ML20198S963

Submits Info Pertaining to Unit 1 Implementation of Mods Associated w/GL-96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions

ML20198S963
Person / Time
Site:	Hatch
Issue date:	11/03/1997
From:	Le N NRC (Affiliation Not Assigned)
To:	Sumner H SOUTHERN NUCLEAR OPERATING CO.
References
GL-96-06, GL-96-6, TAC-M96819, NUDOCS 9711140179
Download: ML20198S963 (4)

Text

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f y* '4 - UNITED STATES j

j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30666-OtH

\.....[& November 3, 1997 Mr. H. L. - Sumner, Jr.

"'ce President Nuclear Hatch Project _.

Southem Nuclear Operating Company, Inc.

Post Office Box 1295 Birmingham, Alamaba 35201-1295

SUBJECT:

INFORMATION PERTAINING TO EDWIN 1. HATCH NUCLEAR PLANT, UNIT 1 IMPLEMENTATION OF MODIFICATIONS ASSOCIATED WITH GENERIC LETTER 96-06, " ASSURANCE OF EQUIPMENT OPERABILITY AND CONTAINMENT INTEGRITY DURING DESIGN-BASIS ACCIDENT ,

CONDITIONS"(TAC NO. M96819)

Dear Sumner:

The staff issued Generic Letter (GL) 96-06 on September 30,1996. The generic letter requested licensees to determine (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 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 October 20,1997, you submitted your 120-day response to GL 96-06.

The staff 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 cptimize whatever actions are needed and to assure that they do not ultimately result in a detriment to safety. Current issues and ongoing 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 ill 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 resolation of the overpressurization of piping issue, and (4) questions regarding the staff's closure of Generic g::3 Safety issue 150, "Overpressurization of Containment Penetrations." Risk insights and industry ryg initiatives that are being considered or that may be proposed could also Infh'ence the course of CD action that licensees take to resolve the GL 96-06 issues.

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Licensees are responsible for assessing equipment operability, determining actions, and Pri establishing schedules that are appropriate for resolving the specific conditions that have been g3

- identified, in determining the appropriate actions and schedules for resolving GL 96-06 issues, Ni licensees should consider, for example, the continued validity of existing operability E4 determinations, compensatory actions required to maintain operability, the safety signdicance associated with the specific nonconformarices or degraded conditions that have been identified, b Q

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

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. actions (e.g., engineering evaluations, design change packages, material procurement, and equipment modification and installation). Also, analytical solutions employing the permanent use of the acceptance criteria contained in the ASME Code, Section lil, 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 i 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 justification.

It is the staffs cuirent position that licensees can use the ASME Code, Section Ill, Appen' dix F, .

criteria for bierim 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 facilitato resolution of the GL 96-06 issues, the NRC wu participate in a public workshop on this topic later this fall. The workshop proceedings will be summarized by the NRC staf' and made publicly available. The need for additional NRC guidance and generic communication will be considered upon completion of the workshop.

4 If you choose to revise your commitments for resolving the GL 96-06 issues, you should submi' 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 questions, please contact me at (301) 415-1458.

Sincerely, Ngoc B. (Tommy) Le, Project Manager Project Directorate 11-2

- Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket No. 50-321 cc: See next page 4

e e pr-b----pege<im* -' - ss-- ry e, e---es-'c-- i -- .

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Edwin I. Hatch Nuclear Plant cc:

Mr. Emest L. Blake, Jr. Charles A. Patrizia, Esquire Shaw, Pittman, Potts Paul, Hastings, Janofsky & Walker and Trowbridge 10th Floor 2300 N Street, NW. 1299 Pennsylvania Avenue Washington, DC 20037 Washington, DC 20004-9500 Mr. D. M. Crowe Chairman Manager, Licensing Appling County Commissioners Southem Nuclear Operating County Courthouse Company, Inc. Baxley, Georgia 31513 P. O. Box 1295 Birmingham, Alabama 35201-1295 Mr. J. D. Woodard Executive Vice President .

Resident inspector Southem Nuclear Operating Plant Hatch Company, Inc.

11030 Hatch Parkway N. P. O. Box 1795 Baxley, Georgia 31531 Birmingham, Alabama 35201-1295 Regional Administrator, Region ll Mr. P. W. Wells U.S.- Nuclear Regulatory Commission General Manager, Edwin I. Hatch Atlanta Federal Center Nuclear Plant 61 Forsyth Street, SW, Suite 23T85 Southem Nuclear Operating Atlanta, Georgia 30303 Company, Inc.

U.S. Highway 1 North Mr. Charles H. Badger P. O. Box 2010 Office of Planning and Budget Baxley, Georgia 31515 Room 610 270 Washington Street, SW. Mr. R. D. Barker Atlanta, Georgia 30334 Program Manager Fossil & Nuclear Operations Harold Reheis, Director Oglethorpe Power Corporation Department of Natural Resources 2100 East Exchange Piace 205 Butler Street, SE., Suite 1252 P. O. box 1349 Atlanta, Georgia 303M Tucker, Georgia 30085-1349 Steven M. Jackson Senior Engineer - Power Supply Municipal Electric Authority of Georgia 1470 Riveredge Parkway, NW Atlanta, Georgia 303284684 1

2 November 3, 1997 actions (e.g., engineering evaluations, design change packages, material procurement, and equipment modification and installation). Also, analytical solutions employing the permanent use of the acceptance criteria contained in the ASME Code, Section lil, 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 should not be delayed without suitable 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 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 ctaff 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 iesponse 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 questions, please contact me at (301) 415-1458.

Sincerely, ORIGINAL SIGNED BY:

Ngoc B. (Tommy) Le, Project Manager Project Directorate 11-2 Division of Reactor Projects - Illi Office of Nuclear Reactor Regulation Docket No. 50-321 DISTRIBUTION NLc JTatum

1. D6Eet FW. BWetzel LBerry cc: See next page PUBLIC JFair JJohnson,Ril PDil-2 RF OGC PSkinner,Ril BBoger ACRS HBerkow DOCUMENT NAME: G: THATCH \ HAT 19606.LTR OFFICE PDil-2/PM PDil-2/LA k PD k NAME N.LE M L. BERRY k Jg 4]SENOWW DATE b) / 3 j 197 /D / Z A /97 b y / 3 ) /97 COPY YES NO YES MO) YES(NO OFFICIAL RECORD COPY V

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