HNP-08-006, License Renewal Application - Response to Request for Additional Information Related to Scoping of Main Feedwater Regulating Valves

License Renewal Application - Response to Request for Additional Information Related to Scoping of Main Feedwater Regulating Valves

ML080290646
Person / Time
Site:	Harris
Issue date:	01/22/2008
From:	Natale T Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
HNP-08-006
Download: ML080290646 (5)

Text

,Progress Energy SERIAL: IINP-08-006 JAN 2 2 2008 10 CFR 54 U. S. Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555

Subject:

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. I DOCKET NO. 50-400 / LICENSE NO. NPF-63 LICENSE RENEWAL APPLICATION - RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO SCOPING OF MAIN FEEDWATER REGULATING VALVES

References:

1. Letter from Cornelius J. Gannon to the U. S. Nuclear Regulatory Commission (Serial: HNP-06-136), "Application for Renewal of Operating License," dated November 14, 2006

2. Letter from Maurice Heath (NRC) to Robert J. Duncan II, "Request for Additional Information for the Review of the Shearon Harris Nuclear Power Plant, Unit 1, License Renewal Application," dated January 14, 2008

3. Letter from Thomas J. Natale to the U. S. Nuclear Regulatory Commission (Serial: HNP-07-122), "Responses to Requests For Additional Information -

License Renewal Application - Additional Questions Related to Scoping and Screening Methodology and Results," dated September 18, 2007 Ladies and Gentlemen:

On November 14, 2006, Carolina Power & Light Company, doing business as Progress Energy Carolinas, Inc. (PEC), requested the renewal of the operating license for the Shearon Harris Nuclear Power Plant, Unit No. 1, also known as the Harris Nuclear Plant (HNP), to extend the term of its operating license an additional 20 years beyond the current expiration date.

By letter dated January 14, 2008, the Nuclear Regulatory Commission provided a request for additional information (RAI) concerning the HNP License Renewal Application (LRA). The RAI involves License Renewal scoping of the Main Feedwater Regulating Valves (FRVs).

PEC responded to a previous RAI that involved scoping of the FRVs by letter dated September 18, 2007. The enclosure to this letter provides the additional information requested by the NRC staff.

Progress Energy Carolinas, Inc.

Harris Nuclear Plant P.O.Box 165 4z(,

Now Hill, NC 27562

Document Control Desk HNP-08-006 / Page 2 Please refer any questions regarding this submittal to Mr. Roger Stewart, Supervisor -

License Renewal, at (843) 857-5375.

I declare, under penalty of perjury, that the foregoing is true and correct (Executed on JAN 2 2 2008 )"

Sincerely, Thomas J. Natale Manager - Support Services Harris Nuclear Plant TJN/mhf

Enclosure:

Response to Request for Additional Information dated January 14, 2008 cc:

Mr. P. B. O'Bryan (NRC Senior Resident Inspector, HNP)

Ms. B. 0. Hall (Section Chief, N.C. DENR)

Mr. M. L. Heath (NRC License Renewal Project Manager, HNP)

Mr. V. M. McCree (NRC Acting Regional Administrator, Region II)

Ms. M. G. Vaaler (NRC Project Manager, HNP)

HNP-08-006 Enclosure Page I of 3 Response to Request for Additional Information dated January 14, 2008

Background

On November 14, 2006, Carolina Power & Light Company (CP&L), doing business as Progress Energy Carolinas, Inc., requested the renewal of the operating license for the Shearon Harris Nuclear Power Plant, Unit No. 1, also known as the Harris Nuclear Plant (HNP), to extend the term of its operating license an additional 20 years beyond the current expiration date.

By letter dated January 14, 2008, the Nuclear Regulatory Commission provided a request for additional information (RAI) concerning the HNP License Renewal Application (LRA). The RAI involves License Renewal scoping of the Main Feedwater Regulating Valves. This enclosure provides the additional information requested by the NRC staff.

NRC RAI 2.3.4.6-2 In a letter dated September 18, 2007, the applicant responded to one of the NRC staff's request for additional information (RAI) on the classification of components (RAI 2.1.1.2-1).

Specifically, the applicant states that the feedwater regulating valves in the turbine building did not meet the license renewal definition for safety-related. The applicant's justification is that the regulating valves were not designed to seismic Category I requirements; therefore, they are not safety-related. (It is noted that the response to RAI 2.1.1.2-1 stated that the feedwater regulating valves are located in areas of the Turbine Building that are not designed to Seismic Category I requirements. The feedwater regulating valves are designed to ASME Section III, Class 3, Seismic Category I requirements.) However, the applicant's Final Safety Analysis Report (FSAR) Section 10.4.7 states that these components are designed to seismic Category I criteria and these components have a specific safety function, as defined in Section 15.1.5, to provide redundant feedwater isolation.

The License Renewal Application (LRA), Section 2.3.4.6, Feedwater System, states, "The system serves no safety function, with the exception of containment isolation integrity, and is, therefore, generally classified as non-safety related. The portion of the system classified as safety-related is the portion from the feedwater header check valves to the Steam Generators."

As stated above, the FSAR states that these regulating valves do provide an important safety function. Section 2.3.4.6 of the LRA contradicts the FSAR in stating that this system does not provide any other safety function besides containment integrity.

Based upon the available information, the NRC staff understands that the information in the current licensing basis substantiates that the feedwater regulating valves do provide a safety-related function, (i.e., mitigates the consequences of an accident in accordance with 10 CFR 54.4(a)(1)(iii)). Accordingly, the applicant should either include the feedwater regulating valves in the scope of license renewal and subject then to aging management based upon criterion 10 CFR 54.4(a)(1) or provide an adequate justification for exempting the valves.

In addition, the applicant should provide an evaluation of other feedwater components, (e.g.,

backup isolation valves, and feedwater pump discharge valves) included in this FSAR

HNP-08-006 Enclosure Page 2 of 3 description with the intended function of providing redundant feedwater isolation to determine whether they are included in the scope of license renewal or provide a justification for exempting the components. Finally, pursuant to 10 CFR 54.21 (a), the applicant should identify components surrounding the above-mentioned 10 CFR 54.4(a)(1) components that would fall within the scope of license renewal pursuant to 10 CFR 54.4(a)(2) and subject to an aging management review.

RAI 2.3.4.6-2 Response The Main Feedwater Regulating Valves (and associated Bypass Valves) have been treated in HNP's Current Licensing Basis (CLB) as Non-Safety Related components that serve as a backup to the Main Feedwater Isolation Valves in the Steam System Piping Failure Accident Analysis.

The Main Feedwater Regulating Valves, which are also called the Feedwater Flow Control Valves, are designed to meet ASME Section III, Class 3, and Seismic Category I requirements to ensure reliability. The following describes the salient points in HNP's CLB that supports this conclusion.

As part of the steam generator replacement/power uprate project, the NRC requested (See Question 4 in NRC letter dated March 27, 2001, Accession Number ML010860456) that HNP:

Provide a list of the systems or components that are non-safety-related and credited in the accident analysis. For each of these non-safety-related equipment, provide justification to show the acceptability of its use for consequence mitigation during a transient. Also, item (c)2(ii)(C) of TitlelO of the Code of Federal Regulations (10 CFR) Section 50.36 requires a technical specification (TS) for the systems or components that are used for event mitigation. Accordingly, the licensee is requested to provide the required TS.

The HNP response to this question was provided in Letter Serial I-INP-01-102, dated July 16, 2001, Accession Number ML012040306, and included the following discussion:

As noted in the CP&L response to Question 14 (submitted by CP&L letter HNP-01-078, dated June 11, 2001), the non-safety Main Feedwater Flow Control Valves serve as "backup" to the Main Feedwater Isolation (Block) Valves. HNP credits the Main Feedwater Flow Control and Flow Control Bypass Valves to be available to manually isolate and terminate the main feedwater flow, which is consistent with the current licensing basis and the staff position documented in the HNP SER (NUREG-103 8).

The Main Feedwater Flow Control Valves and Flow Control Bypass Valves are classified as Seismic Category I, Quality Group D. These valves are classified as Quality Group D, since they are installed in influent lines and are capable of being isolated from the reactor coolant pressure boundary by an additional valve, the Main Feedwater Isolation Valve (MFIV), which has high leak tight integrity (Ref.: Reg. Guide 1.26). These valves are connected to Non-seismic Category I piping in the Turbine Building and serve as redundant feedwater line isolation designed to fail in the closed position, which with reference to the SER (NUREG-1038), serves as an acceptable backup. The Feedwater Control Valves and the Feedwater Control Bypass Valves are not installed in safety grade

H-INP-08-006 Enclosure Page 3 of 3 piping, but they are important to safety because they act as a backup to the main feed isolation valves during a steam line rupture (Ref.: FSAR 15.1.5.1c). These valves are not expected to remain functional during and/or after a seismic event, since failures of secondary system piping and earthquakes are not required by the NRC to occur simultaneously with each other; i.e., loss of non-safety equipment due to an SSE event is not assumed coincident with a spontaneous steam line break accident. Reliance on the non-safety grade valves in the postulated accident evaluation (Ref.: FSAR 15.1.5.1c) is permitted based on the reliability of these valves. The rationale for dependence on these "non-safety grade" Feedwater Control Valves is that they are high quality components since they are built to ASME Section III, Class 3, Seismic Category I requirements.

Based on the above discussion and information as documented in NUREG-0138, "Staff Discussion Memorandum from Director, NRR to NRR Staff," the feedwater control valves and feedwater bypass control valves are not required to be seismically qualified in their installed condition.

Therefore, HNP has adequate assurance that highly reliable means of isolating feedwater will be available and effective.

The above referenced letter (Serial HNP-01-102) is included by reference in the NRC's issuance of the amendment for the steam generator replacement and power uprate at HNP, TAC Nos.

MB0199 and MB0782, dated October 12, 2001, Accession Number ML012830516.

In addition, NUREG-0138, "Staff Discussion of Fifteen Technical Issues Listed in Attachment to November 3, 1976 Memorandum from Director, NRR to NRR Staff," Issue 1, includes an analysis of the treatment of non-safety grade equipment in evaluations of postulated steam line break accidents. On page 1-11 it states:

Thus, the staff believes that it is acceptable to rely on these non-safety grade components in the steam and feedwater systems because their design and performance are compatible with the accident conditions for which they are called upon to function. It is the staff position that utilization of these components as a backup to a single failure in safety grade components adequately protects the health and safety of the public.

Based on the preceding discussion, the License Renewal conclusion that these components are important to safety but not safety-related and meet the criteria of 10 CFR 54.4(a)(2) is consistent with the Current Licensing Basis.