brush accumulation and other debris that could cause flow blockage) and an inspection and maintenance program established to insure adequate conveyance during flood conditions.

INSPECTION PROGRAM The Licensee has stated (2) that the Ginna inspection program for water control structures does not specifically use the methodology described in Regulatory Guide 1. 127.

Engineering records are not kept for many of the water control structures, but documents are available which define the

-specifications for the flood protection revetment.

The Licensee has not stated that the inspection program is conducted or overseen by qualified engineering personnel.

Hence, the licensee must comnit to using competent; qualified personnel to supervise the inspection and maintenance programs.

A civil engineer with experience in water control structures would be an appro-priate inspector:

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Regulatory Guide 1.127 identifies the need to prepare 'inspection reports following the inspection of safety-related water control structures.

These documents should be maintained on site.for reference.

The Licensee did not mention the existence of inspection reports resulting from the "informal" inspections now under way at the Ginna facility.

Fre uenc of Inspection The routine frequency of inspection identified by the Licensee are adequate by Regulatory Guide 1.127 criteria.

However, additional inspections jcalled special inspections) should follow extreme events which challenge both the UHS supply and flood protection. structures.

For the UHS, this implies that an inspection is necessary following significant buildup of ice or other debris.

For. flood protection structures, this implies that inspection is necessary following a large seiche or unusually heavy rainfall runoff.

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~ w-Conclusions and Recommendations The present inspection program for water control structures at. the R. E.

Ginna Nuclear Power Plant does not conform with the intent of Regulatory Guide 1.127 and requires modification.

Recoamended modifications are as follaws The inspection. progr am now underway at Ginna should be formalized so

'hat standard report forms are submitted by competent and qualified inspectors to be reviewed by qualified engineers.

The licensee should develop a checklist for discharge canal inspections, including their frequency.'.

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The Deer Creek basin should be formally recognized as a water control structure and inspected accordingly on an annual basis and following severe rains which cause flooding.

The Iiiservice Inspection Program for Deer Creek should be supplemented by adding: clogging of culverts by debris, slump conditions, soil creep, and bed load movement; 3(a).

The wooded. area downstream of the Visitors Center should be cleaned out to initially establish adequate water conveyance during floods and a baseline for future inspection and maintenace.

5.

6.

The Licensee should compile a comprehensive file of engineering drawings for safety-related water control structures to establish immediate post-construction conditions.

The routine inspection frequency is acceptable, but special inspections also must be performed after extreme. events such as floods and seiches which may jeopardize the integrity of water control structures.

The formal inspection program to be initiated at the R. E. Ginna Plant should incorporate such special inspections.

The Licensee should develop a formal inspection program for water control structures that will result in the development of a comprehensive file of appropriate inspection reports.

7.

The Licensee's monitoring program to be develope'd for the revetment must be approved by the NRC.

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REFERENCES r

~ C D. Eisenhut (NRC)

Letter to ~ licensees, LS05-81-01-015 January 14, 1981, 20 J. E. Maier (RGLE)

Letter. to D. M. Crutchfield (NRC)

Cctober 12, 1981.

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Regulatory Guide 1.127, "Inspection of Hater-Control Structures Associated with Nuclear Power Plants March 1978 Regulatory Guide 1.27, "Ultimate Heat Sink for Nuclear Power Plants" NRC, January 1976 Regulatory Guide Construction)

NRC, March 1978 1.28, "Quality Assurance Program Requirements (Design a.

6.

.Regulatory Guide Po~er Plants" NRC, March 1979 1.132, "Site Investigations for Foundations of Nuclear Regulatory Guide 1.59, "Design Basis Floods for Nuclear Power Plants NRC, August 1977 8 ~

D M. Crutchf ield (NRC)

Letter to L. D. Hhite, Jr.

(RGt'E)

December 12, 1980 9 ~

Memorandum for G. Lear (Chief Hydrologic and Geotechnical Engineering..

Branch)

'FrcEEE G. Staley (Hydrologic Engineering Section)

Re:

Inspection of Ginna Revetment

. November.17, 1981 10 J.

E. Maier (RGGE)

Letter to D. M. Crutchfield (NRC).

August 18, 1981 D. M..Crutchfield (NRC)

Letter to J.

E, Maier (RGaE)

April 10, 1981 12.

G. Staley (NRC, Hydrologic Engineering Section)

Memorandum to G. Lear (NRCi Chief, Hydrologic and Geotechnical Engineering)

Subject:

-. inspection of Ginna Revetment November 17, 1981 13.

George P. Johnson, Colonel (USCE)

Letter Report, to Project Officer, U.S. Nuclear Regulatory Commission

Subject:

Results, Conclusions and Recommenda'tions on Ginna Nuclear Generating I

Plant Revetments December 10, 1981.