ML20203J320

Discusses Lessons Learned from EA 97-099 Re Possible Generic Concern W/Ts Required Flowrates to Containment Fan Coolers

ML20203J320
Person / Time
Issue date:	02/25/1998
From:	Boger B NRC (Affiliation Not Assigned)
To:	Lieberman J NRC OFFICE OF ENFORCEMENT (OE)
References
CON-FIN-W-6781 EA-97-099, EA-97-99, NUDOCS 9803040053
Download: ML20203J320 (3)

Text

_ _ _

. {,, .' me:g\ UNITSD STATES o*m NUCLEAR RESULATCRY COMMISSION 3 WA6HINeToN, D.c. SeteHeM

..... February 25, 1998 i MEMORANDUM To: James L. Uebermen, Director Office of Enforcement  :

- FROM: Bruce A. Boger, Acting Associate Director for Projects -

Office of Nuclear Reactor Regulation CUSJECT: LESSONS LEARNED FROM ENFORCEMENT ACTION EA 97 099 -

POSSIBLE GENERIC CONCERN WITH TECHNICAL SPECIFICATION REQUIRED FLOWRATES TO CONTAINMENT FAN COOLERS By a memorandum dated August 8,1997, the Office of Enforcement (OE) requested the Offlee of Nuclear Reactor Regulation (NRR) to issue an information Notice or to take other apprete action to ensure that opsrating reactors with containmsc;. Fan Coolers (CFC) are performing testing in accordance with their Technical Specifications (TSs). The concem expressed was -

that there may be safety and compliance issues with respect to testing of CFC if it is required that plants test flow through their CFC with component cooling water (CCW) in the accident slignmord.

OE's concem was identified from a recent NRC Enforcement Action (EA)97-099 dated May 9,

!. 1997, and NRC inspection Report 50 382/97-03 dated March 7,1997, each dealing, in part, with the licensee's failure to comply with a TS Surveillance Requirement (SR) for CFC at the -

Waterford 3 (Waterford) station, Subsequent to this enforcement action, OE reviewed the equivalent TSs at Calvert Cliffs and San Onofre as well as the improved Standard Technical Specifications for Combustior: Engineering Plants (NUREG-1432) and found that these SRs read much the same way as the Waterford SRs.- OE indicated that none of these SRs specify that-flow rate through the containment coolers is to be measured in the accident alignment.

In response to OE's memorandum, NRR has takan actions to determine the scope of potential problems in performing the proper surveillance for CFC at other operating plants:

1. - The SR at Waterford is slightly different from the SR at Calvert Cliffs, San Onofre, and NUREG-1432. Waterford has a monthly SR at normal flow rates and an eighteen roonth SR at design basis accident (DSA) required CCW flow rates. Other plants (including NUREG 1432) have only a monthly SR to verify -

flow to their CFC at one flow rate. Testing using the accident ficw path is not discussed in any of these TSs.

2. NRR has discussed this issue with the resident staffs at San Onde h..J Calvoit Cliffs. At San Onofre, the resident staff confirmed through inspection that /

survelliance procedures are provided to verify that edequate flow through p w-@ ps m ne m CCPY b~9 9n a od V " Il ll llllll

. .. Ill,!!I,ll.i gp to g 00g m 225 , , , , ,

l 1432 C PDR

]

'. James L. Ueberman CFC will be provided in the accident wilgnment. The inspection resuhs are documented in the resident's inspection report (IR 50 361/g71g and IR 50 362/g7-1g). At Calvert Giffs a monthly SR requires verifying a flow rate of 2000 gpm when the full flow service water outlet valves are fully open. However, the DBA required minimum flow rate is 1400 gpm. The Baltimore Gas and Electric (BGE) Company routinely does not verify the flow rate in the accident mode. Howeter, BGE has confirmed that Calvert Cliffs is capable of providing the design flow assumed in the Final Safety Analysis Report, in addition, Calvert Cliffs' TSs are worded clearly, and BGE has submitted an application to convert Calvert Cliffs's TSs to improved Standard TSs. The proposed TSs for CFC are the same (including Bases) as NUREG-1432. The staff is expecting to complete its review by spring of 1998. This will resolt s any potential concoms regarding Calvert Cliffs.

3. The Technical Specification Branch (TSB) has rey!ewed the subject TSs and its bases section and determined that the staff has provided adwquate information in the bases section for this survelliance. The bases for CFC say that " Verifying a service water flow of a [2000] gpm to each cooling unit provides assurance that the design flow rate assumed b the safety analyses wi:1 be achieved."

Licensees have flexibility to demonstrate how they meet their accident analyses requirements, either through direct testing or indirectly through evaluation.

Based on this determination TSB believes there is no need to change the Iraproved Standard TSs.

4. We have requested that the Events Assessment, Generic Communications, and Special Inspection Branch consider evaluating the licensees' approach in meeting the SR for the system (s) being inspected during special design l

inspections where the issue may be within the scope of the inspection.

5. Licensees should be reviewing the NUREG-0940," Enforcement Actions:

Significant Actions Resolved. Reactor Licensees" regularly issued by the NRC staff. This NUREG provides information to licensees regarding the staff's expectation for this type of surveillance.

Based on the above considerations, NRR has determined that at present there is no need to provide additional guidance to licensees on this issue. However, we will continue to monitor relevant inspection findings and will consider appropriate actions if warrented in the futuie.

Please let us know if you have any further concems in this area.

• I "" * '

• 6

[t, d

fI

. - James L. Lieberman 2-z L - . -

CFC will be provided in the accident alignment. The inspection results are -

documented in the resident's inspection report (IR 50 361/g71g and

IR 50-362/97-1g). At Calvert Cliffs a monthly SR requires verifying a flow rate of i 2000 gpm when the full flow service water outlet valves are fully open. However, i= the DBA required minimum flow rate is 1400 gpm. The Baltimore Gas and -

Electric (BGQ Company routinely does not verify the flow rate in the accident

[ mode. However, BGE has confirmed that Calvert Cliffs is capable of providing

!~

the design flow assumed in the Final Safety Analysis Report. In addition, Calvert Cliffs' TSs are worded clearty, and BGE has submitted an application to convert Calvert Cliffs's TSs to improved Standard TSs. The proposed TSs for CFC are .

the same (includeg Bases) as NUREG-1432. Thc staff is expecting to complete L lts review by spring of 1998. This will resolve any potential concems regadng,

Calvert Cliffs.

l i

3. The Technical Sr scification Branch (TSB) has reviewed the sebject TSs and its bases section and determined that the staff has provided adequate information in the bases section for this surveillance. The bases for CFC say that " Verifying a

service water"iow of a (2000] gpm to each cooling unit provides assurance that the design flow rate assumed in the safety analyses will be acileved."

. Licenseet have flexibility to demonstrate how they meet their accident analyses

requirements, either through direct testing or indirectly _through evaluation.

Based on this determination TSB believes thera is no need to change the improved Standard TSs.

[ 4. We have requested that the Events Assessment, Generic Communications, and l Special Inspection Branch consider evaluating the liccasees' approach in meeting the SR for the system (s) being inspected during special desi9 n inspections where the issue may be within the scope of the inspection.~ ,

L ' 5. Licensees should be'reviewmg the NUREG-0940, " Enforcement Actions:

Significant Actions Resolved, Reactor Licensees" regularly issucd by the NRC i staff. This NUREG provides information to licensees regarding the staff's -

! emoctation for this type of_ surveillance.

L .

L Based on the above considerations, NRR has determined that at present there is no need to

_ provide additional guidance to licensees on this issue. However, we will continue to monitor

! - relevant inspection findinge and will consider appropriate actions if warrented in the future.

l: Please let us know if you have any further concems in this area.

L DISTRIBUTION i

!> Central File: PUBLIC CPatel CHawes

- PD4-1 r/f CBerlinger Nbv//WM Project Div. Dir., RI-RIV i WBecimer EAdensam (EGA1)

Document Name WATF/099.ENF - See previous concurrence %

i- 1 2e

! OFC PM/PD&1 LA/PO41 TSB* D/PD4-h1 (A)D/DRPW SCSB* (A)ADPR

! NAME CPat[ CHawoh WBeckner JHanno EAhe am CBerlinger BBogerd DATE A/ (198 A f( /98 10/23/07 /98 1/@/98 01/05/98 7 /d/9 l COPY-b NO YES/NO YES/NO hNO YES/NO YES/NO 'YES/NO OFFICIAL RECORD CDP (

1. . , - - . , . _ _ _ _ _ _ _ _ . - - . . _ _- - . .