ML062710539

Memo 09/28/06 Request for Technical Assistance - Appendix R Disputed Violations Regarding Quad Cities Nuclear Power Station (TIA 2006-005)

ML062710539
Person / Time
Site:	Quad Cities
Issue date:	09/28/2006
From:	Pederson C Division of Reactor Safety III
To:	Ho Nieh NRC/NRR/ADRA/DPR
References
TIA 2006-005
Download: ML062710539 (4)

Text

September 28, 2006MEMORANDUM TO:Ho K. Nieh, Acting Division DirectorDivision of Policy and Rulemaking Office of Nuclear Reactor RegulationFROM:Cynthia D. Pederson, Director /RA/Division of Reactor Safety

SUBJECT:

REQUEST FOR TECHNICAL ASSISTANCE - APPENDIX RDISPUTED VIOLATIONS REGARDING QUAD CITIES NUCLEAR POWER STATION (TIA 2006-005) Region III requests NRR assistance in the review of the Quad Cities Nuclear Power Station's(QCNPS) response to two NRC Non-Cited Violations (NCV) regarding compliance with10 CFR Part 50 Appendix R requirements. NRR review of the licensee's response will supportthe Region III evaluation and formal response to the licensee's contestment of the findings. Furthermore, Region III believes that these two non-cited violations raise several questions thatare of generic nature and have implications on future resolution of issues.Specifically, the Region III office requests NRR review and evaluation of the licensee'sresponse relating to:*reliance upon the safe shutdown makeup pump (SSMP), for the purpose ofmeeting 10 CFR Part 50 Appendix R, III.G.2 requirements, without prior NRCreview and approval; and*reliance upon the residual heat removal service water (RHRSW) systemmulti-unit cross-tie capability, for the purpose of meeting 10 CFR Part50 Appendix R, III.G.2 requirements, without prior NRC review and approval.NRR review is requested due to the complexities involving 10 CFR Part 50 Appendix Rrequirements and potential wide-ranging implications resulting from the conclusions of the review of the licensee's response. CONTACT:J. Lara, DRS(630) 829-9731 BackgroundQCNPS has contested two NCVs identified during the 2006 triennial fire protection inspection. Please refer to the associated NRC inspection report and licensee's response for detailedbackground and analysis regarding these two NCVs. The two NCVs were documented in inspection report 05000254(265)/2006002 (ML062140118). The licensee's basis for contesting the Non-Cited Violations are documented in a letter dated August 31, 2006 (ML062560198). With respect to the SSMP finding, the SSMP system was originally installed as a dedicatedshutdown system, and therefore, the system was required to meet the regulations in Appendix R,Section III.G.3. The licensee subsequently maintained compliance with10 CFR Part 50 Appendix R,Section III.G.2 based on the SSMP and reactor core isolationcooling (RCIC) being redundant. The licensee maintains that the systems m eet therequirements to be considered redundant si nce the systems perform the same designfunctions. We note, however, that t he system redundancy is limited to the inventory makeupfunction for a fire event. Since the SSMP system would only be used for inventory makeup,plant safe shutdown would also require the use of other systems to perform the overall samesystem function as RCIC. With respect to the RHRSW finding, the licensee maintains that for multiple unit plants, systemsshared between units may be credited as redundant for each unit. Accordingly, the licensee relies upon the opposite unit RHRSW system, through a locally-operated system cross-tievalve, for the purposes of meeting 10 CFR Part 50 Appendix R, Section III.G.2 requirement toensure that at least one redundant train of a system is available to support safe shutdown.Requested ActionReview the licensee's response to the issued NRC inspection report findings and provideanswers to the following specific questions:With respect to NCV 05000254(265)/2006002-01:1.Can licensees perform a 10 CFR 50.59 evaluation (or other equivalent adverseeffects evaluation) for fire protection program changes which result in changing a previously approved "alternate/dedicated" Safe Shutdown system to a"redundant" system? If not, please identify what regulatory tool precludes thelicensee from making such a change and how we have communicated this expectation to licensees2.If such evaluation processes can be utilized, what is the system design criteriawhich licensee's must meet to rely upon these systems as "redundant" for thepurposes of meeting 10 CFR 50, Appendix R, III.G.2 requirements? 3.For Boiling Water Reactors, what systems can licensees appropriately classifyas "preferred" for the purposes of meeting 10 CFR 50, Appendix R, III.G.2requirements? For those systems, has the NRC defined the design or functionalrequirements for systems to be classified as "preferred"? 4.With respect to the Quad Cities NCV and licensee response, can the licenseeclassify the safe shutdown makeup pum p system (SSMP), as redundant to thereactor core isolation cooling system (RCIC) for the purposes of meeting 10 CFR Part 50 Appendix R, III.G.2?

5.With respect to the Quad Cities NCV and licensee response, does the licensee'sposition asserting compliance with 10 CFR 50 Appendix R, III.G.2 have meritand thereby warrant withdrawal of the NCV? With respect to NCV 05000254(265)/2006002-02:6.Can licensees perform a 10 CFR 50.59 evaluation (or other equivalent adverseeffects evaluation) for fire protection program changes which result in reliance on a multi-unit cross tie capability for the purpose of meeting10 CFR Part 50 Appendix R, III.G.2? If not, please identify what regulatory toolprecludes the licensee from making such a change and how we have communicated this expectation to licensees7.With respect to the Quad Cities NCV and licensee response, for the residualheat removal service water (RHRSW) system configuration, can the licensee relyupon the multi-unit cross-tie capability (previously relied upon for meeting10 CFR Part 50 Appendix R, III.G.3), for the purpose of meeting10 CFR Part 50 Appendix R, III.G.2? 8.With respect to the Quad Cities NCV and licensee response, does the licensee'sposition asserting compliance with 10 CFR 50 Appendix R, III.G.2, throughreliance upon the multi-unit cross-tie capability, have merit and thereby warrantwithdrawal of the NCV? CoordinationThis request was discussed between Julio Lara of Region III and Sunil Weerakkody of NRRduring a telephone conference on September 27, 2006. It was agreed that NRR would acceptthis issue as a Task Interface Agreement and respond to this request by November 3, 2006.Docket No. 50-254; 50-265 cc:J. Honcharik, NRRC. Pederson, DRS J. F. Lara, DRS K. O'Brien, EICS CoordinationThis request was discussed between Julio Lara of Region III and Sunil Weerakkody of NRRduring a telephone conference on September 27, 2006. It was agreed that NRR would acceptthis issue as a Task Interface Agreement and respond to this request by November 3, 2006. Docket No. 50-254; 50-265 cc:J. Honcharik, NRRC. Pederson, DRS J. F. Lara, DRS K. O'Brien, EICSDOCUMENT NAME:E:\Filenet\ML062710539.wpd G Publicly Available G Non-Publicly Available G Sensitive G Non-SensitiveTo receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copyOFFICERIIIRIIIRIIIRIIINAMEJLara:jbCPederson DATE9/28/069/28/06OFFICIAL RECORD COPY