Text

Nine-Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems.
	ML082910295
Person / Time
Site:	Harris
Issue date:	10/14/2008
From:	Burton C; Progress Energy Carolinas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GL-08-001, HNP-08-098
	Download: ML082910295 (23)
	v • d • e

Progress Energy Christopher L Burton Vice President Harris Nuclear Plant Progress Energy Carolinas, Inc.

OCT[ 1 4 208 Serial: HNP-08-098 10 CFR 50.54(f)

U.S. Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS"

References:

1. NRC Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," dated January 11, 2008

2. Letter from R. J. Duncan to the Nuclear Regulatory Commission (Serial:

HNP-08-047), "Three Month Response to NRC Generic Letter 2008-01,

'Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems,"' dated May 09, 2008

3. Letter from M. G. Vaaler, Nuclear Regulatory Commission to C. L.

Burton, "Shearon Harris Nuclear Power Plant, Unit 1 - Generic Letter 2008-01, 'Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems,' Proposed Alternative Course of Action," dated August 08, 2008

4. Letter from W. H. Ruland, Nuclear Regulatory Commission to J. H. Riley (Nuclear Energy Institute), dated July 08, 2008 (ML081830557)

Ladies and Gentlemen:

The Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01 (Reference

1) to request that each licensee evaluate the licensing basis, design, testing, and corrective action programs for the Emergency Core Cooling Systems (ECCS), Residual Heat Removal (RHR) system and Containment Spray (CS) system, to ensure that gas accumulation is maintained less than the amount that challenges operability of these systems, and that appropriate action is taken when conditions adverse to quality are identified.

GL 2008-01 requested each licensee to submit a written response in accordance with 10 CFR 50.54(f) within nine months of the date of the GL to provide the information summarized below:

P.O.Box 165 New Hill, NC27562 T> 919.362.2502 F> 919.362.2095

HNP-08-098 Page 2

"(a) A description of the results of evaluations that were performed pursuant to the requested actions; (b) A description of all corrective actions, including plant, programmatic, procedure, and licensing basis modifications that were determined to be necessary to assure compliance with the quality assurance criteria in Sections III, V, XI, XVI, and XVII of Appendix B to 10 CFR Part 50 and the licensing basis and operating license as those requirements apply to the subject systems; and, (c) A statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule."

In summary, Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc. (PEC), has concluded that the subject systems/functions at the Harris Nuclear Plant (HNP) are in compliance with the TS definition of Operability, i.e., capable of performing their intended safety function and that HNP is in compliance with current licensing and design bases and applicable regulatory requirements with respect to gas accumulation concerns outlined in GL 2008-01.

In Reference 2, HNP committed to completing its assessments, (e.g., walkdowns and supporting ultrasonic inspections) of the inaccessible portions of these systems at HNP during the next Refueling Outage. As previously approved by the NRC (Reference 3), a supplement to this report containing those results will be submitted to the NRC within 90 days of startup from that outage. Based on completed design reviews and site operating experience, there is reasonable assurance that the inaccessible portions of these systems are operable, and the follow-on actions are confirmatory in nature.

The attachments to this letter contain HNP's nine-month response to NRC GL 2008-01.

Regulatory commitments associated with this submittal are contained in Attachment 2.

Please refer any questions regarding this submittal to Mr. Dave Corlett at (919) 362-3137.

I declare, under penalty of perjury, that the foregoing is true and correct (Executed on OCT 1 4 2008 ).

Sincerely, Christopher L. Burton Vice President Harris Nuclear Plant CLB/kms

HNP-08-098 Page 3 Attachments: 1. NRC Generic Letter 2008-01 Requested Information for a Nine-Month

Response

2. Regulatory Commitments cc: Mr. K. J. Korth, Acting NRC Senior Resident Inspector, HNP Mr. L. A. Reyes, NRC Regional Administrator, Region II Ms. M. G. Vaaler, NRR Project Manager, HNP

Attachment 1 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" This Attachment contains the Harris Nuclear Plant (HNP) nine-month response to NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," dated January 11, 2008. In this GL, the NRC requested "that each addressee evaluate its ECCS, DHR system, and containment spray system licensing basis, design, testing, and corrective actions to ensure that gas accumulation is maintained less than the amount that challenges operability of these systems, and that appropriate action is taken when conditions adverse to quality are identified."

The following information is provided for HNP in this response:

a) A description of the results of evaluations that were performed pursuant to the requested actions (see Section A of this Attachment),

b) A description of the corrective actions determined necessary to assure compliance with the quality assurance criteria in Sections III, V, XI, XVI, and XVII of Appendix B to 10 CFR Part 50 and the licensing basis and operating license with respect to the subject systems (see Section B of this Attachment), and c) A statement regarding which corrective actions have been completed, the schedule for the corrective actions not yet complete, and the basis for that schedule (see Section C of this Attachment).

The following systems were determined to be in the scope of GL 2008-01 for HNP:

" Emergency Core Cooling System (ECCS)

Residual Heat Removal System (RHR)

Containment Spray System (CS)

Background

In 2000, Significant Adverse Condition Investigation, Nuclear Condition Report (NCR)

H17895, was performed to address HNP's response to the Institute for Nuclear Power Operation (INPO) Area for Improvement (AFI) EN.2-2. Per this AFI, the design weaknesses in the High Head Safety Injection (HHSI) system were not sufficiently evaluated or pursued to resolution. Item 3 of the INPO AFI on the HHSI system identified that the potential for gas desorption caused by flow through the Charging/Safety Injection Pumps (CSIP) mini-flow recirculation line orifices had not been fully evaluated in response to Significant Operating Experience Report (SOER) 97-1.

In response to this AFI, gas stripping associated with the mini-flow recirculation orifices and gas in-leakage from other systems were reviewed and evaluated for HNP applicability and assignment of corrective actions. Corrective actions associated with this investigation included a plant modification for the CSIP mini-recirculation piping and performance of periodic ultrasonic testing (UT) on systems for gas voids.

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Attachment 1 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" Following the discovery of a gas void on the Charging/Safety Injection system in 2002, a Significant Adverse Investigation, NCR #58670, was performed. The gas void was discovered during ultrasonic testing of the ECCS piping following a plant shutdown after the Residual Heat Removal (RHR) system was secured and Low Head Safety Injection (LHSI) was aligned in the ECCS mode. Corrective actions from this investigation included the installation of thirteen new vents on the ECCS piping, procedure changes, and training for plant personnel related to gas desorption which was determined to be the cause of this gas void event.

HNP currently has in place an existing Technical Specification (TS) Surveillance Requirement (SR) to perform monthly venting of discharge piping of the ECCS. The plant surveillance implementing procedure includes acceptance criteria, directs actions when a void is discovered and provides a threshold for initiating a NCR. Gas voids located in safety related systems are initially classified as non-conforming conditions and the events are entered into the Corrective Action Program (CAP). These condition reports provide documentation of the system operability assessments and the root or apparent causes of these gas intrusion events.

A. EVALUATION RESULTS Licensing Basis Evaluation The HNP licensing basis was reviewed with respect to gas accumulation in the ECCS, RHR, and CS Systems. This review included the TS, TS Bases, Final Safety Analysis Report (FSAR), Regulatory Commitments and License Conditions.

1. Summary of licensing basis review results:

The above documents were evaluated for compliance with the applicable regulatory requirements. The discovery of gas voids in these systems would result in the initiation of an operability determination, in which the ability of the affected system to perform its safety function would be evaluated. To demonstrate operability of each ECCS subsystem, SR 4.5.2.b requires verification at least once per 31 days that the ECCS piping is full of water by venting accessible discharge piping high points. The TS SR bases do not address SR 4.5.2.b with respect to gas accumulation and periodic venting. TS SR 4.5.2.b, as implemented by plant procedures on a monthly basis, requires the ECCS pump discharge piping to be periodically vented.

The LHSI and HHSI systems are periodically vented on a monthly interval to satisfy TS SR 4.5.2.b. The vent locations prescribed in the surveillance procedure include the LHSI and HHSI pumps discharge piping. Piping is vented from several locations on each of the LHSI and HHSI pump discharge piping flow paths.

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Attachment 1 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" The FSAR includes discussions of the ECCS switchover phase to demonstrate the transfer from the Refueling Water Storage Tank (RWST) during ECCS injection to the containment building sumps when recirculation occurs and that the ECCS pumps' suction flow paths are maintained. The FSAR states: "the ECCS piping is designed such that normal system operation and testing assures that the systems remain water-filled to preclude the effects of water hammer." Additionally, per the FSAR: "[s]hould significant leakage be discovered, where an introduction of air into the system could have occurred, provisions have been made in the system design to permit refilling and venting of the affected components or piping following repair to the source of leakage."

2. Summary of changes to licensing basis documents TS improvements are being addressed by the Technical Specifications Task Force (TSTF) to provide an approved TSTF Traveler for making changes to individual licensee's TS related to the potential for unacceptable gas accumulation. The development of the TSTF Traveler relies on the evaluation results of a large number of licensees to address the various&plant designs. HNP is continuing to support the industry and the NEI Gas Accumulation Management Team activities regarding the initiation of generic TS changes via the TSTF Traveler process. After NRC approval of the TSTF Traveler, HNP will evaluate its applicability and determine the feasibility of adopting the changes identified in the TSTF Traveler to supplement or replace current TS requirements.

Potential TS changes may be necessary to reflect the improved understanding achieved during the GL 2008-01 submittals based on the industry analysis of the results. If applicable to HNP, a License Amendment Request incorporating changes identified in the TSTF Traveler will be submitted to the NRC within 9 months after NRC's approval of the TSTF Traveler (Reference Attachment 2, Item No. 7).

HNP did not identify any existing TS weaknesses resulting from this GL evaluation.

Therefore, no short-term corrections to the TS are required to be implemented prior to the completion of the on-going long-term generic program regarding new and improved TSs addressing gas accumulation issues (Reference 4).

Design Evaluation The HNP design basis was reviewed with respect to gas accumulation in the ECCS, RHR, and CS Systems. This review included Design Basis Documents, Calculations, Engineering Evaluations, and Vendor Technical Manuals.

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Attachment 1 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS"

1. Summary of design basis document review HNP's design basis review for the subject systems identified no deficiencies associated with implementation of existing design basis requirements. The systems are designed, tested, and operated in accordance with HNP's regulatory commitments.

The following are specific design features included in this review:

The CS system piping in Containment is full up to approximately the 300' level. The piping above this level, up to the ring headers at elevations 404', 419', and 435', was designed as a voided portion of the CS system. Based on a conservative calculation and comparison of force imbalance vs. piping dead weight (PWROG methodology FAI 08/78), the force imbalance on the spray ring header piping on CS system startup would be within the margin of the existing piping hangers. Therefore, water hammer effects due to this voided piping in Containment are not a concern for HNP.

RWST level instrumentation ensures a sufficient supply of borated water is maintained available for injection into the core by the ECCS. The limits on RWST minimum volume assure that sufficient water will be transferred to containment to permit recirculation cooling flow to the core. When the RWST reaches the Lo-Lo level setpoint, the LHSI (RHR) pumps change from the injection mode, with suction from the RWST, to the recirculation mode, with suction from the containment sump. Operator action is then required to align the HHSI (CSIP) suction to the discharge of the LHSI (RHR) pumps and to isolate the RWST.

Operation of the HHSI (CSIP) pumps is continued in the recirculation mode to ensure long-term core cooling.

The LHSI (RHR) pumps are aligned during normal operationto take suction from the RWST and discharge through the RHR Heat Exchangers to the Reactor Coolant System (RCS) cold legs. In an accident, when the RWST reaches the Lo-Lo level setpoint, the containment sump supply valves to the suction of the LHSI (RHR) pump automatically open. Operator action is then required to isolate the RWST to the LHSI (RHR) pump suction and to align the HHSI (CSIP) suction to the discharge of the LHSI (RHR) pumps. During the recirculation phase, the LHSI (RHR) pumps supply water to the HHSI (CSIP) and, if the reactor coolant pressure is low enough, to the RCS.

The containment recirculation sumps are designed to guard against debris-induced clogging.

LHSI and CS system pump intake within each sump are located to minimize degrading effects such as vortexing and gas dissolution on the pump performance. The sumps are located at the lowest points inside containment, allowing drainage of containment spray water and RCS outflow to the recirculation sumps. The recirculation sump strainers consist of a total of 136 (68 per sump) high performance top hat style assemblies that provide a total net effective surface area of approximately 6,000 ft 2 (3000 ft 2per sump). A vortex A-4

Attachment 1 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-0 1, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" suppressor made from standard floor grating is installed above the vertical top hat modules in each recirculation sump to prevent air from being drawn into the top hat modules.

Site design calculations address the plant design and control features of the ECCS and CS systems that minimize or demonstrate that vortexing of the ECCS and CS system pumps do not occur during the injection phase. These documents demonstrate there is sufficient RWST level during injection to maintain adequate net positive suction head (NPSH) margin prior to reaching the RWST Lo-Lo level setpoint. The HNP GL 2008-01 analysis determined that a summary of this information should be added to the system Design Basis Documents (DBDs). Therefore, DBD-104, "Safety Injection System," and DBD-106, "Containment Spray System," will be revised to include a discussion of the design features for each system that prevent vortexing of the ECCS and CS system pumps during the injection and recirculation phase (Reference Attachment 2, Item No. 4).

Whenever a reduced inventory condition is established during outages, a specific operating procedure is utilized to ensure all Generic Letter 88-17, "Loss of Decay Heat Removal,"

requirements including alarms, indications and RHR pump flow limitations have been established before commencing RCS draindown to mid-loop levels.

There are no keep fill systems associated with LHSI, HHSI or the CS system and no keep fill systems are required to be added as a result of this GL evaluation.

2. New gas volume acceptance criteria Location-specific void volume acceptance criteria have generally not been established for HNP. As an alternative, identified gas voids are entered into the CAP where they are evaluated for impact on system operability. However, location-specific acceptance criteria have been established for a select number of locations, primarily where previous gas voiding has been identified. It is expected that additional acceptance criteria will be developed for locations potentially susceptible to gas accumulation, which will preclude the need for entering identified gas voids into the CAP. Until such acceptance criteria are developed, the CAP will be used to disposition discovered voids. Recently published industry guidance will be considered when either evaluating operability or establishing acceptance criteria. This guidance, which is summarized below, will be supplemented as necessary when evaluating locations/conditions not covered by the industry guidance, ensuring all relevant limitations are assessed.

a. Pump Suction Piping The interim allowable gas accumulation in the pump suction piping is based on limiting the gas entrainment to the pump after a pump start. A Pressurized Water Reactor Owners Group (PWROG) program established interim pump gas ingestion limits to be employed by the member utilities. The interim criteria address pump mechanical A-5

Attachment 1 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" integrity only and are as follows:

Single-Stage Multi-Stage Multi-Stage Stiff Shaft Flexible Shaft Steady-State 2% 2% 2%

Transient 5% for 20 sec. 20% for 20 sec. 10% for 5 sec.

QBEP Range 70%-120% 70%-140% 70%-120%

Pump Type WDF CA RLIJ, JHF (transient data) I _I These conservative criteria will be applied in support of system operability determinations and development of interim acceptance criteria until further data either substantiates the values or supports a change. These criteria, used in conjunction with other factors such as net positive suction head requirements (NPSHR) and accidents for which the system is credited, provide a basis for system operability.

b. Pump discharge piping susceptible to pressure pulsation A joint Owner's Group program evaluated pump discharge piping gas accumulation.

Gas accumulation in the piping downstream of the pump to the first closed isolation valve will result in amplified pressure pulsations after a pump start. The method uses plant specific information for piping restraints and relief valve set points to determine acceptable gas volumes such that relief valve lifting does not occur and that pipe loading remains within acceptable limits. This, or similar methodology, will be applied by HNP in support of system operability determinations and development of acceptance criteria.

c. Pump discharge piping not susceptible to pressure pulsation

1) The PWROG methodology for CS evaluates the piping response as the CS header is filled and compares the potential force imbalances with the weight of the water-filled piping. The methodology concluded that the net force resulting from the pressurization of the CS header during the filling transient is expected to be a fraction of the dead weight of the filled piping, and therefore well within the margin of the pipe hangers. As discussed in the design basis document review section of this response, this methodology was applied at HNP with expected and acceptable results.

2) The PWROG methodology to assess when a significant gas-water water hammer could occur during switchover to hot leg injection is applicable to HNP LHSI, but is not applicable to HHSI since the hot leg injection flow paths include throttled valves by design. The hot leg injection flow paths, used for mitigation of boron precipitation in the core during the switchover from cold leg injection to hot leg injection, are tested on a periodic basis. HNP performs full flow testing of these flow paths per the A-6

Attachment 1 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" Inservice Testing (IST) program. There has not been a water hammer occurrence in these lines during HNP operational history, indicating a potentially damaging water hammer gas void is not likely to occur. In addition, the drawing reviews of the HHSI hot leg injection flow paths have not revealed potential gas accumulation locations, which could lead to a gas void of a size that would potentially create a damaging water hammer event.

d. RCS allowable gas ingestion The PWROG qualitatively evaluated the impact of non-condensable gases entering the RCS on post-accident core cooling functions of the RCS. This evaluation assumed that 5 cubic feet of non-condensable gas at 400 psia was present in the HHSI discharge piping concurrent with 5 cubic feet of non-condensable gas at 100 psia in the LHSI discharge piping. The qualitative evaluation concluded that these quantities of gas will not prevent the ECCS from performing its core cooling function' HNP will use these gas volumes in support of system operability determinations and development of acceptance criteria. In the absence of system- or location-specific acceptance criteria for HNP ECCS and CS system, the proposed interim standard for gas voids will be no air and/or gas allowed. The plant periodic surveillance procedure will be revised to be consistent with this interim standard until specific criterion are developed.

3. Results of drawing reviews Plant piping and instrument diagrams (P&ID), piping isomeric drawings and other piping arrangement drawings were reviewed to identify locations potentially susceptible to gas accumulation. These drawings were also utilized during the detailed system piping walkdowns to confirm the as-built configuration. Potentially susceptible locations were identified and included horizontal piping runs, pipe diameter changes, reducers, pump casings, under closed valves in vertical runs and flow element orifice plates. Unvented potentially susceptible locations were evaluated to determine if installation of a vent was appropriate.

The detailed review of the ECCS and LHSI (RHR) system drawings determined there are an adequate number of vent valves installed for the current TS SR. Additional vent valves may be required if the approved TSTF Traveler requires periodic venting on the ECCS and LHSI (RHR) system suction piping.

4. Results of confirmatory walkdowns Walkdowns of all piping within the scope of the GL that is accessible during normal operation have been completed. The only piping determined as currently "inaccessible" is the HHSI, LHSI and RHR piping located inside the reactor containment building (Reference Corrective Action a as listed in Section C.2). For the CS system, piping downstream of the A-7

Attachment 1 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" normally closed CS pump discharge motor-operated valve was excluded from the walkdown since this piping is partially filled and therefore does not require venting to ensure it is sufficiently full of water. The walkdowns were conducted to verify that design drawings accurately reflected as-built conditions, particularly with respect to gas accumulation potential. The walkdowns also looked for details that may not be included on drawings such as the proper location of vents (e.g., at top-dead-center of horizontal piping, at local high point of nominally horizontal piping), and whether nominally horizontal piping was actually sloped, etc. To assess the latter, the slope of nominally horizontal piping runs was measured to determine if any unvented local high points existed where gas could potentially be trapped or accumulate.

The drawing reviews and supporting detailed system piping walkdowns identified 61 locations potentially susceptible to gas accumulation. UT has been performed and revealed sufficiently full conditions at 58 of 61 locations. The remaining three locations had voids, all on Spray Additive System 2" piping. At two of the locations, voids were expected as a result of planned maintenance at non-ventable piping locations. The sizes of these two voids are acceptable based on criteria developed prior to the maintenance activities. The third. void location was discovered as a result of a condition report investigation unrelated to the GL 2008-01 walkdowns. All of these void locations have been entered into the CAP and the operability determinations found no impact.

It is understood that some areas potentially susceptible to gas accumulation, which might have been full at the time of UT, could have actually contained voids immediately after fill and vent that were subsequently swept away during normal system operation or periodic pump testing. This concern will be addressed by improved system fill and vent practices which are discussed later in this response (Reference Item 6, "Results of the fill and vent activities and procedure review").

Walkdowns of inaccessible piping will be completed during RFO15 as committed in HNP's Three Month Response to GL 2008-01 (Reference 2).

5. Identify new vent valve locations that resulted from the drawing reviews and confirmatory walkdowns.

Based on the drawing reviews, walkdowns, and subsequent evaluation of unvented high points, the following potential new vent location has been identified:

a Spray Additive System tank outlet pipe This new vent valve, which will be installed prior to or during RFO 16, will provide improved vent capability for the Spray Additive system 2" piping. It is not required to demonstrate or to maintain system operability.

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Attachment 1 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" HNP currently has TS SR for ECCS which require periodic venting at accessible discharge piping high points. A review of the corresponding plant surveillance procedure determined that all applicable high point vent locations are used and that all vent locations are accessible.

6. Results of the fill and vent activities and procedure reviews The HNP operating procedures used to fill and vent systems following maintenance were reviewed by Operations and Engineering personnel. An effective method of filling and venting the systems is provided in these procedures. The procedure sequencing is correct and key steps are required to be initialed as the fill and vent process is performed. There are steps included for dynamic venting of systems, specifically the LHSI system, after securing from the shutdown cooling mode of operation. The recommended enhancements for the operating procedures include performing confirmatory UT inspections following maintenance and prior to restoration of system operability.

The operating procedures used for HHSI, LHSI and CS system fill and vent will be revised to include supplemental UT of appropriate piping sections to ensure a sufficiently filled condition is achieved. The UT will be performed prior to restoration of a system to operable following maintenance.

The plant post-maintenance testing (PMT) procedure will also be revised in a similar manner to ensure appropriate confirmatory UT inspections are performed following maintenance activities that require piping to be drained.

In addition, the operating procedures used for HHSI, LHSI and CS system fill and vent will be revised to include a precaution and limitation to ensure an Engineering review has been performed prior to maintenance that requires draining a portion of the system based on the work scope. The intent of the Engineering review is to ensure that the method of system fill and vent following maintenance prevents inadvertent air intrusion and that the operating procedure guidance is sufficient for the work performed.

7. Procedure revisions or new procedures resulting from the fill and vent activities Procedure revisions regarding fill and vent activities will be completed no later than 04/18/09 or prior to first use, which coincides with HNP's next scheduled refueling outage. Based on the procedural controls and favorable UT results, the risk of significant voids being introduced during any maintenance performed before the refueling outage is judged to be acceptably low (Reference Attachment 2, Item No. 1).

8. Potential gas intrusion mechanisms Potential gas intrusion mechanisms for the LHSI system include dissolved gas coming out of solution, back-leakage from the RCS through series check valves and intersystem leakage A-9

Attachment 1 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" through the Safety Injection (SI) test system valves. The operating procedures for securing RHR from shutdown cooling operations and aligning for LHSI include taking gas samples of the LHSI/RHR system. These sample results are then used to determine if dynamic venting is performed.

HHSI system potential gas intrusion mechanisms include dissolved gas coming out of solution from the volume control tank (VCT), SI accumulators and intersystem leakage through the SI test system valves. Per HNP design, CSIP and the downstream SI piping to the normally closed isolation valves outside containment are pressurized from the in-service CSIP at a pressure higher than normal RCS pressure. Therefore, back-leakage from the RCS through series check valves into the HHSI system outside containment is not likely. The SI test line piping would also not provide potential gas accumulation into the HHSI pumps discharge or suction since these lines tie into the SI flow paths inside containment. SI piping located inside the containment building, downstream of the normally closed SI flow path isolation valves, could have gas voids from normally closed leaking SI test line valves.

Although this gas would accumulate at high points, it would not migrate into the upstream side of the SI isolation valves due to the charging pumps operating pressure. The SI accumulators have a separate RCS cold-leg tie-in which minimizes the potential for this gas source causing accumulations in either the LHSI or HHSI systems. Therefore, based on a review of the SI piping drawings, plant operating experience and known periodic flow in these lines during cavity fill and/or check valve testing, there is reasonable assurance that the flow paths for the SI lines in containment are currently operable with respect to voids or gas accumulation. Other than confirmatory walkdowns and UT during RFO 15, no specific actions on the SI lines in containment are proposed at this time.

The CS system has no potential gas intrusion mechanisms from dissolved gas coming out of solution, back-leakage from the RCS through series check valves and intersystem system leakage through the SI test system valves. The only gas source associated with the CS system is the Chemical Addition Tank (CAT) cover gas which could indirectly enter the CS system due to an isolation valve failure to close after the CAT contents are depleted.

However, since the tank cover gas pressure is normally maintained at 1 - 2 psig, this would not be an issue.

Ultrasonic testing of the HHSI and LHSI systems to monitor potential intrusion sources will be a prerequisite of the periodic surveillance procedure for ECCS. The HNP PM program will be used to schedule UT inspections. The plant PM program will also schedule periodic UT inspections of the CS system at selected locations (Reference Attachment 2, Item No. 5).

9. Ongoing Industry Programs Ongoing industry programs in the following areas may impact the conclusions reached during the Design Evaluation of HNP relative to gas accumulation. The activities will be A-10

Attachment 1 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" monitored to determine if additional changes to the HNP design may be required or desired to provide additional margin.

" Gas Transport in Pump Suction Piping The PWROG has initiated testing to provide additional knowledge relative to gas transport in piping. One completed program performed testing of gas transport in 6" and 8" piping. Another program is underway to perform additional testing of gas transport in 4" and 12" piping in low temperature systems and 4" piping in high temperature systems. This program will integrate the results of the 4" through 12" piping testing and develop a scaling model to address even larger diameter pipe.

" Pump Suction Void Fraction Acceptance Criteria Long-term industry tasks were identified that will provide additional tools to address GL 2008-01 with respect to pump gas void ingestion tolerance limits.

In accordance with the guidance provided in Reference 3, the long-term actions associated with the on-going industry assessment regarding the necessity of performing pump testing to determine the allowable limits on ingested gas volume in pump suctions will be tracked by HNP in its CAP. This action item will also track the need to develop the analysis capability to adequately predict void movement (entrapped gas) in pump suction piping.

10. Detailed list of items that have not been completed, a schedule for their completion, and the basis for that schedule, based on the completed Design Evaluation Design Basis - Design Basis Documents for SI and CS systems will be revised to include a discussion of the design features for each system that prevent vortexing of the ECCS and CS system pumps during the injection and recirculation phase. This corrective action will be completed by 01/29/09 (Reference Attachment 2, Item No. 4).

System Walkdowns - Walkdowns of inaccessible piping will be completed during RFO 15 as committed to in HNP's Three-Month Response (Reference 2).

Fill and Vent Review - Operating procedures for HHSI, LHSI and CS system will be revised to include supplemental UT of appropriate piping sections to ensure an adequately filled condition is achieved. A precaution and limitation will be included for Engineering review to ensure system filling and venting is properly planned and that the procedure guidance is sufficient for the work performed. The procedure revisions identified above will be completed no later than 4/18/09 or prior to first use (Reference Attachment 2, Item No. 1).

Gas Intrusion - The plant PM program will be revised to include a requirement for A-1I

Attachment 1 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" periodic verification (every 31 days or longer with supporting justification) that the ECCS pumps suction piping are maintained sufficiently full by performing an UT at locations identified to be potentially susceptible to accumulation of gas over time. This PM program revision will be completed by 12/19/08 (Reference Attachment 2, Item No. 5).

A new requirement for periodic inspections (every 31 days or longer with supporting justification) to verify that the CS system suction piping, CS pumps and discharge piping up to the first normally closed discharge line valve are maintained sufficiently full will be added to the plant PM program. This will be implemented through a combination of UT and venting at selected locations identified to be potentially susceptible to accumulation of gas over time. This PM program revision will be completed by 12/19/08 (Reference Attachment 2, Item No. 5).

Testing Evaluation

1. Results of the periodic venting or gas accumulation surveillance procedure review

" The periodic venting of the ECCS system (HHSI and LHSI) is performed to satisfy TS SR 4.5.2.b. The plant surveillance procedure for periodic venting is required to be performed every 31 days.

" The venting surveillance procedure includes the use of a vent rig intended to quantify the amount of air and/or gas present during venting.

" The venting surveillance procedure includes acceptance criteria stated as "flow observed from vent."

" The venting surveillance procedure currently includes a requirement to initiate an NCR, "if a significant quantity of gas is found in the low pressure ECCS discharge piping."

" HNP currently has TS SR for ECCS systems which require periodic venting at accessible discharge piping high points. The plant surveillance procedure was reviewed to ensure all high point vent locations are used and no vent locations were determined to be inaccessible.

" Based on reviews performed, there are no new additional locations where periodic venting should be performed to ensure piping remains sufficiently full. Periodic UT will be performed to supplement the existing TS SR for ECCS systems (HHSI and LHSI). Additionally, periodic UT of the CS system suction and discharge piping will be performed.

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Attachment 1 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS"

2. Procedure revisions or new procedures resulting from the periodic venting or gas accumulation surveillance procedure review The plant surveillance procedure will be revised to include a requirement to secure the venting process, notify the Superintendent Shift Operations (SSO) and initiate an NCR in the event air or gas is detected during venting. The plant surveillance procedure will have a prerequisite for UT at selected locations before commencing the periodic venting for each system. The plant periodic surveillance procedure will be revised to be consistent with the interim standard discussed in Section 2.d (Design Evaluation) of this response. System engineers will receive completed procedure results for trending purposes. In the interim period, administrative controls will be established to ensure the new actions are provided to Operations (Reference Attachment 2, Item No. 3).

3. Manual operation of the RHR system in its decay heat removal mode of operation.

HNP procedures ensure the RHR system is ready for service prior to aligning from the LHSI injection mode to the residual heat removal mode. To provide assurance the piping between the RHR loop isolation valves is full of water, these pipes are UT tested when securing from RHR cooling mode. Whenever a reduced inventory condition is planned during outages, a separate operating procedure is utilized to ensure all GL 88-17 requirements including alarms, indications and RHR pump flow limitations have been established before beginning RCS draindown to mid-loop levels.

4. Results of the procedure reviews performed to determine that gas intrusion does not occur as a result of inadvertent draining due to valve manipulations specified in the procedures, system realignments, or incorrect maintenance procedures HNP procedures have been reviewed during the GL evaluation process to ensure sufficient methods of preventing inadvertent draining of systems are adequately controlled by existing plant processes. The recommended procedure changes resulting from this evaluation provide additional controls to supplement the current methods to prevent inadvertent draining of these systems.

5. Gas voids documentation The methods for detecting gas voids include the periodic venting surveillance of the ECCS system (HHSI and LHSI) and UT of selected systems. Gas voids discovered during the monthly venting surveillance procedure would be documented with an NCR if the void size is greater than the value specified in the procedure.

Gas voids discovered during ultrasonic testing would be documented by plant personnel performing the UT and the test results presented to System Engineering. Engineering would initiate an NCR when any voids are discovered during periodic UT in order. to provide A-13

Attachment 1 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" documentation of the operability assessment, investigate the source of gas and determine the impact of the affected system.

6. List of items that have not been completed, a schedule for their completion, and the basis for that schedule See Corrective Actions c, d, f and g as listed in Section C.2 below.

Corrective Actions Evaluation

1. Results of the reviews regarding how the Corrective Action Program is utilized with respect to gas accumulation at HNP HNP's Corrective Action Program (CAP) is used to document gas intrusion/accumulation issues as potential nonconforming conditions. Existing procedures for the ECC systems require the initiation of a condition report and notification of the SSO if the accumulated gas volume exceeds the acceptance criteria specified in the procedures. Integral to HNP's CAP, condition reports related to plant equipment are evaluated for potential impact on operability and reportability. Therefore, HNP's review has concluded that issues involving gas intrusion/accumulation are properly prioritized and evaluated under the CAP.

2. Explain the threshold (acceptance criteria) for entry into the Corrective Action Program (CAP) and how the CAP addresses disposition and trending The periodic surveillance procedure requires initiation of a condition report if the volume of gas discovered during monthly venting exceeds the specified acceptance criteria. These condition reports are used for investigation by System Engineering and also serve as the method of tracking and trending gas void events.

3. List of items that have not been completed, a schedule for their completion, and the basis for that schedule No changes to CAP identified.

Conclusion Based upon the above, HNP has concluded that HNP ECCS, RHR and CS system are Operable as required by TS. These systems are in conformance with commitments to the applicable General Design Criteria (GDC) as stated in the FSAR with respect to gas accumulation concerns addressed in GL 2008-01.

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Attachment 1 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" B. DESCRIPTION OF NECESSARY CORRECTIVE ACTIONS The following corrective actions were determined to be necessary to assure compliance with the applicable regulations:

1) Perform a detailed walkdown of currently inaccessible piping and ultrasonic examinations of locations potentially susceptible to gas accumulation.

2) Revise the operating procedures for HHSI, LHSI and CS system to include supplemental ultrasonic testing (UT) of appropriate piping sections to ensure an adequately filled condition is achieved. Include a precaution and limitation for an Engineering review to ensure system filling and venting is properly planned and the procedure guidance is sufficient for the work performed.

3) Revise the post-maintenance testing procedure to ensure appropriate confirmatory UT inspections are performed following maintenance activities that require piping to be drained.

4) Revise plant surveillance procedure (OST- 1107) to include a requirement to secure the venting process, to notify the SSO and to initiate an NCR in the event air or gas is detected during venting. This revision will include instructions to perform UT in the event of air/gas and to route the results to the system engineer for trending purposes.

A prerequisite will be added to verify that UT inspections have been performed at selected locations prior to the periodic venting. Until specific criterion are developed for HNP systems and, in the absence of system- or location-specific acceptance criteria, the proposed interim standard for ECCS and CS system gas voids will be no air and/or gas allowed.

5) Revise the design basis documents for SI and CS to include a discussion of the design features for each system that prevent vortexing of the ECCS and CS system pumps during the injection and recirculation phase.

6) Revise the plant PM for the LHSI and HHSI systems to perform periodic inspections (combination of UT and/or vent) at locations susceptible to gas accumulation over time.

The PM will be performed monthly (or less frequently if justified).

7) Initiate a plant PM to ensure the CS system suction piping, CS pumps and discharge piping up to the first closed discharge line isolation valve will be maintained sufficiently full. The PM will ensure monthly (or less frequent if justified) inspections (combination of UT and/or vent) at locations susceptible to gas accumulation over time are performed.

8) Install one new vent valve on Spray Additive System tank outlet pipe.

A-15

Attachment 1 to SERIAL: H1NP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" C. CORRECTIVE ACTION SCHEDULE

1. Completed corrective actions HNP has completed the GL 2008-01 requested actions regarding the evaluation of licensing and design basis, testing and corrective actions. A/

2. Corrective actions to be completed including the scope, schedule, and a basis for that schedule

a. Walkdowns of inaccessible piping in containment Scope: Complete detailed walkdowns of HHSI, LHSI and RHR system inaccessible piping inside containment and perform ultrasonic examinations of locations potentially susceptible to gas accumulation.

Due Date: Completion of refueling outage (RFO) 15, scheduled to begin in April 2009.

Basis: The piping inside containment is inaccessible during power operation.

Acceptable per NRC response to GL 2008-01 Three Month Submittal (Reference 3).

b. Revise operating procedures used for system fill and vent Scope: ECCS and CS system procedure changes include enhancements to perform engineering reviews of the system fill and vent methods during planning and the performance of confirmatory UT inspections following maintenance.

Due Date: 04/18/09 or prior to first use.

Basis: The guidance of the current operating procedures is adequate for the interim period while these revisions are processed.

c. Revise the plant post-maintenance testing procedure Scope: PLP-400 procedure change involves an enhancement to ensure appropriate confirmatory UT inspections are performed following maintenance activities that require piping to be drained.

Due Date: 01/29/09 or prior to first use.

Basis: Engineering will provide guidance to ensure confirmatory UT inspections are performed during the interim period while this revision is processed.

d. Revise the plant periodic venting surveillance procedure Scope: OST-1 107 will be revised to include a requirement to secure the venting process, to notify the SSO and to initiate an NCR in the event air or gas is detected during venting. This revision will include instructions to perform UT in the event of air/gas and to route the results to the system engineer for trending purposes. A prerequisite will be added to verify that UT A-16

Attachment 1 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" inspections have been performed at selected locations prior to the periodic venting. Until specific criterion are developed for HNP systems and, in the absence of system- or location-specific acceptance criteria, the proposed interim standard for ECCS and CS system gas voids will be no air and/or gas allowed.

Due Date: 12/18/08 Basis: In the interim period, administrative controls will be established to ensure the new actions are provided to Operations.

e. Revise the plant Design Basis Documents Scope. Revise ECCS and CS system DBDs to discussthe design features which minimize vortexing of the systems during injection and recirculation.

Due Date: 01/29/09 Basis: These changes are enhancements to the ECCS and CS system design basis documents.

f. Revise the plant PM for periodic ECCS UT inspections Scope: Revise PM # 26857 to include a requirement for periodic verification (every 31 days or longer with supporting justification) that the LHSI and HHSI pumps suction piping are maintained sufficiently full. This is verified by performing inspections at locations identified to be potentially susceptible to accumulation of gas over time.

Due Date: 12/19/08 Basis: The revision of the plant PM will include enhancements of the existing UT inspections to perform periodic UT of the ECCS system. These UT inspections supplement the current TS SR for monthly venting.

g. Develop a plant PM for periodic UT inspections of CS system Scope: The plant PM program will include a requirement for periodic verification (every 31 days or longer with supporting justification) that the CS system suction piping, CS pumps and discharge piping up to the first normally closed valve are maintained sufficiently full by UT and/or venting at locations identified to be potentially susceptible to accumulation of gas

-over time.

Due Date: 12/19/08 Basis: The PM for the CS system will include a requirement for periodic checks (UT) of the CS system, currently without an existing plant TS SR or PM for periodic UT inspections. The results of the HNP GL evaluation indicate the risk of gas accumulation for the CS system is less severe than ECCS systems.

h. Install one new vent valve Scope: The vent valve location is on the Spray Additive System tank outlet pipe.

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Attachment 1 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" Due Date: Prior to or during RFO 16 (November 2010)

Basis: The new vent valve is for maintenance and convenience. It is not required for system operability but provides a system vent for maintenance purposes on the Spray Additive system.

i. Evaluate TSTF related to potential for unacceptable gas accumulation for applicability to HNP Scope: Completion of a long-term generic program to provide new and improved TSs which address gas accumulation issues.

Due Date: If applicable, a License Amendment Request incorporating changes identified in the TSTF Traveler will be submitted to the NRC nine months after NRC's approval of the TSTF Traveler Basis. Although TS changes may be necessary to reflect the improved understanding achieved during the GL 2008-01 analysis, these cannot be fully developed to meet the current submittal deadlines (Reference 3).

CONCLUSION Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc.

(PEC), has evaluated the accessible portions of those HNP systems that perform the functions described in Generic Letter 2008-01 and has concluded that the affected systems are Operable, as defined in the HNP TS, and are in conformance to the commitments to the applicable General Design Criteria (GDC) as stated in the HNP FSAR.

The open actions cited above are considered to be enhancements to the existing programs/processes/procedures for assuring continued operability of these subject systems.

As committed in Reference 2, HNP will complete its evaluation of the inaccessible portions of these systems by startup from the next Refuel Outage. A supplemental response will be provided to the NRC within 90 days of startup.

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Attachment 2 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01 LIST OF REGULATORY COMMITMENTS The actions in this document committed to by Progress Energy Carolinas, Inc. (PEC) regarding Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray systems," are identified in the following table. Statements in this submittal, with the exception of those in the table below, are provided for information purposes and are not considered commitments. Please direct any questions regarding this document or any associated regulatory commitments to the Supervisor, Licensing/Regulatory Affairs.

Item Commitment Completion Date 1 Revise operating procedures used for ECCS and CS fill and 04/18/09 or prior to first use vent. This will include enhancements to perform engineering reviews of the system fill and vent methods during planning and confirmatory UT inspections following maintenance. The guidance of the operating procedures is adequate for the interim period while these revisions are processed.

2 Revise HNP post-maintenance testing (PMT) procedure (PLP-400) to ensure appropriate confirmatory UT inspections are performed following maintenance activities that require piping to be drained.

3 The plant surveillance procedure (OST-1 107) will be revised to include a requirement to secure the venting process, to notify the SSO and to initiate an NCR in the event air or gas is detected during venting. This revision will include instructions to perform UT in the event of air/gas and to route the results to the system engineer for trending purposes. A prerequisite will be added to verify that UT inspections have been performed at selected locations prior to the periodic venting. Until specific criterion are developed for HNP systems and, in the absence of system- or location-specific acceptance criteria, the proposed interim standard for ECCS and CS system gas voids will be no air and/or gas allowed.

4 Revise HNP Design Basis Documents to include a discussion of the design features for each system that minimize vortexing of 01/29/09 the ECCS and CS system pumps during the injection and recirculation phase.

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Attachment 2 to SERIAL: HNP-08-098 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 NINE-MONTH RESPONSE TO NRC GENERIC LETTER 2008-01 LIST OF REGULATORY COMMITMENTS Item Commitment Completion Date 5 Revise/Develop HNP PM Program to include a requirement for periodic verification using UT that the HHSI, LHSI and CS system pump discharge and suction piping high points and other potential gas accumulation locations are maintained 12/19/08 sufficiently full.

- ECCS (revise existing PM)

- CS (develop new PM) 6 Install one vent valve on the Spray Additive System tank outlet Prior to or during RFO 16 pipe (not required to maintain system operability). (estimate date - November 2010) 7 Evaluate forthcoming TSTF Traveler concerning new/modified Submit LAR to the NRC TS requirements on gas intrusion for applicability to HNP. If within nine months of the determined applicable to HNP, submit a License Amendment NRC's approval of the TSTF Request (LAR) incorporating TS changes identified in the Traveler TSTF Traveler to the NRC.

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