ML20199E561

Discusses Info Re Plant Implementation of Mods Associated W/Gl 96-06, Assurance of Equipment Operability & & Containment Integrity During Design-Basis Accident Conditions

ML20199E561
Person / Time
Site:	Callaway
Issue date:	11/13/1997
From:	Westreich B NRC (Affiliation Not Assigned)
To:	Randolph G UNION ELECTRIC CO.
References
GL-96-06, GL-96-6, TAC-M96791, NUDOCS 9711210244
Download: ML20199E561 (4)

Text

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d .I t UNITED STATES

• ,g NUCLEAR REGULATORY COMMISSION

• WASHINGTON, D.C. 3044H001 k* * . . . . / November 13, 1997 .

Mr. Garry L. Randolph Vice President and Chief Nuclear Office-Union Electric Company Post- Office Box 620 Fulton. Missouri 65251 ,

SUBJECT:

INFORMATION PERTAINING TO CALLAWAY PLANT IMPLEMENTATION OF MODIFICATIONS ASSOCIATED WITH GENERIC LETTER 96 06, " ASSURANCE OF EQUIPMENT OPERABILITY AND CONTAINMENT INTEGRITY DURING DESIGN BASIS ACCIDENT CONDITIONS" (TAC NO. M96791)

Dear Mr. Randolph:

t 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 oseipressurization of p1)ing could occur. By letters dated January 28. 1997, as supalemented Octo)er 17, 1997, you submitted your 120 day response to GL 96 06. T1e 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 licensees have indicated that it would be prudent to take more time to better understand the specific concerns that have been identified in order to optimize 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 resolution of the overpressurization of piping issue, dnd (4) questions regarding the staff's closure of Generic Safety issue 150, *0verpressurization 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 licensees take to resolve the GL 96-06 issues.

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9711210244 971113 PDR ADOCK 05000483 P PDR

Mr. Garry L. Randolph 2 November 13, 1997 ,

Licensees are res>onsible for assessing equipment operability determining actions and esta)lishing 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 s1gnificance associated with the s>ecific nonconformances or degraded .

conditions that have been identified. risc insights, and the time required to complete any generic initiatives and/or )lant-specific actions (e.g., engineering evaluations, design clange 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. t 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, 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 licensees can use the ASME Code.

Section 111. Appendix f. criteria for interim operability determinations for degraded and nonconforming piping and 31pe supports until permanent actions have been identified and approved by tie 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 farilitate resolution of the GL 96-06 1ssues, the NRC will participate in a Jublic worksho) on this topic laier this fall. The workshop proceedings will ye summarized )y 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 L

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l Mr. Garry L. Randolph -3 t;ovember 13, 1997 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) 415-3456.

Sincerely.

Original Signed By  ;

t 4 Barry C. Westreich, Project Manager -

Project Directorate IV-2 -

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Division of Reactor Projects - Ill/IV Office of Nuclear Reactor Regulation Docket No. 50-483 )lSTRIBUTLON:

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Professional Nuclear Mr. Otto L. Maynard Consulting. Inc. President and Chief Executive Officer 19041 Raines Drive Wolf Creek Nuclear Operating Corporation Derwood, Maryland 20855 P.O. Box 411 Burlington. Kansas 66839

-Gerald Charnoff, Esq.

Mr.-Dan I. Bolef. President Thomas A. Baxter. Potts Esq& TrowbridgeKay Drey, Representative Shaw. Pittman.

2300 N. Street. N.W. Board of Directors Coalition Washington D.C. 20037 for the Environment 6267 Delmar Boulevard Mr< H. D. Bono University City. Missouri- 63130 Supervising Engineer Quality Assurance Regulatory Support Mr. Lee Fritz Union Electric Company Presiding Comissioner Post Office Box 620 Callaway County Court House Fulton, Missouri -65251 10 East Fifth Street Fulton. Missouri 65151 U.S. Nuclear Regulatory Commission Resident Inspector Office Mr. Alan C. Passwater. Manager

-8201 NRC Road Licensing and Fuels Steedmanc Missouri . 65077 1302 Union Electric Company Post Office Box 66149 Mr. J. V. Laux. Manager St. Louis, Missouri 63166 6149 Quality Assurance Union Electric Company Post Office Box 620 fulton, Missouri 65251 Manager - Electric Department Missouri Public Service Commission 301 W. High Post Office Box 360 Jefferson City. Missouri 75102 Regional Administrator. Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavilion 611 Ryan Plaza Drive. Suite 400 Arlington. Texas 76011-8064 Mr. Ronald A. Kucera. Deputy Director De)artment of Natural Resources P.O. Box 176

. Jefferson City. Missouri 65102 4

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