ML20198S590
| ML20198S590 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 01/06/1999 |
| From: | Pulsifer R NRC (Affiliation Not Assigned) |
| To: | Kingsley O COMMONWEALTH EDISON CO. |
| References | |
| TAC-MA3447, TAC-MA3448, NUDOCS 9901110367 | |
| Download: ML20198S590 (7) | |
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' January 6, 1999 Mr. Oliver D. Kingsley, President Nuclear Generation Group Commonwealth Edison Company Executive Towers West lli 1400 Opus Place, Suite 500 Downers Grove,IL 60515
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - QUAD CITIES, UNITS 1 AND 2 (TAC NOS. MA3447 AND MA3448)
Dear Mr. Kingsley:
In'a letter dated November 9,1998, Commonwealth Edison Company (Comed) submitted a res,wnse to the staffs request for additional information (RAI), dated November 3, 1998, regarding Comed's August 31,1998, amendment application. The staff has reviewed this response and determined that Comed has not fully responded to the staffs concerns on the structural integrity portion of the main steam isolation valve (MSIV) leakage treatment issue.
The staffs second request for additional information is enclosed. These questions were discussed with members of your staff on December 21,1998. It was agreed that the responses would be provided within 60 days of the date of this letter.
Sincerely, h
Original signed by:
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Office of Nuclear Reactor Regulation Docket Nos. 50-254, 50-265
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l January 6, 1999 I
Mr. Oliver D. Kingsley, President Nuclear Generation Group Commonwealth Edison Company l
Executive Towers West til 1400 Opus Place, Suite 500 Downers Grove, IL 60515
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - QUAD CITIES, UNITS 1 AND 2 (TAC NOS. MA3447 AND MA3448)
Dear Mr. Kingsley:
In a letter dated November 9,1998, Commonwealth Edison Company (Comed) submitted a response to the staff's request for additional information (RAI), dated November 3, 1998, regarding Comed's August 31,1998, amendment application. The staff has reviewed this response and determined that Comed has not fully responded to the staff's concems on the structural integrity portion of the main steam isolation valve (MSIV) leakage treatment issue.
The staff's second request for additionalinformation is enclosed. These questions were discussed with members of your staff on December 21,1998. It was agreed that the responses would be provided within 60 days of the date of this letter.
Sincerely, Original signed by:
l Robert M. Pulsifer, Project Manager Project Directorate lll-2 Division of Reactor Projects -Ill/IV Office of Nuclear Reactor Regulation i
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Docket Nos. 50-254,50-265 i
Enclosure:
RAI cc w/ encl: See next page Distribution:
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S. Richards C. Moore L. Burkhart R. Pulsifer OGC,015B18 ACRS, T2E26 M. Ring, Rlli DOCUMENT NAME: G:\\PD#-2\\RAlA3447.WPD Ta receive a copy of this document, Indk min the box: "C" = Copy without enclosures *E" = Copy with enclosures 'N" = No copy l
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January 6, 1999-Mr. Oliver D. Kingsley, President Nuclear Generation Group Commonwealth Edison Company Executive Towers West 111 1400 Opus Place, Suite 500 Downers Grove,IL 60515
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - QUAD CITIES, UNITS 1 AND 2 (TAC NOS. MA3447 AND MA3448)
Dear Mr. Kingsley:
In a letter dated November 9,1998, Commonwealth Edison Company (Comed) rubmitted a response to the staff's request for additional information (RAI), dated November 3, 1998, regarding Comed's August 31,1998, amendment application. The staff has reviewed this response and determined that Comed has not fully responded to the staff's concems on the structural integrity portion of the main steam isolation valve (MSIV) leakage treatment issue.
The staff's second request for additional information is enclosed. These questions were discussed with members of your staff on December 21,1998. It was agreed that the responses would be provided within 60 days of the date of this letter.
Sincerely, Robert M. Pulsifer, Project Manager Project Directorate 111-2 Division of Reactor Projects - lilllV Office of Nuclear Reactor Regulation Docket Nos. 50-254, 50-205
Enclosure:
RAI cc w/ encl: See next page
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,'i' O. Kingsley -
Quad Cities Nuclear Power Station.
Commonwealth Edison Company Units 1 and 2
- cc:
Commonwealth Edison Company -
Vice President-Law and 3
Quad Cities Station Manager Regulatory Affairs
' 22710 206th Avenue North MidAmerican Energy Company
' Cordova, Illinois 61242-9740 One River Center Place -
106 E. Second Street i
U.S. Nuclear Regulatory Commission P.O. Box 4350
~ Quad Cities Resident inspectors Office Davenport, Iowa 52808
- 22712 206th Avenue N.
Cordova, Illinois - 61242 Mr. Ds.vid Helwig SeniorVice President i
Chairman Commonwealth Edison Company Rock Island County Board Executive Towers West lli of Supervisors 1400 Opus Place, Suite 900 1504 3rd Avenue Downers Grove, Illinois 60515 1
Rock Island County Office Bldg.
Rock Island, Illinois 61201 Mr. Gene H. Stanley PWR Vice President
- Illinois Department of Nuclear Safety Commonwealth Edison Company Office of Nuclear Facility Gafety' Executive Towers West lli i
. 1035 Outer Park Drive 1400 Opus Place, Suite 900 Springfie!d, Illinois 62704 Downers Grove, Illinois 60515
)
Regional Administrator Mr. Christopher Crane U.S. NRC, Region lli
- BWR Vice President
- 801 Warrenville Road Commonwealth Edison Company Lisle, Illinois 60532-4351 Executive Towers West lll 1400 Opus Place, Suite 900
' William D. Leach-Downers Grove, Illinois 60515 Manager-Nuclear MidAmerican Energy Company Commonwealth Edison Company
- 907 Walnut Street Site Vice President - Quad Cities P.O. Box 657
' 22710 206th Avenue North Des Moines, Iowa 50303 Cordova, Illinois 61242-9740 Mr. R. M. Krich Commonwealth Edison Company Vice President - Regulatory Services Reg. Affairs Manager-Quad Cities Commonwealth Edison Company 22710 206th Avenue N.
Executive Towers West lli Cordova, Illinois 61242-9740 1400 Opus Place, Suite 500 Downers Grove, Illinois 60515 Ms. Pamela B. Stroebel Senior Vice President and General Counsel Document Control Desk-Licensing Commonwealth Edison Company Commonwealth Edison Company P.O. Box 767 1400 Opus Place, Suite 400 Chicago, Illinois 60690-0767 Downers Grove, Illinois 60515 l
1
)i SECOND REQUEST FOR ADDITIONAL INFORMATION REGARDING QUAD CITIES. UNITS 1 AND 2 4
APPLICATION FOR AMENDMENT TO APPENDlX A. TECHNICAL SPECIFICATIONS. SECTION 3/4.7.D.
PRIMARY CONTAINMENT ISOLATION VALVES I
References:
(1) Letter from J. P. Dimmette, Jr., to Document Control Desk (NRC), " Response to NRC Requests for Additional Information for Technical Specification Change Request," dated November 9,1998.
(2)
Letter from J. P. Dimmette, Jr., to Document Control Desk, " Application for i
Amendment to Appendix A, Technical Specifications, Section 3/4.7.D, Primary Containment Isolation Valves," dated August 31,1998.
freneral Comments j
1
. In Reference 1, a peneral reference was made to the Boiling Water Reactor Owners' Group's l
(BWROG) approach for qualifying the attemate leakage treatment (ALT) system piping and condenser using earthquake experience data without providing appropriate plant-specific information. Since a complete description of the BWROG approach, including a
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comprehensive program scope, is not provided in either Reference 1 or Reference 2, its intended use for the main steam isolation valve (MSIV) leakage treatment issue lacks sufficient
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basis for staff use.
I The staff has determined that, subject to conditions and limitations such as those identified in j
its past review of individual licensee submittals, the proposed BWROG approach contained in i
j the General Electric (GE) report, NEDC-31858P, Revision 2, can be utilized for the resolution of the Boiling Water Reactor (BWR) MSIV leakage issue. Comed is responsible for providing
,f sufficient plant-specific information to substantiate the validity of the approach if it is to be used.
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Specifically, Comed needs to address the following:
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1.
The estimation of seismic ground motions used for database plants; l
2.
the seismic verification wa;kdowns and assessments of credible failure modes for ALT system piping, including those due to differential motions-1 l
3.
the summary of existing seismic evaluations on portions of ALT pathway, including materials, design codes, and methodologies used; i
4.
the plan *-specific verification for the adequacy of ALT path piping and condenser, to I
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ensure th.it they fall within the bounds of design characteristics found in the earthquake experience database (e.g., uniqueness of piping configurations, pipe span between L
supports, diameter-to-thickness ratios t 3r each pipe size, condenser dimensions, and i
i anchorage configurations, etc.),
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the interaction concems of small diameter piping and instrumentation from falling objects, or objects in proximity; and 6.
the plant-specific support and anchorage evaluations for piping and condenser under a safe shutdown earthquake (SSE).
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ENCLOSURE I
2 It should be emphasized that, at the present time, there is no standard endorsed by the NRC that provides guidance for determining what constitutes an acceptable number of earthquake ~
recordings and their magnitudes, to be referenced for particular applications of the BWROG methodology. Neither does a standard exist to establish the criterion for determining the required number of piping and equipment items that should be referenced in the earthquake experience database when applying the methodology. Therefore, Comed is responsible for ensuring the sufficiency of the experience data submitted for staff review.
Soecific Comments 1.
The response in Reference 1 to item No. 6 of the staff's RAI is not acceptable to the staff.
If the seismic qualification of the ALT path piping is based on the BWROG approach, the concems stated in the above general comments should be addressed. If the seismic qualification is to be based on an analytical evaluation, provide a comprehensive summary for the seismic analysis of main steam and drain line piping, as well as other pertinent ALT 1
path lines. The information provided should include the methodology and design code used, the resulting piping stresses and supports, and the corresponding safety margins available.
When the earthquake experience database methodology is used to verify the seismic f
adequacy for the Quad Cities condenser structural members, the design parameters for the Quad Cities condenser should be compared to pertinent data in the database in order to determine the applicability of the generic condenser database to the Quad Cities condenser. It is insufficient to just compare the design parameters of the Quad Cities condenser to those of the LaSalle condenser. Besides, a casual reference to the BWROG report regarding the general structural integrity of condensers, without detailed plant-specific verification of design parameters, is also not sufficient for the staff to reach a conclusion regarding the seismic adequacy of the Quad Cities condenser.
2.
In regard to the potential seismic 11/1 situations, the response to item No. 7 of the staff's RAI concerning the seismic adequacy of the Quad Cities turbine building is insufficient.
Although turbine buildinge are generally classified as non-seismic, the staff has required that existing non-safety design programs, such as seismic design to the Uniform Building Code, or wind design bases for the turbine building, be reviewed to ensure position retention integrity of the structures and the components housed therein, under an SSE loading. Provide such plant-specific information to verify that the scismic adequacy of the turbine building has oeen properly evaluated.
it should be emphasized that a seismic evaluation for the turbine building performed under an IPEEE program is not considered applicable to the MSIV leakage issue. Also, a casual reference to the performance of this type of industrial structure contained in the earthquake experience databat,e, without a plant-specific evaluation, should not be used as a basis for concluding the seismic adequacy of the building.
3.
The response to item No. 8 of the staff's RAI did not provide a clear description of the credible ALT pathway. Provide a comprehensive, legible drawing of the MSIV leakage treatment path, including valves that ensure flow passage and valves that serve as
G 3-l boundary valves. Identify on the drawing the primary ALT pathway, as well as an attemate ALT pathway, if applicable, which performs the MSIV leakage treatment function.
.l 4.
The analytical procedures described in the EPRI-NP-6041 report, typically referred to as the conservative deterministic failure margin (CDFM), seismic margin assessment (SMA),
or high-confidence-low probability-failure (HCLPF) analysis methods, have not been formally reviewed and approved by the NRC for the deterministic operability evaluation for i
safety-related systems, components and the associated supports. Their conservatism and, consequently, the potentialimpact to the pubi;c health and safety are not certain at this j
time. The NRC, therefore, does not endorse the use of the above analytical procedures and the EPRI report, for the deterministic seismic analysis of safety-related systems, l
components and their associated supports. For this reason, confirm that all the analytical evaluations re'ated to the MSIV leakage issue have been performed using the plant licensing basis methodology, or approaches which are acceptable to the staff.
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