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| #REDIRECT [[IA-87-244, Requests Concurrence W/Interpretation of Requirements for Compliance W/Gdc 2 & 4 Protection of safety-related Structures,Sys & Components from Internal Flooding & Internal Missiles.Interpretation Challenged by Utils]]
| | {{Adams |
| | | number = ML20213E456 |
| | | issue date = 07/14/1983 |
| | | title = Requests Concurrence W/Interpretation of Requirements for Compliance W/Gdc 2 & 4 Protection of safety-related Structures,Sys & Components from Internal Flooding & Internal Missiles.Interpretation Challenged by Utils |
| | | author name = Parr O |
| | | author affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR) |
| | | addressee name = Mattson R |
| | | addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR) |
| | | docket = 05000000, 05000312, 05000352, 05000353 |
| | | license number = |
| | | contact person = |
| | | case reference number = FOIA-87-244 |
| | | document report number = TAC-52656, NUDOCS 8307200562 |
| | | package number = ML20213E458 |
| | | document type = INTERNAL OR EXTERNAL MEMORANDUM, MEMORANDUMS-CORRESPONDENCE |
| | | page count = 2 |
| | | project = TAC:52656 |
| | | stage = Other |
| | }} |
| | |
| | =Text= |
| | {{#Wiki_filter:_ . _ _ _ _ _ _ _ _ _ _ . |
| | /# "%e,\ tmitsJ str.Tss l' m NUCLEAR RECULATORY COMMISSION |
| | , j. n |
| | ! . ww.stose. o. c. mu |
| | (; r |
| | %, * * * * * ) |
| | Jgg, g 4 l MEMORANDUM FOR: Roger J. Mattson, Director Division of Systems Integration NRR THRU: g L. S. Rubenstein, Assistant Director for Core and Plant fy Systems Division of Systems Integration NRR I |
| | FROM: Olan D. Parr, Chief. Auxiliary Systems Branch, Division of Systems Integration, NRR |
| | |
| | ==SUBJECT:== |
| | ASB INTERPRETATION OF REQUIREMENTS FOR COMFLIANCE WITH GDC 2 AND 4 WITH RESPECT TO PROTECTION OF SPECIFIC STRUCTURES, SYSTEMS AND COMPONENTS FROM INTERNAL FLOC 014G OR INTERHAL MISSILES The purpose of this memorandum is to request your concurrencit with the Auxiliary Systems Branch's interpretation of the requirements for compliance with GDC 2 and 4 regarding protectio.1 of safety-related structures, systems and components from internal flooding and internal missiles. This matter is being brought to your attention at this time due to the fact that our interpretation as discussed below has been challenged by the Philadelphia Electric Company during the licensing review of the Limerick Generating St1 tion and by the Sacramento Municipal Utility District during the Appeal Board consideration of the restart ' |
| | . of Rancho Seco following the accident at TMI. |
| | During the Limerick review, the applicant has questioned ASB's interpretation of compliance with GDC 2 and 4 regarding internal flooding follcwing an SSE , |
| | wherein the guidelines of Regulatory Guide 1.29, Positions C.) and C.2, are applied. Position C.1 applies directly to those structures, systems and com-ponents which are required to maintain the primary pressure boundary, safely shut the plant down or mitigate the consequences of an accident (the SSE), and thus identified those which are " safety-related " to be classified " seismic Category !" and are therefore to be protected from internal flooding. Position C.2 states that nonseismic Category I structures, systems or components whose failure could reduce the functioning of safety-related, seismic Category I structures, systems or components should be designed and constructed so that the SSE would not cause such failure. In ASB's evaluations we assume that the ' |
| | direct consequences of the initiating event are taken concurrent with that. |
| | event and then compounded by a single active failure. When considering internal |
| | ! flooding following the SSE, we assume failure (total rupture) of one nonseismic Category I pipe in each compartment individually (the most limiting with respect to fluid loss) as a consequence of the event (SSE) and then take a concurrent single active failure (the most limiting from the standpoint of plant shutdowns. |
| | r s3DNC0$h2 ,, |
| | h |
| | |
| | 2 JUI.141983 Based on the above, we interpret compliance with Regulatory Guide 1.29 and therefore GDC 2 and 4 regarding internal flooding to consist of the following when nonseismic Category I fluid piping is in areas which may cause adverse flooding ofisafety-related equipment: |
| | : 1. Only seismic Category I structures, systems and components may be assumed available to mitigate the consequences of flooding due to a nonseismic Category I pipe break; |
| | : 2. If operator action is regt. ired, safety-related (seismic Category I) indica-tion and alams must be available to provide indication of flooding in safety-related areas; |
| | : 3. Operator response time of 20 miautes from the control room and 30 minutes from outside the control room are assumed for detemining the resulting water level in affected compartments prior to mitigation of the concern. |
| | For the Rancho Seco case, the staff was requested by the Appeal Board to review the capability of the. AFWS to comply with the current revision of the Standard Review Plan. Here the licensee has questioned ASB's interpretation of com-pliance with GDC 4 regarding internal missiles that could result from in-plant component overspeed failures and high-pressure system ruptures. Where safetyd related systems or components are located in areas containing nonsafety-related systems or components, the nonsafety-related systems or components are reviewed C, with respect to internal missile effects if the failure could preclude the intended safety function of the safety-related systems or components. In ASB's ^ |
| | evaluations, as is the case for the SSE, we assume that the direct consequences of the initiating events (missile impact damage) are taken concurrent with the event. That is, in a manner similar to Regulatory Guide 1.29, Position C.2, no missile generated from a nonsafety-related component should have the potential to damage a safety-related components. The event is then compounded by a single active failure. Consequently, for Rancho Seco, which has only two AFW trains, both trains must be protected. |
| | While the Standard Review Plan (SRP) does not lead to easy interpretation the staff's implementation of the SRP as contained herein has been used for sometime. |
| | We are not aware of any plants which have not been reviewed against these criteria during the last ten years. We therefore do not consider it necessary to treat these matters as part of the backfit procedure or to go before the CRGR. |
| | Ib . |
| | OlWD. Parr, Chief Auxiliary Systems Branch Division of Systems Integration cc: H. Denton E. Case D. Eisenhut T. Novak R. Purple ASB Members G. Lainas r / |
| | Approved L CD Roger D. Mptson (}} |
|
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Category:INTERNAL OR EXTERNAL MEMORANDUM
MONTHYEARML20211D1001999-08-20020 August 1999 Notification of 990908 Meeting with Util to Discuss Status of Limerick & Peach Bottom Licensing Issues.Meeting Held in Rockville,Md ML20207F2731999-05-25025 May 1999 Notification of 990609 Meeting with PECO Energy in Linfield, Pennsylvania to Discuss Results of Plant Performance Review of Limerick Issued on 990409 ML20205F9901999-04-0202 April 1999 Notification of 990419 Meeting with Util in Rockville,Md to Discuss Schedule for Completion of Installation of Fire Barriers at Plant ML20207J7561999-02-19019 February 1999 Forwards Proposed Transmittal Ltr & Comments on Physical Protection Plan in Response to Verbal Request from Rancho Seco to Provide Addl Comments on ISFSI Physical Protection Installation ML20196J9851998-12-0808 December 1998 Notification of 981218 Meeting with Util in Rockville,Md to Plant Licensing Issues ML20155G7751998-11-0404 November 1998 Notification of 981118 Meeting with Util in Rockville,Md to Discuss Limerick Generating Station,Units 1 & 2 & Peach Bottom Atomic Power Station,Units 2 & 3 Ampacity Validation Analyses ML20216C4501998-05-12012 May 1998 Notification of 980610 Meeting 98-51 W/Util in King of Prussia,Pa to Discuss Diesel Generator Failure & HPCI Exhaust Valve Failure & RHR Min Flow Valve Predecisional Enforcement Conference ML20216C4351998-04-15015 April 1998 Notification of 980527 Meeting W/Peco Energy Co in King of Prussia,Pennsylvania to Discuss Diesel Generator Failure & HPCI Exhaust Valve Failure & RHR Min Flow Valve Failure Predecisional Enforcement Conference IR 05000352/19980011998-03-0909 March 1998 Forwards NRC Operator Licensing Exam Repts 50-352/98-01 & 50-353/98-01 for Exams Administered on 980120-23 ML20210K3001997-08-15015 August 1997 Notification of 970820 Meeting W/Util in North Bethesda,Md to Discuss Plants Project Mgt Issues Including Planned TSs Submittals & Generic Licensing Issue Status ML20217H1991997-08-0606 August 1997 Forwards Signed Original of Order Prohibiting Involvement in NRC-licensed Activities (Effective Immediately) for Transmittal to Ofc of Fr,For Publication.W/O Encl ML20151L7771997-08-0101 August 1997 Notification of Meeting W/Peco Energy Co on 970805 in Rockville,Md to Discuss Plans & Schedules for Resolving thermo-lag Fire Barrier Issues at Mentioned Plants ML20148F7201997-05-30030 May 1997 Forwards Semiannual Status Rept on Fire Protection Task Action Plan & plant-specific Thermo-Lag Correction Action Programs ML20148E3591997-05-28028 May 1997 Notification of Significant Licensee Meeting 97-62 W/Util on 970602 to Discuss Issues Associated W/Inaccurate Records Relating to Fire Protection & Chemistry Surveillance Results ML20137Z8141997-04-21021 April 1997 Forwards NRC Approved Operator Licensing Exam (as-given Operating Exam) for Tests Administered on 970120-24 ML20137Z8881997-04-21021 April 1997 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal) for Tests Administered on 970120-24 ML20137G7241997-03-25025 March 1997 Corrects Notification of 970414 Meeting W/Util in Bethesda, MD to Discuss Util Plans & Schedules for Resolution of Thermo-Lag Fire Barrier Issues at Plants ML20203C0741997-03-17017 March 1997 Discusses OI Rept 1-96-033 Re Alleged Falsification of Fire Protection Surveillance Test Documentation.Requests That OGC Analyze Rept & Determine If Sufficient Evidence for Action. EA-97-115 Assigned to Track Case ML20136G0391997-03-13013 March 1997 Notification of 970414 Meeting W/Util in North Bethesda,Md to Discuss PECO Plans & Schedules for Resolution of Thermo Lag Fire Barrier Issues at Peach Bottom & Limerick ML20132A8991996-12-12012 December 1996 Forwards Background Document Re Event Rept on Fire Protection Analysis Assumptions for Safety Relief Valve Operation,For Plant,Units 1 & 2 ML20129K2561996-11-0505 November 1996 Notification of Significant Licensee Meeting 96-109 W/Listed Attendees on 961202-03 in Philadelphia,Pa to Provide Training,Resolve Interagency Exercise Scheduling Conflicts & Discuss Current Issues in Emergency Preparedness ML20129B5541996-10-18018 October 1996 Notification of 961025 Meeting W/Util in Delta,Pa to Discuss Status of Open & Planned Licensing Actions for Pbaps,Units 2 & 3 & Limerick Generating Station,Units 1 & 2 ML20134K5771995-12-0505 December 1995 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal & as-given Operating Exam) for Tests Administered on 951113-16 ML20149J1451994-12-22022 December 1994 Notification of Significant Licensee Meeting 94-149 W/Util on 950109 in King of Prussia,Pa to Discuss Upcoming Unit 2 Outage & Changes in Health Physics Organization NUREG-1299, Forwards Continuation of Curtiss Papers to Be Filed Under Commission Correspondence in Pdr.Advanced Copy Sent to Pdr. List of Documents Included in Four Boxes Encl1994-06-29029 June 1994 Forwards Continuation of Curtiss Papers to Be Filed Under Commission Correspondence in Pdr.Advanced Copy Sent to Pdr. List of Documents Included in Four Boxes Encl ML20058K1571993-12-0606 December 1993 Notification of 931214 Meeting W/Util in Rockville,Md to Discuss Risk of Performing EDG 24 Hr Testing at Power ML20059K7201993-11-0808 November 1993 Notification of Significant Licensee Meeting 93-145 W/Util on 931124 in Limerick,Pa to Discuss SALP Mgt Meeting ML20059K2711993-11-0303 November 1993 Discusses 931027 Operating Reactors Events Briefing Conducted to Inform Senior Managers from Listed Ofcs of Selected Events That Occurred Since Last Briefing on 931020. List of Attendees Encl ML20057F8771993-10-14014 October 1993 Notification of 931103 Meeting W/Util in Rockville,Md to Discuss Certain Cost Beneficial Licensing Actions ML20057F1511993-10-0808 October 1993 Notification of 931019 Meeting W/Util in Rockville,Md to Discuss MOV Testing Program ML20057F4341993-10-0606 October 1993 Notification of 931014 Significant Licensee Meeting 93-129 W/Util in King of Prussia,Pa to Discuss Power Oscillation Issue Which Was Subj of Notice of Deviation ML20057D2721993-09-24024 September 1993 Notification of Significant Licensee Meeting 93-125 W/Util on 931004 in King of Prussia,Pa to Discuss 13 Kv Cable Fault During Excavation on 930907 ML20057C1161993-09-17017 September 1993 Notification of 931001 Significant Licensee Meeting 93-125 in King of Prussia,Pa to Discuss 13 Kv Cable Fault During Excavation on 930907 ML20056G8501993-08-25025 August 1993 Notification of Significant Licensee Meeting 93-113 W/Util on 930908 to Discuss Transfer of Fuel from Shoreham to Limerick ML20056E0461993-08-17017 August 1993 Notification of 930824 Meeting W/Util in Rockville,Md to Discuss Control & Maint Qualifications & License Status for Lsros to Fuel Handling Licensed at Pbaps,Units 2 & 3 & LGS, Units 1 & 2 ML20056E4571993-08-0505 August 1993 Forwards Technical Review Rept Re, Tardy Licensee Actions Initiated Because of Delayed Replacement of Batteries in Uninterruptible Power Supplies at Plant ML20056C8421993-07-13013 July 1993 Notification of Significant Licensee Meeting W/Util on 930727 to Discuss Decommissioning & General Status ML20128P5341993-02-19019 February 1993 Notification of 930225 Meeting W/Util in Wayne,Pa to Discuss Evaluation for Conversion to 24-month Fuel Cycle from Current 18-month Period ML20128P5561993-02-12012 February 1993 Notification of Significant Licensee Meeting 93-19 W/Util on 930226 to Discuss QA Change Request for Facilities ML20127L0861992-12-29029 December 1992 Notification of Significant Licensee Meeting 92-188 on 930107 in King of Prussia,Pa to Discuss Common Emergency Plan for Plants ML20126C3521992-12-16016 December 1992 Notification of Significant Licensee Meeting 92-183 W/Util on 930112 to Conduct Enforcement Conference for Edsfi ML20126C3931992-12-15015 December 1992 Notification of Significant Licensee Meeting 92-182 W/Util on 921222 to Discuss Continuing Problems W/Maintenance Procedures ML20126H2791992-12-11011 December 1992 Notification of Significant Licensee Meeting 92-181 W/Util on 921218 to Discuss Failed Fuel Reliability ML20126B4721992-12-10010 December 1992 Notification of Significant Licensee Meeting 92-180 W/Util on 921218 to Discuss Needs Program.Meeting Closed to Public Due to Sensitive Personnel Related Issues ML20198E3331992-11-24024 November 1992 Notification of 921201 Meeting W/Util in Rockville,Md to Discuss Licensing Activities ML20062H0281990-11-20020 November 1990 Notification of Significant Licensee Meeting 90-138 W/Util on 901128 to Discuss SALP Board Meeting ML20062F3981990-11-0909 November 1990 Notification of Significant Licensee Mgt Meeting 90-134 W/ Util on 901120 at Region I Ofc to Discuss Early Retirement Program ML20058D1231990-10-25025 October 1990 Notification of Significant Meeting on 901030 W/Util in Herald,Ca to Discuss Licensee Organization,Staffing,Plant Status & Status of Licensee Programs 1999-08-20
[Table view] Category:MEMORANDUMS-CORRESPONDENCE
MONTHYEARML20211D1001999-08-20020 August 1999 Notification of 990908 Meeting with Util to Discuss Status of Limerick & Peach Bottom Licensing Issues.Meeting Held in Rockville,Md ML20207F2731999-05-25025 May 1999 Notification of 990609 Meeting with PECO Energy in Linfield, Pennsylvania to Discuss Results of Plant Performance Review of Limerick Issued on 990409 ML20205F9901999-04-0202 April 1999 Notification of 990419 Meeting with Util in Rockville,Md to Discuss Schedule for Completion of Installation of Fire Barriers at Plant ML20207J7561999-02-19019 February 1999 Forwards Proposed Transmittal Ltr & Comments on Physical Protection Plan in Response to Verbal Request from Rancho Seco to Provide Addl Comments on ISFSI Physical Protection Installation ML20196J9851998-12-0808 December 1998 Notification of 981218 Meeting with Util in Rockville,Md to Plant Licensing Issues ML20155G7751998-11-0404 November 1998 Notification of 981118 Meeting with Util in Rockville,Md to Discuss Limerick Generating Station,Units 1 & 2 & Peach Bottom Atomic Power Station,Units 2 & 3 Ampacity Validation Analyses ML20216C4501998-05-12012 May 1998 Notification of 980610 Meeting 98-51 W/Util in King of Prussia,Pa to Discuss Diesel Generator Failure & HPCI Exhaust Valve Failure & RHR Min Flow Valve Predecisional Enforcement Conference ML20216C4351998-04-15015 April 1998 Notification of 980527 Meeting W/Peco Energy Co in King of Prussia,Pennsylvania to Discuss Diesel Generator Failure & HPCI Exhaust Valve Failure & RHR Min Flow Valve Failure Predecisional Enforcement Conference IR 05000352/19980011998-03-0909 March 1998 Forwards NRC Operator Licensing Exam Repts 50-352/98-01 & 50-353/98-01 for Exams Administered on 980120-23 ML20210K3001997-08-15015 August 1997 Notification of 970820 Meeting W/Util in North Bethesda,Md to Discuss Plants Project Mgt Issues Including Planned TSs Submittals & Generic Licensing Issue Status ML20217H1991997-08-0606 August 1997 Forwards Signed Original of Order Prohibiting Involvement in NRC-licensed Activities (Effective Immediately) for Transmittal to Ofc of Fr,For Publication.W/O Encl ML20151L7771997-08-0101 August 1997 Notification of Meeting W/Peco Energy Co on 970805 in Rockville,Md to Discuss Plans & Schedules for Resolving thermo-lag Fire Barrier Issues at Mentioned Plants ML20148F7201997-05-30030 May 1997 Forwards Semiannual Status Rept on Fire Protection Task Action Plan & plant-specific Thermo-Lag Correction Action Programs ML20148E3591997-05-28028 May 1997 Notification of Significant Licensee Meeting 97-62 W/Util on 970602 to Discuss Issues Associated W/Inaccurate Records Relating to Fire Protection & Chemistry Surveillance Results ML20137Z8881997-04-21021 April 1997 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal) for Tests Administered on 970120-24 ML20137Z8141997-04-21021 April 1997 Forwards NRC Approved Operator Licensing Exam (as-given Operating Exam) for Tests Administered on 970120-24 ML20137G7241997-03-25025 March 1997 Corrects Notification of 970414 Meeting W/Util in Bethesda, MD to Discuss Util Plans & Schedules for Resolution of Thermo-Lag Fire Barrier Issues at Plants ML20203C0741997-03-17017 March 1997 Discusses OI Rept 1-96-033 Re Alleged Falsification of Fire Protection Surveillance Test Documentation.Requests That OGC Analyze Rept & Determine If Sufficient Evidence for Action. EA-97-115 Assigned to Track Case ML20136G0391997-03-13013 March 1997 Notification of 970414 Meeting W/Util in North Bethesda,Md to Discuss PECO Plans & Schedules for Resolution of Thermo Lag Fire Barrier Issues at Peach Bottom & Limerick ML20132A8991996-12-12012 December 1996 Forwards Background Document Re Event Rept on Fire Protection Analysis Assumptions for Safety Relief Valve Operation,For Plant,Units 1 & 2 ML20129K2561996-11-0505 November 1996 Notification of Significant Licensee Meeting 96-109 W/Listed Attendees on 961202-03 in Philadelphia,Pa to Provide Training,Resolve Interagency Exercise Scheduling Conflicts & Discuss Current Issues in Emergency Preparedness ML20129B5541996-10-18018 October 1996 Notification of 961025 Meeting W/Util in Delta,Pa to Discuss Status of Open & Planned Licensing Actions for Pbaps,Units 2 & 3 & Limerick Generating Station,Units 1 & 2 ML20134K5771995-12-0505 December 1995 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal & as-given Operating Exam) for Tests Administered on 951113-16 ML20149J1451994-12-22022 December 1994 Notification of Significant Licensee Meeting 94-149 W/Util on 950109 in King of Prussia,Pa to Discuss Upcoming Unit 2 Outage & Changes in Health Physics Organization NUREG-1299, Forwards Continuation of Curtiss Papers to Be Filed Under Commission Correspondence in Pdr.Advanced Copy Sent to Pdr. List of Documents Included in Four Boxes Encl1994-06-29029 June 1994 Forwards Continuation of Curtiss Papers to Be Filed Under Commission Correspondence in Pdr.Advanced Copy Sent to Pdr. List of Documents Included in Four Boxes Encl ML20058K1571993-12-0606 December 1993 Notification of 931214 Meeting W/Util in Rockville,Md to Discuss Risk of Performing EDG 24 Hr Testing at Power ML20059K7201993-11-0808 November 1993 Notification of Significant Licensee Meeting 93-145 W/Util on 931124 in Limerick,Pa to Discuss SALP Mgt Meeting ML20059K2711993-11-0303 November 1993 Discusses 931027 Operating Reactors Events Briefing Conducted to Inform Senior Managers from Listed Ofcs of Selected Events That Occurred Since Last Briefing on 931020. List of Attendees Encl ML20057F8771993-10-14014 October 1993 Notification of 931103 Meeting W/Util in Rockville,Md to Discuss Certain Cost Beneficial Licensing Actions ML20057F1511993-10-0808 October 1993 Notification of 931019 Meeting W/Util in Rockville,Md to Discuss MOV Testing Program ML20057F4341993-10-0606 October 1993 Notification of 931014 Significant Licensee Meeting 93-129 W/Util in King of Prussia,Pa to Discuss Power Oscillation Issue Which Was Subj of Notice of Deviation ML20057D2721993-09-24024 September 1993 Notification of Significant Licensee Meeting 93-125 W/Util on 931004 in King of Prussia,Pa to Discuss 13 Kv Cable Fault During Excavation on 930907 ML20057C1161993-09-17017 September 1993 Notification of 931001 Significant Licensee Meeting 93-125 in King of Prussia,Pa to Discuss 13 Kv Cable Fault During Excavation on 930907 ML20056G8501993-08-25025 August 1993 Notification of Significant Licensee Meeting 93-113 W/Util on 930908 to Discuss Transfer of Fuel from Shoreham to Limerick ML20056E0461993-08-17017 August 1993 Notification of 930824 Meeting W/Util in Rockville,Md to Discuss Control & Maint Qualifications & License Status for Lsros to Fuel Handling Licensed at Pbaps,Units 2 & 3 & LGS, Units 1 & 2 ML20056E4571993-08-0505 August 1993 Forwards Technical Review Rept Re, Tardy Licensee Actions Initiated Because of Delayed Replacement of Batteries in Uninterruptible Power Supplies at Plant ML20056C8421993-07-13013 July 1993 Notification of Significant Licensee Meeting W/Util on 930727 to Discuss Decommissioning & General Status ML20128P5341993-02-19019 February 1993 Notification of 930225 Meeting W/Util in Wayne,Pa to Discuss Evaluation for Conversion to 24-month Fuel Cycle from Current 18-month Period ML20128P5561993-02-12012 February 1993 Notification of Significant Licensee Meeting 93-19 W/Util on 930226 to Discuss QA Change Request for Facilities ML20127L0861992-12-29029 December 1992 Notification of Significant Licensee Meeting 92-188 on 930107 in King of Prussia,Pa to Discuss Common Emergency Plan for Plants ML20126C3521992-12-16016 December 1992 Notification of Significant Licensee Meeting 92-183 W/Util on 930112 to Conduct Enforcement Conference for Edsfi ML20126C3931992-12-15015 December 1992 Notification of Significant Licensee Meeting 92-182 W/Util on 921222 to Discuss Continuing Problems W/Maintenance Procedures ML20126H2791992-12-11011 December 1992 Notification of Significant Licensee Meeting 92-181 W/Util on 921218 to Discuss Failed Fuel Reliability ML20126B4721992-12-10010 December 1992 Notification of Significant Licensee Meeting 92-180 W/Util on 921218 to Discuss Needs Program.Meeting Closed to Public Due to Sensitive Personnel Related Issues ML20198E3331992-11-24024 November 1992 Notification of 921201 Meeting W/Util in Rockville,Md to Discuss Licensing Activities ML20062H0281990-11-20020 November 1990 Notification of Significant Licensee Meeting 90-138 W/Util on 901128 to Discuss SALP Board Meeting ML20062F3981990-11-0909 November 1990 Notification of Significant Licensee Mgt Meeting 90-134 W/ Util on 901120 at Region I Ofc to Discuss Early Retirement Program ML20058D1231990-10-25025 October 1990 Notification of Significant Meeting on 901030 W/Util in Herald,Ca to Discuss Licensee Organization,Staffing,Plant Status & Status of Licensee Programs 1999-08-20
[Table view] |
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Jgg, g 4 l MEMORANDUM FOR: Roger J. Mattson, Director Division of Systems Integration NRR THRU: g L. S. Rubenstein, Assistant Director for Core and Plant fy Systems Division of Systems Integration NRR I
FROM: Olan D. Parr, Chief. Auxiliary Systems Branch, Division of Systems Integration, NRR
SUBJECT:
ASB INTERPRETATION OF REQUIREMENTS FOR COMFLIANCE WITH GDC 2 AND 4 WITH RESPECT TO PROTECTION OF SPECIFIC STRUCTURES, SYSTEMS AND COMPONENTS FROM INTERNAL FLOC 014G OR INTERHAL MISSILES The purpose of this memorandum is to request your concurrencit with the Auxiliary Systems Branch's interpretation of the requirements for compliance with GDC 2 and 4 regarding protectio.1 of safety-related structures, systems and components from internal flooding and internal missiles. This matter is being brought to your attention at this time due to the fact that our interpretation as discussed below has been challenged by the Philadelphia Electric Company during the licensing review of the Limerick Generating St1 tion and by the Sacramento Municipal Utility District during the Appeal Board consideration of the restart '
. of Rancho Seco following the accident at TMI.
During the Limerick review, the applicant has questioned ASB's interpretation of compliance with GDC 2 and 4 regarding internal flooding follcwing an SSE ,
wherein the guidelines of Regulatory Guide 1.29, Positions C.) and C.2, are applied. Position C.1 applies directly to those structures, systems and com-ponents which are required to maintain the primary pressure boundary, safely shut the plant down or mitigate the consequences of an accident (the SSE), and thus identified those which are " safety-related " to be classified " seismic Category !" and are therefore to be protected from internal flooding. Position C.2 states that nonseismic Category I structures, systems or components whose failure could reduce the functioning of safety-related, seismic Category I structures, systems or components should be designed and constructed so that the SSE would not cause such failure. In ASB's evaluations we assume that the '
direct consequences of the initiating event are taken concurrent with that.
event and then compounded by a single active failure. When considering internal
! flooding following the SSE, we assume failure (total rupture) of one nonseismic Category I pipe in each compartment individually (the most limiting with respect to fluid loss) as a consequence of the event (SSE) and then take a concurrent single active failure (the most limiting from the standpoint of plant shutdowns.
r s3DNC0$h2 ,,
h
2 JUI.141983 Based on the above, we interpret compliance with Regulatory Guide 1.29 and therefore GDC 2 and 4 regarding internal flooding to consist of the following when nonseismic Category I fluid piping is in areas which may cause adverse flooding ofisafety-related equipment:
- 1. Only seismic Category I structures, systems and components may be assumed available to mitigate the consequences of flooding due to a nonseismic Category I pipe break;
- 2. If operator action is regt. ired, safety-related (seismic Category I) indica-tion and alams must be available to provide indication of flooding in safety-related areas;
- 3. Operator response time of 20 miautes from the control room and 30 minutes from outside the control room are assumed for detemining the resulting water level in affected compartments prior to mitigation of the concern.
For the Rancho Seco case, the staff was requested by the Appeal Board to review the capability of the. AFWS to comply with the current revision of the Standard Review Plan. Here the licensee has questioned ASB's interpretation of com-pliance with GDC 4 regarding internal missiles that could result from in-plant component overspeed failures and high-pressure system ruptures. Where safetyd related systems or components are located in areas containing nonsafety-related systems or components, the nonsafety-related systems or components are reviewed C, with respect to internal missile effects if the failure could preclude the intended safety function of the safety-related systems or components. In ASB's ^
evaluations, as is the case for the SSE, we assume that the direct consequences of the initiating events (missile impact damage) are taken concurrent with the event. That is, in a manner similar to Regulatory Guide 1.29, Position C.2, no missile generated from a nonsafety-related component should have the potential to damage a safety-related components. The event is then compounded by a single active failure. Consequently, for Rancho Seco, which has only two AFW trains, both trains must be protected.
While the Standard Review Plan (SRP) does not lead to easy interpretation the staff's implementation of the SRP as contained herein has been used for sometime.
We are not aware of any plants which have not been reviewed against these criteria during the last ten years. We therefore do not consider it necessary to treat these matters as part of the backfit procedure or to go before the CRGR.
Ib .
OlWD. Parr, Chief Auxiliary Systems Branch Division of Systems Integration cc: H. Denton E. Case D. Eisenhut T. Novak R. Purple ASB Members G. Lainas r /
Approved L CD Roger D. Mptson (