ML20027B967

Requests Briefing Re Standby Shutdown Facility Design Requirement Changes,Focusing on Integration of NRC Backfit Efforts.Briefing Requested at 820908 CRGR Meeting

ML20027B967
Person / Time
Issue date:	08/19/1982
From:	Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20027B966	List: ML20027B965 ML20027B967
References
NUDOCS 8210120053
Download: ML20027B967 (2)

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Art UNITED STATES

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NUCLEAR REGULATORY COMMISSION f

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AUS 1. 9 1392 MEMORANDUM FOR: Harold R. Denton, Director, NRR FROM:

Victor Stello, Jr., Deputy Executive Director Regional Operations and Generic Requirements

SUBJECT:

REQUEST FOR CRGR BRIEFING - STANDBY SHUTDOWN FACILITIES REF:

1.

7/17/82 Ltr. to William Parker, Jr., Duke Power Co.

fm. J. Stolz, Chief, ORB #4 2.

USI A-45, Task Action Plan 3.

Study of Impact & Value of Alternate Decay Heat Removal Concepts for LWRS (final draft), NUREG/CR-2883 (SAND 82-1796)

Recent NRR staff correspondence with Duke Power Co. (Ref.1) indicates that the staff is changing the design requirements for the Oconee Standby Shutdown Facility (SSF), which was suggested as a backfit alternative to meet the fire protection requirements in Appendix R.. In Ref.1, the staff appears to have interpreted Appendix R in a way that means that the

- SSF already~ backfit in the Oconee Plant should now be further upgraded to cope with excessive cooldown events from secondary system depressuriza-tion and with events involving excess loss of coolant from the primary system. Ref.'l also poses additional requirements for SSF instrumentation and requirements for coping with other potential safety challenges such as sabotage, earthquakes and floods.

I understand that the SSF design for Oconee was approved, at least in principle, by NRC in 1978.

There is little doubt that add-on SSF features of the right kind could result in a safety benefit by covering a spectrum of safety threats that are now being treated by the staff in a disjointed fashion. However, the costs of such add-on SSF features can be very large if the staff does not settle on design and performance criteria prior to their design or installation. References 2 and 3 are closely related agency

-efforts that could be useful to help establish such performance criteria.

8210120053 820923 PDRREV0PIm0CRg e

,_,f, AUG1W Id Harold R. Denton I would like to request that your staff brief the CRGR on this subject, with the focus on NRR plans for integrating these staff efforts and ensuring that any SSF backfit requirements are made in light of clearly defined performance criteria. Please let me know who will make the briefing and if it can be done at the September 8,1982 CRGR meeting.

or St' llo, Jr.

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Deputy Executive Director Regional Operations and Generic Requirements cc:

W. J. Dircks, ED0 CRGR Members

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NUCLEAR REGULATORY _ COMMISSION.,

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j-wAsamonw. o. c.nossa July 17,1982 i

Dockets d 269, 50 M and~'56287 1

4 Mr. William O. Parker, Jr.

h Vice President - Steam Production Duke Power Company h

P. O. Box 33189 t

422 South Church Street Charlotte, North Carolina 28242 j

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Dear Mr. Parker:

We have reviewed your February 1,1978,-June 19,1978 and March 28, 1980 submittals regarding the Oconee Standby Shutdown Facility (SSF) to determine its cceptability to resolve the NRC concerns related to l

fire protection (Appendix R Paragraphs III.G and III.L) and turbine i

butiding flooding. The criteria we are using in our review are:

1.

The SSF should be designed to meet seismic Category I requirements since the Auxiliary Service Water System in the SSF is relied upon to backup the emergency feedwater system in the event of a design basis earthquake.

-f 2.

The SSF need not meet single failure or other design basis accident criteria, except where required for other reasons, e.g. because of interface with or impact on existing safety systems, or because of i

adverse valve actions due to fire damage.

I 3.

Additional requirements 'for the SSF flow from the proceeding two criteria, e.g. the facility components should be environmentally qualified for conditions to which they may be exposed.

As a result of our review, we have a number of unresolved concerns; these are contained in the enclosed Request for Additional Infomation.

We would appreciate your response to this request within 60 days of its receipt.

i Since this infomation request relates solely to the 'Oconee Nuclear Station, i

fewer than ten respondents are affected; therefore,.0MB clearance is not required under P.L.96-511.

Sincerely, hw u,

~ JohbF. S'tolz, Chief 1

09,g A/,2 u k Operating Recctors Branch #4 Division of Licensing OWP@Y

Enclosure:

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Request for Additional Infomation

.cc w/ enclosure: See next page l

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Duke, Power. Company y

ccw/ enclosure (s):

Mr. William L. Porter Duke Power Company P. O. Box 33189 422 South Church Street Office of Intergovernmental Relations

'{

Charlotte North Carolina 28242 116 West Jones Street Raleigh,, North Carolina 27603 Oconee County Library 501 West Southbroad Street Walhalla, South Carolina 29691-i Honorable James M. Phinney 1

Coun"y Supervisor of Oconee County i

Walha!1a South Carolina 29621 q

Mr. Jamei P. O'Reilly, Regional Administrator i

i U. S. Nucitar Regulatory Comission, Region II i

101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 l

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I Regional Radiation Representative EPA Region IV 345 Courtland Street, N.E.

Atlanta, Georgia.30308 l

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William T. Orders i

Senior Resident Inspector i

U.S. Nuclear Regulatory Comission

'j Route 2 Box 610 5

l Seneca, South Carolina 29678 Mr. Robert 8. Borsum f

Babcock & Wilcox i

l Nuclear Power Generation Division f

Suite 220, 7910 Woodmont Avenue t

l Bethesda, Maryland 20814 3

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Manager, LIS 3

1 NUS Corporation i

2536 Countryside Boulevard Clearwater, Florida 33515 J. Michael McGarry, III Esq.

l DeBevoise & Liberman s

1200 17th Street, N.W.

Washington, D. C.

20036

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1 ENCLOSURE REQUEST FOR ADDITIONAL INFORMTION OCONEE NUCLEAR STATION STANDBY SHUTDOWN FACILITY A

1.

In the Staff's evaluation of the SSF', which was fontarded to the licensee December 29, 1978, the staff found the design criteria acceptable, subject to the following conditions:

"(a) DPC state'd in their June 19,1978'submittill.that they would selectively apply portions of NUREG-75/087 to their design.

We have requested that the licensee identi.fy and justify those portions of the design,not meeting NUREG-75/087.

(b) Any deviations from the above listed criteria, and/or the criteria specified in the Oconee PSAR, and/or the criteria described in NUREG-75/087, shall be identified by the licen;ee and submitted for NRC review in the final design submittal."

In the licensee's March 28, 1980 submittal, such a discussion was not included. The licensee is requested to provide a response.

,2.

The licensee has indicated that AC and DC power supply s'ystems including the standby, power system for the Standby Shutdown Facility will meet.or exceed the requirements of' Class 1E power systems and '

equipment except for the single failure criteri'on. Provide a s

description of how the power systems for SSF satisfy the criteria for Class 1E equipment.

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Please describe the adequacy (in capacity) of the 26 gpm SSF RC makeup pump for primary RCS inventory loss control (e.g., leakage, shrinkage) when utilizing the condenser for cooldown during a fire concurrent with loss of offsite power. scenario.

4[ Describe the means by which the spurious operation of the following valves is prevented to assure primary boundary integrity.(fire scenario):

(a) RHR isolation valves (b) letdown valve (c) excess letdown (d) head vent valve (e) sampling line valves If manual isolation of any of the above valves is required, the licensee should demonstrate that the SSF makeup pump can quickly return reactor coolant level in the pressurizer to the normal shutdown range after delayed isolation. A delay time of 30 minutes should be used to evaluate leakage

'.from these unisolated paths in accordance with draft ANSI standard ANS 58.8, ANSI N660 Revision 2 March 1981 which specifies an operator action time of 30 minutes outside the control room.

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The licensee is also requested to address the spurious operations of valves or components which may affect the safe shutdown capability.

5'.

In order to make the SSF fully functional following a fire, and flooding:

(a) Will cabling of an affected train have to be physically disconnected in order to utilize the SSF train (similar to McGuire)

.(b) Will breakers have to be physically realigned in order to Qtilize the SSF train, make the SSF operational similar to McGuire or to ensure proper system configuration (e.g.(, valve positioning),to

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assure safe hot shutdown conditions.,If so, state.the locations and access of such switchgear rooms.

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6 4f cables for all atmospheric dump valves are located in the same fire area,,it is conceivable, that hot shorts could cause all these m _

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valves to fail open. The licensee should discuss the worst; case effect of a' fire on' the atmospheric dump valves, and demonstrate that the SSF can maintain safe hot standby conditions in the event of such ai postulated damage.

7.

By letter dated January 25, 1982, the licensee provided responses regarding

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the absence of source range flux and steam generator pre.ssure indication at the SSF with respect to Appendix R to 10 CFR 50-Safe Shutdown in the Event,

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of Fire.

It is the Staff's interpretation of Section III.L.2 of Appendix R that source range flux and steam generator pressure are control parameters /

j process variables which require " direct readings"- in order to assure the achievement of the performance goals for safe shutdown. Thus, the licensee

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is requested to provide a commitment, to provide direct readings for source j

range flux and steam generator pressure at the SSF.or an alternate shutdown i

panel. electrically isolated from t,h,e control room.

8.

State the elevation of the grade level entrance to the SSF.

If this ele-vation is below the maximum lake levels, provide a discussion of the means by which the equipment within the SSF is protected from the effects of flooding caused by an unisolable break of the non-seismic CCW system / piping located in the Turbine Building.

The discussion should also state the maximum expected water level within the site boundary should such an event occur.

9 With regard to the licensee's response of June 19, 1978 to the Staff's May.18, 1978 request for additional information; are the responses to

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Questions 4 and 5 regarding design criteria of equipment and systems in the SSF intended to also address the requirements at the system interface

_ (i.e., interi.cing between SSF equipment and "In Plant" equipment).

• 9 10.. With respect to the licensee's response.(Reference 2) to Question 1 of Reference i

l concerning the design of Reactor Coolant Make-up. System and Auxiliary Service Water System, the following areas require clarification, The Auxiliary Service W ter. Piping which penetrates.the containment for a.

each unit is incorrectly clusified piping Class F as shown.in Figure 4-1 of Reference 3.

These lines should be classified piping Class B as addressed in Reference 2.

Correct the appropriate figure and confirm

~ that the system is designed in accordance with the' appropriate classification.

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11.

With respect to the licensee's response (Reference 4 ) to Question '2 of Reference 1 concerning the conf ~ormance with the NRC Standard Review Plans, the following areas require additional information to demonstrate that the

.i licensee's methodologies comply with Standard Review Plans (SRP).

I The licensee!s response to SRP Sections 3.7.3 II.2 through II.12 states a.

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. that all requirements are satisfied. Expand the response to include a discussion describing how the licensee's methodologies comply with the SRP.

b.

The licensee's response to SRP Section 3.9.2 II.1 states that procedures are being established to verify thermal motion and vibration.for compliance within acceptance criteria.

Expand the response to include a description of the acceptance criteria which will be used.

l The licensee's response to SRP Section 3.9.3 II.3 states that all require-c.

ments are satisfied.

Expand the response to include a discussion describ-ing how the licensee's methodologies comply with the SRP.

The response "One RC Makeup Pump will be seismic and operability 12.

tested on a shaker table" lacks specificity regarding seismic qualification of pumps. What are the methods; procedures such as input, load combinations, codes and standards; and criteria to be used?

Justify the selection of the methods, procedures, and criteria used.

13.

What are the specific tests that constitute performance tests for pumps?

14a.

List all the mechanical and electrical equipment located in the SSF that is needed to safely shutdown the plant from the SSF.

14b. Discuss in detail tha plan to seismically qualify mechanical and electrical equipment located in the SSF and those that tie into existing systems. This should include methods, procedures, load combinations, codes, standards and criteria to be used.

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Describe the type of displays provided for measured parameters used for the SSF. Are any parameters recorded, such as primary system temper'ature from which trending information may be i

obtained to confirm natural circulation?

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16. Provide a list of the instrument tag item numbers for those instru-ments listed in Sections 3.2.3 and 4.2.3 of the FDR to permit their i

identification in the figures and P&I drawings requested in A 1 and 2 above. Provide the range of each measured parameter.

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17.

Describe the means by which steam generator pressure is controlled i

for shutdown from the SSF.

If the steam generator safety valves are the sole means of pressure control, provide the basis that q

- valves are capable of operation for three and one-half days at the required duty cycle. Are other means of controlling steam gen-erator anticipated and available to assure shutdown without damage control measures?

18. Describe any features provided for peiiodic testing to assure that the

'SSF system would be available if required. What measures would be taken to assure that inst'rumentation and contmls are operable and what e

frequency would instruments be calibrated?

f 19.

Describe those features of the design that assure that single failures within SSF conponents or that design basis events do not result in.

consequential failures of the SSF that would lead to conditions which exceed tfjat for which safety systems have been designed.

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Design Details Requested Full size drawing for the following figures included 1.

in the final design report (FDR)

(Duke letter of March 28,1980)

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Figure 3-1 b.

Figure'4-1 i

c. Figure 5-1 ~ through 5-4

d. Figure 6-1 1

2.

P&I Drawing for instrumentation identified in Sections 3.2.3 and 4.2.3 of which are not shown on drawings noted in 1 above.

3.

Electrical Schematics for following:

Make up pump and valves listed in Section 3.2.2.3 of FDR.

a.

b.

Pressurizer heater controls used in SSF design; Auxiliary service wa'ter pump and valves listed in Section 4.2.2.2 c.

• 1 of FDR.

d.

HVAC and diesel engine service water pumps.

e.

Sump pumps.

f.

Ventilation and Air Conditioning Systems.

4.

Layout drawing of SSF control panel.

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References:

1.

Letter.from R. W. Reid.to W. 0. Parker,' " Request for. Additional

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Information.for DPC Standby Shutdown at the Oconee Nuclear Station", dated October 27, 1980 2.

Letter from W. O. Parker to H. R. Denton, " Response to NRC Questions Concerning Oconee Standby Shutdown Facility", dated February 16, 1981 3.

Oconee Nuclear Station, Information in Support of S Shutdown Facility", dated March 28, 1980 4.

Letter from W. O. Parker to H. R. Denton, " Response to NRC March 31, 1981 Questions Concerning Oconee Standby Shutdown Facility m...,

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