ML072130460
| ML072130460 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/20/2007 |
| From: | Maurice Heath NRC/NRR/ADRO/DLR/RLRA |
| To: | Duncan R Carolina Power & Light Co |
| Heath, M, NRR/DLR/RLRA, 415-3137 | |
| References | |
| Download: ML072130460 (13) | |
Text
August 20, 2007Mr. Robert J. Duncan IIVice President Carolina Power & Light Company P.O. Box 165, Mail Zone 1 New Hill, NC 27562
SUBJECT:
REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THESHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1, LICENSE RENEWAL APPLICATION
Dear Mr. Duncan:
By letter dated November 14, 2006, Carolina Power & Light Company submitted an applicationpursuant to Title 10 of the Code of Federal Regulations Part 54, to renew the operating license for Shearon Harris Nuclear Power Plant, Unit 1, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.These requests for additional information were discussed with Roger Stewart, and a mutuallyagreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-3137 or via e-mail MLH5@nrc.gov
.Sincerely,/RA/Maurice Heath, Project ManagerLicense Renewal Branch A Division of License Renewal Office of Nuclear Reactor RegulationDocket No. 50-400
Enclosure:
Requests for Additional Informationcc w/encl: See next page
ML072130460 Document Name: C:\FileNet\ML072130460.wpdOFFICEPM:RLRA:DLRLA:DLRBC:RLRA:DLRNAMEM. HeathI. KingL. Lund DATE08/06/0708/03/0708/20/07 EnclosureSHEARON HARRIS NUCLEAR POWER PLANT (HNP), UNIT 1LICENSE RENEWAL APPLICATION (LRA)REQUESTS FOR ADDITIONAL INFORMATION (RAIs)RAI 2.1.1.2-1LRA Section 2.1 Scoping and Screening MethodologyIn LRA Section 2.1.1.2, "Non-Safety Related Criteria Pursuant to 10 CFR 54.4(a)(2)," theapplicant describes the methodology in identifying applicable structures, systems andcomponents (SSC's). LRA Section 2.1.1.2 contains guidance for "10 CFR 54.4(a)(2) ScopingBased on NRC Scoping Guidance for Spatial Interactions and Seismic-Connected Piping." Additionally, in LRA Section 2.1.1.2, the applicant describes "Spatial Interactions," and on page2.1-10, the applicant requires that non-connected, non-safety related systems be brought withinthe scope of license renewal to protect safety related SSC's from the consequences of failuresof the non-safety related systems.On LRA pages 2.1-9 and 11, the applicant states in the guidance that the turbine buildingcontains safety related components and that this information is used to identify non-safetyrelated systems having potential for adverse spatial interactions. On LRA page 2.1-11, theapplicant describes that feedwater system flow transmitters, the feedwater regulating valves,associated bypass valves, etc., in the Turbine Building as designated safety related in the PassPort equipment data base (EDB). However, the applicant makes the conclusion, "Therefore, nosystems in the Turbine Building are brought into scope per the current guidance regarding special interactions."On LRA pages 2.1-9 and 11, the applicant states in the guidance that the Waste ProcessingBuilding contains safety related components and that this information is used to identify non-safety related systems having potential for adverse spatial interactions. On LRA page 2.1-11, the applicant describes that the waste gas decay tanks and associated piping and valves and radiation monitor components as designated safety related in the Pass Port EDB.Although, there are non-safety related SSC's within the Waste Processing Building and withinthe Turbine Building that may have the potential for adverse spatial interaction with safety related components, the applicant has excluded them from 10 CFR 54.4(a)(2) for spatial interactions. The applicant's evaluation has determined that the safety related components do not meet the license renewal definition of "safety related."Provide the details of the evaluation that allowed the exclusion of the non-safety relatedSSC's within the Turbine Building and within the Waste Processing Building from the 10 CFR 54.4(a)(2) criterion for spatial interactions. RAI 2.1.1.2-2In LRA Section 2.1.1.2, page 2.1-13, under the topic of Seismic-Connected Piping, theapplicant states, "These air/gas piping systems with seismically-connected piping include theInstrument Air System [Section 2.3.3.27], Service Air System [section 2.3.3.28], Bulk NitrogenStorage System [Section 2.3.3.29], Hydrogen Gas System [Section 2.3.3.30], and PenetrationPressurization System [Section 2.3.3.62]." These systems have non-safety related pipingconnected to safety related piping that is included in the scope of license renewal up to the firstseismic anchor or equivalent anchor past the safety/non-safety interface. It is expected that allof these systems should have an intended function of "M-4 structural support" in LRA tables2.3.3-23, 2.3.3-24, 2.3.3-25, 2.3.3-26 respectively.Explain why the intended function M-4 Structural Support (i.e. provide structuralsupport/seismic integrity) is not shown also in LRA tables mentioned above for thecomponents subject to an Aging Management Review (AMR).RAI 2.1.2.1-1In LRA Section 2.1.2.1, "Mechanical Components," the applicant describes the process used toidentify mechanical components subject to AMR. In LRA Section 2.1.2.1 paragraph 5, on page2.1-22, the applicant states, "In-scope mechanical components with no mechanical intendedfunction are assigned a screening result of 'no mechanical intended function,' and they are notsubjected to Aging Management Review." However, the applicant states, "In a limited numberof cases, there are in-scope mechanical components that do not support a mechanical systemintended function but are in the scope because of their potential to damage safety relatedcomponents through direct impact during a seismic event."
Identify the in-scope mechanical components with "no mechanical intended function"that are not subject to an AMR and describe why they are not subject to an AMR.RAI 2.3-1LRA Section 2.3 Scoping and Screening Results - Mechanical SystemsIn several LRA section descriptions and associated licensee renewal scoping drawings, theapplicant describes and highlights various components indicating that they are within the scope of the license renewal and subject to an AMR. The staff notes that many component/
commodity types are not included in the associated LRA tables. The highlighted components include: valves, piping, accumulators closure bolting, drain traps, detectors, pumps, etc. In the associated LRA tables, the applicant did not identify the following component/commodity types:Section 2.3.3.6 Circulating Water System - expansion joints, temperature elements, thermowells Section 2.3.3.21 Emergency Diesel Generator System - expansion joints, flexible connections Section 2.3.3.27 Instrument Air System - valves Section 2.3.3.28 Service Air System - valves, drain trap(s), closure bolting Section 2.3.3.29 Bulk Nitrogen Storage System - valves, accumulator tank Section 2.3.3.30 Hydrogen Gas System - valves, excess flow check valve Section 2.3.3.18 Emergency Screen Wash System - buried piping Section 2.3.4.14 Turbine System - valvesSection 2.3.3.37 Laundry and Hot Shower System - piping, piping components, and piping elements Section 2.3.3.54 Spent Fuel Cask Decontamination and Spray System - filters, pumps, tanks, valves Section 2.3.3.81 Mechanical Components in Electrical Systems - detector, sample cooler Sections 2.3.3.6, 7, 8, 9, 10, 11, 12, 14, etc. - valves and/or pumps Section 2.3.4.4 Main Steam Dump System - silencersSpecifically explain how each of these components is represented in the LRA.Additionally, explain what components the term "piping, piping components, and piping elements" includes for each system.RAI 2.3.3.12-12.3.3.12 Normal Service Water SystemIn final safety analysis report (FSAR) Section 9.2.1.2, page 9.2.1-3, the applicant describes thenormal service water pumps as follows:Normal Service Water (NSW) Pumps - Two 100 percent capacity pumps are providedwith one pump normally supplying all service water requirements. One single supply header will normally furnish the two redundant loops serving the essential plant components. Pumps are sized such that the water requirements for Unit start-up and normal operation can be met by one pump. Both pumps may be required after fourhours have elapsed from the plant normal shutdown initiation (see Table 9.2.1-1). Inthis case both loops serving the essential plant components will be in service.In LRA Section 2.3.3.12, pages 2.3-70 & 71, the applicant describes the NSW pumps asfollows:Two 100-percent capacity NSW pumps are provided. During Unit start-up, shutdown,and normal operation, service water (SW) requirements will be met by one of the NSWpumps. The pump furnishes all normal operating SW requirements for the Unit througha single supply line.Explain the discrepancy in operating requirements of one or two pumps, between thedescriptions in FSAR Section 9.1.2 and LRA Section 2.3.3.12.RAI 2.3.3.13-12.3.3.13 Emergency Service Water SystemIn LRA Section 2.3.3.13, the applicant, identifies that under emergency operation, the servicewater booster pumps start. However, the booster pumps are not identified in either LRA Table 2.3.3-11 or LRA Table 2.3.3-10 (Section 2.3.3.12) as one of the component/commodity types subject to an AMR. Explain why the service water booster pumps are not identified as acomponent/commodity type in either LRA Tables 2.3.3-10 or 2.3.3-11.RAI 2.3.3.16-12.3.3.16 Essential Services Chilled Water SystemOn license renewal scoping drawing 5-G-0499, location L-16, for the essential services chilledwater system, a flag is shown with a "3" in it indicating that the piping and valves beyond it are designed to meet Safety Class 3 and Seismic Category I requirements. The piping beyond the piping class flag (line number 3CX4-71SB-1) is partially highlighted as in the scope of license renewal for 10 CFR 54.4(a)(1) criterion. There is no piping class flag indicating a change in pipe class at the location along the pipe where the highlighting stops.Since pipe line 3CX4-71SB-1 is designed to meet Safety Class 3 and Seismic Category Irequirements, explain why pipe line 3CX4-71SB-1 is not highlighted along its total length; thereby, indicating that it is not within the scope of license renewal for 10 CFR 54.4(a)(1) criterion.RAI 2.3.3.21-12.3.3.21 Emergency Diesel Generator SystemIn LRA Table 2.3.3.17, the applicant identifies, for the emergency diesel generator system, thecomponent/commodity type of "piping, piping components, and piping components."It is unclear why the words "piping components" were listed twice. Please clarifywhether this is a typographical error and what the intended verbiage should be.RAI 2.3.3.22-12.3.3.22 Diesel Generator Fuel Oil Storage and Transfer SystemIn LRA Section 2.3.3.22, the applicant describes that buried fuel oil piping is coated andcathodically protected. The buried piping is required in order for the system to perform its intended function of supplying fuel oil to the emergency diesel generators for all modes of operation. In LRA Table 2.2-3, License Renewal Scoping Results for Electrical/I&C Systems,the applicant identifies that the cathodic protection system is not within the scope of license renewal.Explain whether the cathodic protection for the diesel generator fuel oil storage andtransfer system buried piping is included within the system identified in LRA Table 2.2-3, or if it should be added or included into LRA Table 2.3.3-18. If it is included in Table 2.2-3, explain why the cathodic protection system is not within the scope of license renewal. RAI 2.3.3.22-2On license renewal scoping drawing 5-G-0133-LR, the applicant depicts the diesel generatorfuel oil day tanks 1A-SA and AB-SB for emergency diesel generators 1A-SA and 1B-SB respectively. Each day tank has a supply line from its respective fuel oil transfer pump which is required for the system to perform its intended function. Piping sections 3FO1-237SA-1 and 3FO1-238SB-1 are not highlighted on the license renewal scoping drawing, even though their failure could prevent the transfer of fuel oil to the day tanks.Explain whether these piping sections are intended to be excluded from the scope oflicense renewal. If they are, then explain the effects of their failure on the diesel generator fuel oil storage and transfer system.RAI 2.3.3.28-12.3.3.28 Service Air SystemOn license renewal scoping drawing 5-G-0300, location B-2, for the service air system, theapplicant depicts valve 7SA-V79-1 as attached to the continuation piping required for containment isolation at penetration M-41. The piping required for the containment isolation atpenetration M-41 is highlighted as in the scope of license renewal for 10 CFR 54.4(a)(1) criteria; and the continuation piping has been highlighted as in the scope of license renewal for 10 CFR 54.4(a)(2) criteria for functional support (seismic continuity).Explain why valve 7SA-V79-1 is not highlighted as within the scope of license renewalfor 10 CFR 54.4(a)(2) criterion since it may be a part of the continuation piping needed for seismic continuity.RAI 2.3.3.28-2In LRA Section 2.3.3.28, page 2.3-109, the applicant states that the service air system includessafety related system piping associated with the containment penetration as well as supply piping for the essential services chilled water system. On page 2.3-110, the applicant states that the license renewal scoping boundaries for the service air system are shown on the following boundary drawing 5-G-0300-LR. In addition, the staff noted that service air system piping and components are highlighted on license renewal scoping drawings 8-G-0498-S02-LR, HVAC essential services chilled water condenser flow diagram Unit 1-SA and 8-G-0499-S02-LR, HVAC essential services chilled water condenser flow diagram Unit 1-SB, indicating they are within the scope of license renewal.Explain why the license renewal scoping drawings 8-G-0498-S02-LR and 8-G-0499-S02-LR are not included on LRA page 2.3-110 as license renewal scoping drawings for the service air system. RAI 2.3.3.34-12.3.3.34 Radioactive Floor Drains SystemIn Section 2.3.3.34, the applicant has included "system strainers" as a component/commoditytype in LRA Tables 2.3.3-30 and 3.3.2-30. This component has intended functions of filtration and pressure boundary. On license renewal scoping drawings 5-G-0816-LR at location F-3, and 5-G-0866-LR at locations F-2, 4 and 6, pump strainers were found, however these strainers are not indicated on the drawings as being within the scope of license renewal. Additionally, if these strainers as indicated in Tables 2.3.3-30 and 3.3.2-30 have a pressure boundary intended function, the surrounding piping would also need to also have a pressure boundary function.Clarify if these strainers and the surrounding piping are the specified componentsindicated in LRA Tables 2.3.3-30 and 3.3.2-30 that are subject to AMR or justify their exclusion.RAI 2.3.3.43-12.3.3.43 Oily Waste Collection and Separation SystemOn the license renewal scoping drawing titled "Scoping Notes for Miscellaneous Systems," alsoknown as "System Boundary Drawing Scoping Discussions," CALC HNP-P/LR-0002, , Revision 2, the applicant states that highlighted flow paths in the "Oily Drains System" are intended to indicate flow paths for draining fire fighting water when needed.
However, on license renewal scoping drawing 5-G-0485-LR, the applicant does not highlight portions of the system downstream of the oil water separator.Explain why the piping downstream of the oil water separator is not needed to supportthe intended function of draining fire fighting water. If piping is to be included in the scope of license renewal, identify the piping downstream of the oil water separator necessary to support the fire protection intended function.RAI-2.3.3.45-12.3.3.45 Secondary Waste Treatment SystemIn LRA Section 2.3.3.45, the applicant states that the Secondary Waste Treatment System onlyperforms the system intended function of containing components that have the potential for spatial interactions with safety related SSC's or are relied on for seismic continuity in accordance with 10 CFR 54.4(a)(2). However, on license renewal scoping drawing titled "Scoping Notes for Miscellaneous Systems," the applicant states that highlighted flow paths in the "Liquid Waste Processing System" are intended to indicate flow paths for draining fire fighting water when needed. In FSAR Section 11.2.2.6, the applicant describes the Secondary Waste Treatment System as a subsystem of the Liquid Waste Processing System.Explain the exclusion of the system intended function associated with fire protection, 10 CFR 50.48, for the secondary waste treatment system in accordance with 10 CFR 54.4(a)(3). RAI 2.3.4.1-12.3.4.1 Steam Generator Blowdown SystemIn LRA Section 2.3.4.1, the applicant identifies the steam generator blowdown system as inscope of license renewal because, in part, it contains components that are relied on during postulated fires and station blackout events, and components that are part of the environmental qualification program. In FSAR Section 10.4.8, the applicant describes the steam generator blowdown system, but does not identify how the system is credited in fire protection, station blackout, and environmental qualification.Provide a list of all the components and their intended function(s) within this system thatare within the scope of license renewal and are relied on during postulated fires, station blackout events, or part of the environmental qualification program.
Letter to R. Duncan, from M. Heath, dated August 20, 2007
SUBJECT:
REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THESHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1, LICENSE RENEWAL APPLICATIONDISTRIBUTION
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MHeath SHernandez LRegner Shearon Harris Nuclear Power Plant, Unit 1 cc:David T. ConleyAssociate General Counsel II -
Legal Department Progress Energy Service Company, LLC Post Office Box 1551 Raleigh, NC 27602-1551Resident Inspector / Harris NPSc/o U. S. Nuclear Regulatory Commission 5421 Shearon Harris Road New Hill, NC 27562-9998Ms. Margaret A. ForceAssistant Attorney General State of North Carolina Post Office Box 629 Raleigh, NC 27602Public Service CommissionState of South Carolina Post Office Drawer 11649 Columbia, SC 29211Ms. Beverly Hall, Section ChiefDivision of Radiation Protection N.C. Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, NC 27609-7721Mr. J. Paul Fulford, ManagerPerformance Evaluation and Regulatory Affairs PEB 5 Carolina Power & Light Company Post Office Box 1551 Raleigh, NC 27602-1551Mr. Eric McCartneyPlant General Manager Shearon Harris Nuclear Power Plant Carolina Power & Light Company P. O. Box 165, Mail Zone 3 New Hill, NC 27562-0165Mr. Chris L. BurtonDirector of Site Operations Carolina Power & Light Company Shearon Harris Nuclear Power Plant Post Office Box 165, Mail Zone 1 New Hill, NC 27562-0165Mr. Robert P. GruberExecutive Director Public Staff NCUC 4326 Mail Service Center Raleigh, NC 27699-4326Chairman of the North Carolina Utilities Commission P. O. Box 29510 Raleigh, NC 27626-0510Mr. Herb Council, ChairBoard of County Commissioners of Wake County P. O. Box 550 Raleigh, NC 27602Mr. Tommy Emerson, ChairBoard of County Commissioners of Chatham County P. O. Box 87 Pittsboro, NC 27312Mr. Thomas J. Natale, ManagerSupport Services Carolina Power & Light Company Shearon Harris Nuclear Power Plant P. O. Box 165, Mail Zone 1 New Hill, NC 27562-0165Mr. David H. Corlett, SupervisorLicensing/Regulatory Programs Shearon Harris Nuclear Power Plant Carolina Power & Light Company P. O. Box 165, Mail Zone 1 New Hill, NC 27562-0165 Shearon Harris Nuclear Power Plant, Unit 1 cc:-2-Mr. John H. O'Neill, Jr.Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW Washington, DC 20037-1128Ms. Julie KeysNuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-2708