ML20198S641

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Discusses Review of 970127 & 0523 120-day Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions, for Facility
ML20198S641
Person / Time
Site: Farley 
Issue date: 11/03/1997
From: Jacob Zimmerman
NRC (Affiliation Not Assigned)
To: Dennis Morey
SOUTHERN NUCLEAR OPERATING CO.
References
GL-96-06, GL-96-6, TAC-M96810, NUDOCS 9711140079
Download: ML20198S641 (4)


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UNITED STATES f

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NUCLEAR REGULATORY _ COMMISSION =

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. November 3i 1997 yg Mr. D.~ N. Morey Vice President - Farley Project Southem Nuclear Operating Company, Inc.

P.O. Box 12951 Birmingham, Alabama 35201 -

SUBJECT:

INFORMATION PERTAINING TO JOSEPH M. FARLEY NUCLEAR PLANT, UNIT 2, IMPLEMENTATION OF MODIFICATIONS ASSOCIATED WITH

- GENERIC LETTER 96-06, " ASSURANCE OF EQUIPMENT OPERABILITY AND CONTAINMENT INTEGRITY DURING DESIGN-BASIS ACCIDENT CONDITIONS'( AC NO. M96610)

Dear Mr,

Morey:

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-The staff issued Generic Letter (GL) 96-06 on September 30,1996. The generic letter requested licensees to determine (1) if containment air coo ler cooling water systems are susceptible to either waterhammer or two-phase flow conditions during postulated accident conditions, and (2) it piping systems that penetrate the containment are susceptible to thermal expansion of fluid so that overpressurization of piping could occur. By letter dated January 27, 1997, as, supplemented May 23,1997, you submitted your 120-day response to GL 96-06.

The.taff is currently performing a detailed review of your responses.

Implementing corrective actions to resolve the GL 96-06 issues can have a significant impact on outage schedules and resources. Some licensees have indicated that it would be prudent to take more time to better understand the specific concems that have been identified in order to optimize whatever actions are needed and to assure that they do not ultimately result in a detriment to safety. Current issues and orgoing efforts that could influence a licensee's

' decision in planning corrective actions include (1) risk implications of installing relief valves to deal with the thermai overoressurization issue, (2) feasibility of using the acceptance criteria -

corstained in Appendix F to Section lll of the American Society of Mechanical Engineers Boiler

. and Pressure Vessel Code (ASME Code) for the permanent resolution of the GL 96-06 issues, (3) ongoing tests by the Electric Power Research Institute to support a generic resolution of the overpressurization of piping issue, and (4) questions regarding the staff's closure of Generic

_ Safety issue 150, "Overpressurization of Containment Penetrations." Risk insights and industry

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y initiatives that are being considered or that may be proposed could also influence the course of gg action that licensees take to resolve tne GL 96-06 issues.

J [,. Licerisees am responsible for assessing eqttipment operability, determF 5q actions, and a

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establishing schedules that are appropriats for resolving the specific conuions that have been g

2-p identified. Ir, determining the appropriate actions and schedules for resolving GL 96-06 issues, y

licensees should consider, for example, the continued validity of existing operability

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' determinations, compensatory actions required to maintain operability, the safety significance gi associated with the specific nonconformances or degraded conditions that have been identified,- k!

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risk insights, and the time required to complete any generic initiatives and/or plant-specific

. actions (e.g., engineering evaluations, design change packages, material procurement, and f]

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equipment modification and installation). Also, analytical solutions ' employing the permanent

- use of the acceptante criteria contained in the ASME Code, Section lil, Appendix F (or other

- acceptance criteda) may present viable attematives to plant modifications and can be used where appropriate, justified, and evaluatsd in accordance with NRC requ!rements such as -

10 CFR 50.59, as appliceble. Licensees may find the revised guidance contained in GL 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability," Revision 1, dated October 8,-

I 1997, helpfulin determining appropriate actions and schedules. Although adjustments in r

l schedules may be warranted on the basis of theta (and other) considerations, specific actions that have been defined and are clearly r'eeded should not be delayed without suitable justification.

't it is the staffs current position that licensees can use the ASME Code, Section Ill, Appendix F, criteria for interim operability determinations for degraded and nonconforming piping and pipe _

supports until permanent actions have been identified and approved by the NRC (as applicable) for resolving the GL 96-06 issues. This guidance supplements the guidance provided by GL 91-18 for resolution of the GL 96-06 !ssues.

In order to further facilitate resolution of the GL 96-06 issues, the NRC will participate in a public workshop on this topic later this fall. The workshop proceedings will be summarized by the NRC staff and made publicly available. The need for additional NRC guidance and generic communication will be considered upon completion of the workshop.

If you choose to revise your commitments for resolving the GL 96-06 issues, you should submit a revised response to the generic letter. Your revised response should include appropriate discussion of the considerations discussed above, the current resolution status, and actions remaining to be completed, and plans being considered for final resolution of the GL 96-06 issues.

If you have any queations, please contact me at (301) 415-2426.

Sincerely, 4

Jacob 1. Zi erman, Project Manager Project Directorate ll-2 Division of Reactor Projects - 1/II

- Office of Nuclear Reactor Regulation Docket No. 50-364 cc: See next page

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  • ~ Joseph M. Farley Nucle:r Plint.

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- Mr. R. D. Hill,-Jr.

GeneralManager. _

~ Southem Nuclear Operating Company Post Office Box 470-. ~

Ashford, Alabama 36312 Mr. Mark Ajiuni. Lice'nsing Manager Southem Nuclear Operating Company

, Post Offico Box 1295 '

Birmingham, Alabama 35201-1295 t

Mr. M. Stanford Blanton Balch and Bingham Law Firm Post Office Box 306 -

1710 Sixth Avenue North Birmingharn, Alabama 35201 Mr. J. D. Woodard Executive Vice President Southern Nuclear Operating Company Post Office Box 1295 Birmingham, Alabama 35201 State Health Officer Alabama Department of Public Health 434 Monree Street Montgor e,y, Alabama 36130-1701 Chairman Houston County Commission Post Office Box 6406 Dothan, Alabama 36302

- Regional Administrator, Region 11 U.S. Nuclear Regulatory Commission Atlanta Federal Center l 61 Forsyth Street, S.W., Suite' 23T85 Atlanta, Georgia 30303 Resident inspector U.S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia, Alabama 36319 i

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November 3, 1997 equipment modification and installation). Also, analytical solutions employing the permanent use of the acceptance criteria contained in the ASME Code, Section Ill, Appendix F (or other acceptance criteria) may present viable alternatives to plant modifications and can be used where appropriate, justified, and evaluated in accordance with NRC requirements such as 10 CFR 50.59, as applicable. Licensees may find the revised guidance contained in GL 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability," Revision 1, dated October 8, 1997, helpfulin determining appropriate actions and schedules. Although adjustments in schedules may be warranted on the basis of these (and other) considerations, specific actions that have been defined and are clearly needed shou;d not be delayed without suitable justification.

It is the staff's current position that licensees can use the ASME Code, Section lil, Appendix F, criteria for interim operability determinations for degraded and nonconforming piping and pipe supports until permanent actions have been identified and approved by the NRC (as applicable) for resolving the GL 96-06 issues. This guidance supplements the guidance provided by GL 91-18 for resolution of the GL 96-06 issues.

In order to further facilitate resolution of the GL 96-06 issues, the NRC will participate in a public workshop on this topic later this fall. The workshop proceedings will be summarized by the NRC staff and made publicly available. The need for additional NRC guidance and generic communication will be considered upon completion of the workshop.

If you choose to revise your commitments for resolving the GL 96-06 issues, you should sLbrrit a revised response to the generic letter. Your revised response should include appropriate discussion of the considerations discussed above, the cuirent resolution status, and actions remaining to be completed, and plans being considered for final resolution of the GL 96-06 issues.

If you have any questions, please contact me at (301) 415-2426.

I l' SIGNED BY W. GLEAVES FOR:

Jacob 1. Zimmerman, Project Manager Project Directorate 112 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket No. 50-364 DISTRIBUTION:

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