ML20198S938

Submits Info Pertaining to Unit 2 Implementation of Mods Associated W/Gl 96-05, Assurance of Equipment Operability & Containment Integrity During DBA Conditions

ML20198S938
Person / Time
Site:	Vogtle
Issue date:	11/03/1997
From:	Larry Wheeler NRC (Affiliation Not Assigned)
To:	Mccoy C SOUTHERN NUCLEAR OPERATING CO.
References
GL-96-06, GL-96-6, TAC-M96882, NUDOCS 9711140172
Download: ML20198S938 (4)

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UNITED STATES y

NUCLEAR R20ULATORY COMMISSION -

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- WASHINGTON, D.c. seess ceM I*g.....

November 3, 1997-Mr. C. K.7 McCoy -

Vice President -.

Southem Nucleir Operating Company, Inc.

- P. O.- Box 1295

. Birmingham, Alabama 35201

SUBJECT:

_ INFORMATION PERTA!NING TO VOGTLE ELECTRIC GENERAMG PLANT, -

UNIT 2 IMPLEMENTATION OF MODIFICATIONS ASSOCIATED WITH -

GENERIC LETTER 96-06, " ASSURANCE OF EQUIPMENT OPERABILIT( AND

- CONTAINMENT INTEGRITY DURING DESIGN-BASIS ACCIDENT CONDITIONS"(TAC NO. M96882)

D' eas IcCoy:

-The staff issued Generic Letter (GL) 96-06 on September 30,1996. The generic letter requested licensees to dete, We (1) if containment air cooler cooling water systems are susceptible to either waterhammer or two-phase flow conditions during postulated accident conditions, and (2) if piping systems that pene'. rate the containment are susceptible to thermal expansion of fluid so that overpressurization of piping could occur. By letter dated January 27, 1997, you submitted your 120-day response to GL 96-06. The staff is currently performing a detailed review of your response.

Implementing corrective actions to resolve the GL 96-06 issues can have a significant impact on outage schedules and resources.- Some licansees have indicated that it would be prudent to take more time to better understand the specific concerns that have been identified in order to i

optimize whatever actions are needed and to assure that they do not ultimately result in a detriment to safety. Current issues and oigoing efforts that could influence a licensee's decision in planning corrective actions include (1) risk implications of installing relief valves to deal with the thermal overpressurization issue, (2) feasibility of using the acceptance criteria contained in Appendix F to Section lil of the American Society cf 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 lasue 150, "Overpressurization of Containment Penetrations."- Risk insights and industry initiatives tnat are being considered or that may be proposed could also' influence the course of action that licensees take to resolve the GL 96-06 issues.

Licensees are responsible for assessing equipment operability, de'.armining actions, and establishing schedules that are appropriate for resolving the specific conditions that have been

. identified, in determining the appropriate actions and schedules for resolving GL 96-06 issues,

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

' determinations, compensatory actions required to maintain operability, the safety significance

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J associated with the specific nonconformances or degraded conditions that have been identified, risk insights, and the time required to complete any generic initiatives and/or plant-specific

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actions (e.g;, engineering evaluations, design change packages, material procurement, and Q D W M8 3 EsN o4as-3M P

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2 f4vember 3, 1997 equipment modification and installation). Also, analytical solutions employing the permanent use of the ecceptance criteria contained in the ASME Code, Section Ill, Appendix F (or other.

acceptance criteria) may present viable attematives to plant modifications and can be used where appropriate, justified, and evaluated in accordance with NRC requirements such as 10 CFR 50.59, as applicablec Licensees may find the revised guidance contained in GL 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of De9raded and Nonconforming Conditions and on Operability," Revision 1, dated October 8,-

1997, helpful in 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 should not be delayed without suitable i

justification.

it is the staffs 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 pennanent actions have been identified and approved by the NRC (as appli,able) 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 resolvirig the GL 96-06 issues, you should submit a revised response to the generic letter. Your revised response should include approp-iate discussion of the considerations discussed above, the current resolution status, and actions remaining to be comple.ed,' and plans being considered for final resolution of the GL 96-06 issues.

if you have any questions, please contact me at (301) 415-1444.

Sincerely, P

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ouis L. Wheeler, Senior Project Manager Project Directorate 11-2 Division of Reactor Projects -l/ll Office of Nuclear Reactor Regulation Docket No. 50-425 cc: See next page y

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Vogtle Electric Generating Plant-R: cc: _.

Mr. J. A. Bailey ;

Harold Rebels, Director C Mar ager, Licensing -

- Department of Natural Resources

- Southem Nuclear Operating 205 Buter Street, SE. Suite 1252 Company, Inc.

Atlanta, Georgia-30334 P. Oi Box 1295 Birmingham, Alabama 35201-1295 :

Attomey General Law Department Mr.'J. B. Beasley.

132 Judicial Building -

General Manager, Vogtle Electric Atlanta, Georgia 30334

- Generating Plant

' Southem Nuclear Operating _

- Mr. R. D. Barker Company, Inc,

- Program Manager V

P. O. Box 1600 Fossil & Nvcicar Operations

!Waynesboro, Georgia -30830 Oglethorpe Power Corporation 2100 East Exchange Place Regional Administrator, Region ll P. O. Box 1349

- U S. Nuclear Regulatory.

Tucker, Georgia ?,0085-1349 Commicsion Atlanta Federal Center Charles A. Patrizia, Esquire 61 Forsyth Street, SW., Suite 23T85 Paul, H,:. stings, Janofsky & Walker

_ Atlanta, Georgia 30303_

10th Floor

- 1299 Pennsylvania Avenue

.. Office of Planning and Budget Washingion, DC 20004 9500 i

. L Room 615B 270 Washington Street, SW.

Arthur H. Domby, Esquire

- Atlanta, Georgia 30334 Troutman Sanders NationsBank Plaza Mr. J. D. Woodard -

600 Peachtree Street, NE.

Executive Vice President Suite 5200 Southem Nuclear Operating Atlanta, Georgia 30308-2216

. Company, Inc.-

P, O. Box 1295 Resident inspector Birmir,gham, Alabama 35201-1295 Vogtle 8805 River Road Steven M.~ Jackson Waynesboro, Georgia 30830 Senior Enginear-Power Supp!y Municipal Electric Authority Office of the County Corr,missioner.

'.of Georgia -

Burke County Commission 1470 Riveredge Parkway, NW.

Waynesboro, Georgia 30830 Atlanta, Georgie.30328 4684 t

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2 Noveraber 3,1997

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equipment modification and installation). Also, analytical solutions employing the permanent suse of the acceptance criteria contained in the ASME Code, Section ll1, Appendix F (or other *

' acceptance criteria) may present viable alternatives to plant modifications and can be used 1

where appropriate, justified, and evaluated in accordance with NRC requirements such as

,j 10 CFR 50.59, as applicable. Licensees may find the revised guidance contained in GL 91 18,

'1nformation 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 should not be delayed without suitable

, = justification.

It is the staff's arrent position that licensees can use the ASME Code, Section Ill, Appendix F, criteria for intenm operability determinations for degraded and nonconforming piping and pipe supports until permanent actions have been identified and 9pproved by the NRC (as applicable) for resclving the GL 96-06 issues. This guidance suppiements 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 submit a revised response to the generic letter. Your revised response should include appropriate discussion of the considerations discussed abovs, the current resdution status, und actions remaining to be completed, and plans being considered for final molution of the GL 96-06 issues.

If you have any questions, please contact me at (301) 415-1444.

i Sincerely, ORIGINAL SIGNED BY:

Louis L Wheeler, Senior Project Manager Project Directorate 11-2 Division of Roactor Projects -I/ll Office of Nuclear Reactor Regulation Docket No. 50-425 DISTRIBUTION

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