ML20199C730

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Provides Encl Documents to NRC Pdr.Accession Number Requested to Be Provided.Appropriate Nudocs Entries Requested to Be Modified to Reflect Fact That Documents Re GL 96-06,supplement 1
ML20199C730
Person / Time
Issue date: 11/18/1997
From: Shapaker J
NRC (Affiliation Not Assigned)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-96-06, GL-96-6, TAC-M99618, NUDOCS 9711200109
Download: ML20199C730 (1)


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g November 18. 1997 MEMORANDUM 10: Document Control Desk Information and Records Management Branch Information Management Division Office of the Chief Information Officer FROM: James W. Shapaker id) 4 l#

Events Assessment and.-Generic. Communications Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation

SUBJECT:

DOCUMENTS ASSOCIATED WITH NRC GENERIC LETTER 96 06.

Supplement 1. Assurance of Equipment Operability and Containment Integrity During Design Basis Accident Conditions (TAC No. M99618)

The Plant Systems Branch (SPLB) in the Divisison of Systems Safety and Analysis (OSSA) prepared the subject generic letter, which was issued on November 13. 1997, and given accession number 9711050091. There is material related to the subject generic letter that should be placed in the NRC Public Document Room and made available to the public. Therefore, by copy of this memorandum. I am providing the following documents to the NRC Public Document Room: (1) a co)y of the published version of the subject generic letter, and (2) a copy of t1e information paper (SECY-97 258) that was sent to the Commission.

I request that you provide me with the Nuclear Documents System accession number for this memorandum. This information may be provided by telephone (415 1151) or by e mail (JWS). In addition, please modify the ap3ropriate NUDOCS entries to reflect the fact that the documents identified lerein are related to Generic Letter 96 06. Supplement 1. t Attachments:

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UNITEL, STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C. 20555-0001 November 13,1997 NRC GENERIC LETTER 96-06, SUPPLEMENT 1: ASSURANCE OF EQUIPMENT OPERABILITY AND CONTAINMENT INTEGRITY DURING DESIGN BASIS ACCIDENT CONDITIONS Addressee 3 All holders of operating licenses for nuclear power reactors except those who have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel.

Purpose The U.S. Nuclear Regulatory Commission (NRC) is issuing this supplement to Generic Letter (GL) 90-06, " Assurance of Equipment Operability and Containment Integrity During Design.

Basis Accident Conditions," to inform addressees about ongoing efforts and new developments associated with GL 96 06 and to provide additional guidance for completing corrective actions. Addressees may find this information usefulin planning and scheduling future actions associated with GL 96-06. This generic letter supplement contains no new NRC requirements. Furthermore, no specific action or written response is required.

Backoround GL 96 06 was issued on September 30,1996, to address the following issues of concem:

1. Cooling water systems serving the containment air coolers may be exposed to the hydrodynamic effects of waterhammer during either a loss-of-coolant accident (LOCA) or a main steam line break (MSLB). These cooling water systems were not designed to withstand the hydrodynamic effects of waterhammer and actions may be needed to satisfy system design and operability requirements.
2. Cooling water systems serving the containment air celers may experience two-phase flow conditions during postulated LOCA and MSLB scenarios. The heat removal assumptions for design-basis accident scenarios are based on single-phase flow conditions and actions may be needed to satisfy system design and operability requirements.
3. Thermally induced overpressurization of isolated water filled piping sections in containment could jeopardize the ability of accident-mitigating systems to perform their safety functions and could lead to a breach of containment integrity through bypass

, leakage. Actions may be needed to satisfv system operability requirements, t

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' 4 GL 96-06, Supplement 1 November 13,1997 Page 2 of 5 GL 96-06 states-

  • lf systems are found to be susceptible to the conditions discussed in this generic letter, addressees are expected to assess the operability of affected systems and take corrective action as appropriate in accordance with the requirements stated in 10 CFR Part 50 Appendix B and as required by the plant Technical Specifications."

GL 96-06 refers to GL 91 18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability," for guidance on the resolution of issues identified in GL 96 06. (Note:

GL 91 18, Revision 1 was issued on October 8,1997, to inform licensees of the issuance of a revised section of the NRC Inspection Manual, Part 9900, " Technical Guidance," on the resolution of degraded and nonconforming conditions. The GL 96-06 reference to GL 9118 remains valid since it refers only to the " Technical Guidance" on operability, which was not changed by the issuance of GL 91 18, Revision 1.) Criterion XVI, " Corrective Actions," of Appendix B to 10 CFR Part 50 states, in part, " Measures shall be established to assure that...nonconformances are promptly identified and corrected." In this regard, GL 91-18 st&tes that the timeliness of corrective actions should be commensurate with the safety significance of the issue, and that the corrective action requirements of Appendix B may be satisfied by making changes in the design of the plant in lieu of restoring the affected equipment to its original design, in one example, GL 91 18 specifically discusses the use of the American Society of Mechanical Engineers Boiler end Pressure Vessel Code (ASME Code), Section Ill, Appendix F, criteria for interim operability determinations for degraded and nonconforming piping and pipe supports. It states that the use of Appendix F criteria is valid until the next rebeling outage when the supports are to be restored to the final safety analysis report criteria.

Addressees have responded to the generic letter and have established schedules for resolving the GL 96 06 issues. The NRC utaff is currently reviewing the information that has been submitted.

Discussion implementing corrective actions to resolve the GL 06-06 issues can have a significant impact on outage schedules and resources, and some addressees 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 modifications are needed and to assure that they do not ultimately result in a detriment to safety. Current issues and ongoing efforts that could influence an addressee'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 111 of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for the permanent resolution of the GL 96-08 issues; (3) ongoing tests by the Electric Power Research Institute to support a generic resolution of the overpressurization of piping issue; and (4) questions

l

. GL 96 06, Supplement 1 November 13,1997 Page 3 of 5 regarding the staff's closure of Generic Safety issue 150,"Overpressurization of Containment -

Penetrations." Risk insights and industry initiatives that are being considered or that may be proposed could also influence the course of action that addressees take to resolve the GL 96-06 issues.

Addressees are responsible for assessing equipment operability, determining actions, and establishing schedules ihat are appropriate for resolving the specific conditions that have been identified. In determining the appropriate actions and schedules for resolving GL 96-06 issues, addressees should consider, for example, the continued validity of existing operability determinations, compensatory actions required to maintain operability, the safety significance 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 actions (e.g., engineering evaluations, design change packages, material procurement, and equipment mooification 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 altematives 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. Addressees may find the revised guidance contained in GL 91 18, 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 justification.

It is the staff's current position that addressees 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 9118 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 scheduled for December 4,1997. 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.

&ouested Information Addressees who choose to revise their commitments for resolving the GL 96-06 issues should submit a revised response to the generic letter. Revised responses 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.

. GL 96-06, Supplement i November 13,1997 Page 4 of 5 1

Federal Reaistor Notification Because this GL supplement is informational, requires no specific action or response, and is I the result of ongoing efforts between NRC staff and addressees to resolve GL 96-06 issues, j there is no r'eed for additional opportunities for comment. Accordingly, a notice of opportunity for public comment was not published in the Federal Registor. However, ,

comments on the content of this supplement to GL 96-06 may be sent to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001.

Paperwork Reduction Act Stateme_01 For those addressees who find it necessary to revise their commitments for resolving the GL 96-06 issues, this generic letter supplement contains information collections that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collections were approved by the Office of Management and Budget, approval number 3150-0011, which expires on September 30,2000.

The public reporting burden for addressees who find it necessary to revise their response to GL 96-06 is estimated to average 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. The U.S. Nuclear Regulatory Commission is seeking public comment on the potentialimpact of the collection of information contained in the generic letter and on the following issues:

(1) is the proposed collection of information necessary for the proper performance of the functions of the NRC, including whether the information will have practical utility?

(2) la the estimate of burden accurate?

t3) is there a way to enhance the quality, utikty and clarity of the information to be collected?

(4) How can the burden of the collection of information be minimized, including the use of automated collection techniques?

Send comments on any aspect of this collection of information, including suggestions for reducing this burden, to the information and Records Management Branch, T-6F33, U.S.

Nuclear Regulatory Commission, Washington, D.C. 20555-0001, and to the Desk Officer, Office of Information and Regulatory Affairs NEOB 10202 (3150-0011), Office of Management and Budget, Washington, D.C. 20503.

November 13,1997 j Page 5 of 5 If you have any questions about this matter, rfosse contact the lead project manager or one I of the technical contacts listed below, or the appropriate Office of Nuclear Reactor Regulation  !

(NRR) project manager fer a specific nuclear power plant.  !

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'a Jack W. Roe, Acting Director Division of Reactor Program Management  !

Office of Nuclear Reactor Regulation ,

Technical contactsi James Tatum, NRR l 301-415 2805

  • E-mail: Jet 1@nte. gov  ;

John Fair, NRR l 301 415 2759  :

E-mail: jrf@nrc. gov Lead Project Manager: Beth Wetzel, NRR '

301 415 1355 E-mail: baw@nrc. gov

Attachment:

List of Recently Issued NRC Generic Letters i

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, Attachment GL 96 06, Supplement 1 November 13,1997 Page 1 of 1 LIST OF RECENTLY IStVf& EENE81Q_LEIIEBR Generic Date of Lgtier Sublect issuance issued To 91-18, INFORMATION TO LICENSEES 10/08/97 ALL HOLDERS OF OL:

REV.1 REGARDING NRC INSPECTION FOR NUCLEAR POWER MANUAL SECTION ON RESOLUTION AND NPRs, INCLUDING OF DEGRADED AND NONCONFORM- THOSE POWER REACTOR ING CONDITIONS LICENSEES WHO HAVE PERMANENTLY CEASED OPERATIONS, AND ALL HOLDERS OF NPR LICENSES WHOSE LICENSE NO LONGER AUTHORIZES OPERATION 97-04 ASSURANCE OF SUFFICIENT 10/07/97 ALL HOLDERS OF OLs NET POSITIVE SUCTION FOR NUCLEAR POWER HEAD FOR EMERGENCY PLANTS, EXCEPT THOSE CORE COOLING AND WHO HAVE PERMANENTLY CONTAINMENT HEAT CEASED OPERATIONS AND REMOVAL PUMPS HAVE CERTIFIED THAT FUEL HAS BEEN PERMAN-ENTLY REMOVED FROM THE REACTOR VESSEL 97-03 ANNUAL FINANCIAL SURETY 07/09/97 URANIUM RECOVERY LICENSEES UPDATE REQUIREMENTS AND STATE OFFICIALS FOR URANIUM RECOVERY LICENSEES 97-02 REVISED CONTENTS OF 05/15/97 ALL HOLDERS OF OLs THE MONTHLY OPERATING FOR NPRs, EXCEPT THOSE REPORT WHO HAVE PERMANENTLY CEASED OPERATIONS AND HAVE CERTIFIED THAT FUEL HAS BEEN PER-MANENTLY REMOVED FROM THE REACTOR VESSEL OL = OPERATING LICENSE CP = CONSTRUCTION PERMIT NPR = NUCLEAR POWER REACTORS

GL 96-06, Supplement 1 November 13,1997 Page 5 of 5 If you have any questions about this matter, please contact the lead project manager or one of the technical contacts listed below, or the appropriate Office of Nuclear Reactor Regulation 1 (NRR) project manager for a specific nuclear power plant. l original signed by D.B. Matthews for Jack W. Roe, Acting Director Division of Reactor Program Management Office of Nuclear Reactor Regulation Technical contacts: James Tatum, NRR 301 415-2805 E-rnail: Jet 1@nrc. gov John Fair, NRR 301-415 2759 E-mail: jrf@nrc. gov Lead Project Manager: Beth Wetzel, i'RR 301-415-1355 E-mail: baw@nrc. gov

Attachment:

List of Recently issued NRC Generic Letters DOCUMENT NAME: 9006SUP1 GL To receive a copy of this document. indicate in the box C= Copy w/o attachment / enclosure EsCopy with attachment /endosure N = No copy OFFICE STAFF C TECH C OGC BC:PECB E (A)D:DRPM CONTACTS BRANCH ,

NAME BWetzel* RHWessman* MRafky* SRichards* JRoe JFair* LBMar< h*

JTatum* CHBe. Liger

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DATE 10/03/97

  • 10/15/97 11/10/97 11/l}/97

'See Previous Concurrence OFFICIAL RECORD COPY

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l POLICY ISSUE October 31. 1997 (Information) SECY-97-258 l

E@: The Comissioners 1 Efg: L. Joseph Callan Executive Director for Operations

SUBJECT:

PRCPOSED SUPPLEMENT TO GENERIC LETTER 96 06. " ASSURANCE OF EQUIPMENT

! OPERABILITY AND CONTAINMENT INTEGRITY DURING DESIGN BASIS ACCIDENT '

CONDITIONS" l

PURPOSE:

The purpose of this paper is to inform the Comission, in accordance with the i guidance in a memorandum dated December 20, 1991, from Samuel J. Chilk to '

! James M. Taylor regarding SECY 91-172. " Regulatory Impact Survey l Re> ort-Final," of the staff's intent to issue a supplement to Generic Letter (GJ 96 06. The supplement is for information only and does not request  :

!! addressees to perform any actions. The suppleme:it to the generic letter informs addressees about ongoing efforts and new developments associated with l GL 96 06 and provides additional guidance for completing corrective actions.

A copy of the proposed supplement is attached.

i ElSCUSSION:

l GL 96 06 was issued on September 30, 1996, and requested addressees to review l cooling water systems that serve the containment air coolers and determine if i they are susceptible to waterhamer or two phase flow development. or both. l

during postulated accident conditions Additionally. the generic letter I
requested addressees to determine if piping systems that penetrate the i
containment are susceptible to thermal expansion of fluid such that  !

overpressurization may occur.

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Contact:

NOTE: To BE MADE PUBI.ICLY AVAILABLE IN Beth Wetzel. NRR 5 WORKING DAYS FROM THE DATE OF THIs PAPER I 301-415 1355 4D1" $ bpp

T I

2 The staff requested that licensees respond within 120 days (1) actions taken of in the date of the response generic letter with a summary re) ort stating:to the requested actions n relative to susceptibility for waterhammer and two-phase flow in the containment air cooler cooling water system and overpressurization of piping that penetrates containment. (3) the basis for continued operability of affected systems and components as applicable,The and staff (4) actions that were is currently implemented or are planned to be implemented. In an performing detailed reviews of licensees' responses to GL 96 06.

initial review of the licensees

  • 120 day responses, the staff noted that licensees of operating reactors have completed operability determinations and either made modifications to ensure operability or concluded that affected systems and components are operable.

Making plant modifications to resolve the GL 96 06 issues can have a significant impact on outage schedules and resources, an specific concerns that have been identified in order to optimize whatever modifications are needed and to assure that they do not ultimately result in a detriment to safety. Current issues and ongoing (1) efforts that could influence risk implications of a licensee's decision in this regard include:

installing relief valves to deal with the thermal overpressurization issue:

(2) feasibility of using the acceptance criteria contained in Appendix F to Section 111 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 andto(4) support a generic resolution of the overpressurization of piping issue:

questions regarding the staff's closure of Generic Safety issue 150, Risk insights

'Overpressurization of Containment Penetrations." initiatives that are influence the course of act1on that licensees take to resnive the GL 96 0 issues.

Although a number of issues have arisen that could affect licensees' schedules for resolvirg GL 96-06, licensees of the operating plants have determined that systems and components susceptible to the conditions discussed in GL 96-06 remain o)erable.

Therefore, the staff is receptive to licensees revising their scledular commitments for resolving the GL 96 06 issues. if justifiad.

The staff is notifying the licensees through a supplement to GL 96-06 thoc if a licensee elects to revise its schedular commitments, it should submit a revised response to the generic letter.

The staff has reviewed the original responses to GL 96 06 and noted that licensees of 16 plants with outages scheduled during the f all of 1997 plan to implement modifications related to GL 96-06 during these upcoming outages.

The staff plans to send letters to these licensees to notify them The that staff the NRC is

is receptive to revision; in schedular commitments if justified.

also planning to participate in a public workshop later this fall to discuss l

current issues related to GL 96 06 and licensees

  • Schedules for implementing actions in response to the GL.

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3-Because the GL sup)lement is informational, requires no specific action or response and is tie result of ongoing efforts between NRC staff and licensees to resolve GL 96 06 issues. there is no need for additional opportunities for comment. Accordingly a notice of opportunity for public comment on the proposed generic letter will not be published in the Federal Register.

The Office of the General Counsel has reviewed the proposed generic letter supplement and has no legal objection to its issuance.

A co)y of the proposed supplement to the generic letter has been transmitted to tic Committee To Review Generic Requirements (CRGR) for information only.

Since the supplement contains no requirements and no licensee action or response is required the staff recomnended that no CRGR review would be appropriate. terbal communications with members of the CRGR indicated that 11ey agreed with the staff's recommendation that CRGR review would not be required.

The staff intends to issue this generic letter approximately 5 working days after the date of this information paper.

b L.<jsephCallan Executive Director for Operations

Attachment:

Proposed Supplement 1 to GL 96 06 DISTRIBUTloN:

Commissioners oGC OlG oPA oCA ACRS Clo CFo EDo REGloNS SECY i

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