ML20125B247

Responds to NRC Re Revisions to FSAR to Indicate Considerations Made to Preclude Entry of Spent Fuel Shipping Cask Into Spent Fuel Pool & Measures Taken Assuring Accuracy of Info Provided to NRC

ML20125B247
Person / Time
Site:	McGuire, Mcguire
Issue date:	08/21/1979
From:	Willie Lee DUKE POWER CO.
To:	Thornburg H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20125B242	List: IR 05000369/1978020 IR 05000369/1979020 ML20125B240 ML20125B244 ML20125B247
References
NUDOCS 7910250531
Download: ML20125B247 (2)

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.704s 3 7 3-eg 6J Mr. Barold D. Thornburg, Director Division of Reactor Construction Office of Inspection and Enforcement U. 8. Nuclear Regulatory Commission Washington, D. C. 20555 P.e : McGuire Nuclear Station Units 1 and 2 Docket Nos. 50-369, 50-370

Dear Mr. Thornburg:

Your letter of August 1, 1979, requested a response which addressed the following:

1) Ravisions to the FSAR to cicarly indicate the considerations maue in the plant design to preclude entry of the spent fuel shipping cask into the spent fuel pool and the status of the final design.

") Measures taken to assure the accuracy and completeness of all informa-tion provided to the NRC.

With regard to item (1). it is our 1.ntention to revise the McGuire TSAR to reflect the results of cask drop evaluations for the NTS-4, NLI-1/2 and TN-8 truck casks. The analysis currently in the FSAR for a rail cask will be deleted.

These changes will more accurately reflect the situation as far as near term spent fuel handling at McGuire is concerned in that the only spent fuel ex-pected to be shipped to or from McGuire is that generated at our Oconee Sta-tion and the above are the only casks which we currently regard as potential candidates for this shipment. (Note that the storage of Oconee fuel at McGuire is the subject of a 10CFR Part 70 licensing proceeding and is subject of ongoing hearings before an Atomic Safety and Licensing Board.) 'Ihase casks may also be used for intra-atation transfers of spent fuel at McGuire. Duke does not currently own or have a lease for rail cask. At such tima as a par-ticular rail cask is identified for use at McGuire, appropriate analysas will be performed and handling provisions will be made, as necessary, to assure that no potential adversa cask drop consequences exist. If these analyses identify a need to modify any part of the design, appropriate design changes would be made

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.r. . d l's.P00RiORIGINAL Mr. Harold D. Thornburg, Director August 21, 1979 Page Two M , y

' With regard to item (2), it is considered that an adequate program has existed and continues to exist to assure that accurate information is provided to NRC.

This program includes the following:

e Safety Analysis Reports and Environmental Reports chapters are assigned to responsible individuals to be prepared and reviewed and approved internally by designated individuals.

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e , Correspondence is made to the NRC through the appropriate Vice- l Presidents in Design Engineering and Steam Production.

e Licensing groups coordinate and handle questions, bulletins, event reports with responsible individuals.

e Commitment and design deviation lists are used.

e Procedures exist for reporting under 10CFR50.SS(e).

Rovaver, to reiterate the importance of providing both accurate and complete information. I issued a policy letter on January 23, 1979, in reference to the December 6,1978 transmittal from Mr. Harold R. Denton and Mr. John G.

Davis. My letter distributed the NRC letter to senior personnel and directed that employees working in the nucicar area be reminded of the requirement for providing accurate and complete information to the NRC. New employees are to be well indoctrinated in this policy.

I believe that Duko has dono a good job in providing complete and accurate information to the NRC and we will continue to do so in the future.

Very truly yours,

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Duke Power Company Attn: W. S. Lee, President Docket Nns. 50-3 3 P. D. Box 33189 59-? M Charlotte, North Carulina 28242 Gentlemen:

- This refers to an investigation beginning on April 11 and cowleted cn December 6, 1978, by the NRC Region 11 Officu of activities authorized a W Construction Permit Nos. CPPR-83 and CPPR-64 fev the McGuire facility. 16.:

investigation results were discussed by James P. O'Rei!1y, Rcgion II Direc.cr.

in a meeting with Mr. L. C. Dail and others ef your staff on January 5,19 79.

This also refers to Duke letter dated January 26, 1979, which discusses matters involved in this investigation.

This investigation was conducted to deteratine the facts involved in the analysis of the hypothetical cask drop accident and the response to tiRC ques-tions submitted Report (F5AR). by Duke Power Company in the McGuire Final Safety Analysis dures and representative records and interviews with present and fo employees.

have been reviewed by the NRC Office of Nuclear Reactor Regu included reevaluation of your FSAR submittal.

The investigation confirmed that the Duke response to the NRC in 1975 did rat include one postulated cask drop case that had been analyzed, lhe calcula-tions for that case (Case No. 3) indicated that the cash could f all into ti e fuel pool given certain conservative assumptions regarding energy absorpticn.

We recognize that the supervisor involved was acting within the linitt of his authority and that his rejection of the results of using the conservathe assumptions of Case No. 3 was an exercise of his engineering juccment. Wevar-theless, we believe that completeness and candor would have been cetter ure.J by including a discussion of the rejected case in tha Duke response to fMC avcn though the conclusions may have been unchanged.

The NRC regulatory program is based on the preraise that information proviceJ by licensees is factual, complete, and supported by data, records, calcuir-

• tions and judgment of technically qualified individuals.

tion and inspection processes in the NRC's regulatory program are based enThe rev sampling and auditing techniques designed to rely on the validity of th.st premise.

Inaccurate, incomplete, or omitted information could rssult in decisions which adversely affect the health and safety of the public. It is therefore imperative that licensees exercise the utmost care in supplying OM

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Duke Power Company AUG1 1979 information to the NRC. The necessity for accuracy and completeness must be stressed throughout licensee organizations. This was emphasized to all utility executives in a letter from the Acting Director of IE dated December 6, 1978.

In this case, there is no indication that the omission was a willful or deliberate attempt to deceive the NRC. However, we believe it was not good .

judgment MRC.

to omit all information concerning Case No. 3 in your response to the 3uring the course of our investigation documents were found that had been sitered.

NRC. We did not establish that the documents had been altered to mislead alone.

Also, it appeared that the individual who made the alteration acted In addition, we are disturbed with the implication contained in Duke's letter of J6nuary 26, 1979, to the Region II Director that the NRC staff should have beca sware of Duke's third analysis on the basis of FSAR Figure 9.1.2-1.

Quite apart from our disagreement with such an implication is our concern with the statement that figure 9.1.2-1 is the " precise drawing" for the third analysis.

FSAR Figure 9.1.2-1 (Rev. 6) shows a 6" overlap between the edge of June 11, 1975,and the cask whereas the sketch for the third analysis dated the cash pit the cask pit andonthe page 8 (Duke File No. AB 1000.08) shows no overlap between cask.

It is requested days. that you provide a written response to this letter within 20 Your response should provide revisions to the FSAR to clearly indicate the considerations made in the plant design to preclude entry of the spent fuel thipping cask into the spent fuel pool and the status of the final design.

It should also discuss measures you have taken to assure the accuracy and completeness of all information provided to the NRC. Future inspections will t!6termine the effectiveness of your corrective actions and what enforcement actions, if any, are necessary to ensure future compliance in this area.

Sipedrely, Harold D. Thornbyrg, Director Division of Reactor Construction Inspection Office of Inspection and Enforcement 300R BRE E