ML081360497
| ML081360497 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 05/09/2008 |
| From: | Duncan R Progress Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GL-08-001, HNP-08-047 | |
| Download: ML081360497 (5) | |
Text
Robert J. Duncan, 11 Progress Energy rice Plant Harris Nuclear Plant Progress Energy Carolinas, Inc.
MAY 0 9 2008 Serial: HNP-08-047 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 THREE 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 J. P. Fulford to the Nuclear Regulatory Commission (Serial:
PE&RAS-08-025), "Request for Extension of 3-Month Response to Generic Letter 2008-01, 'Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems,"'
dated April 8, 2008 Ladies and Gentlemen:
On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01 (Reference 1), requesting that each licensee evaluate its Emergency Core Cooling System (ECCS), Residual Heat Removal (RHR) 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.
GL 2008-01 requested each licensee submit a written response in accordance with 10 CFR 50.54(f) within 9 months of the date of the GL to provide the following information:
"(a) A description of the results of evaluations that were performed pursuant to the requested actions of the GL. This description should provide sufficient information to demonstrate that you are or will be in 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 of the GL; PO. Box 165 New Hill, NC 27562 T> 919.362.2502 F> 919.362.2095 tw,K
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Serial: HNP-08-047 Page 2 (b) A description of all corrective actions, including plant, programmatic, procedure, and licensing basis modifications that you determined were necessary to assure compliance with these regulations; and (c) A statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule."
Additionally, the NRC requested that if a licensee cannot meet the requested response date, the licensee "shall provide a response within 3 months of the date of the GL," describing a proposed alternative course of action, including the basis for the acceptability of such a proposed alternative course of action. Subsequently, Progress Energy requested, and received, an extension until May 09, 2008, for the submission of Harris Nuclear Plant's (HNP) 3 month response (Reference 2).
Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc., is providing this notification that the HNP does not anticipate being able to fully complete the requested GL 2008-01 evaluations within the allotted nine-month period. In accordance with 10 CFR 50.54(f), Attachment I to this letter provides HNP's three-month response to 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 MAY 0 8 AB*
Sic ly, R. J. Duncan, II Vice President Harris Nuclear Plant RJD/kms Attachments: 1. GL 2008-01 Three-Month Response
- 2. Regulatory Commitments cc:
Mr. P. B. O'Bryan, NRC Sr. Resident Inspector Mr. V. M. McCree, NRC Acting Regional Administrator, Region II Ms. M. G. Vaaler, NRC Project Manager
Attachment I to SERIAL: HNP-08-047 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 GENERIC LETTER 2008-01 THREE MONTH RESPONSE As part of Generic Letter (GL) 2008-01, the NRC requested that each licensee evaluate its Emergency Core Cooling Systems (ECCS), Decay Heat Removal 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 results of these evaluations are requested to be reported within nine months of the date of the GL pursuant to 10 CFR 50.54(f). The GL also requires licensees who do not believe that they can complete the requested evaluations within the nine month period to inform the NRC within three months of the date of the GL, propose alternative actions and provide sufficient justification for such alternatives.
Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc.
(PEC), is hereby notifying the NRC that the Harris Nuclear Plant (HNP) does not anticipate being able to fully complete the requested evaluations within the requested nine-month period.
HNP therefore is providing the following proposed alternative actions and supporting justifications of adequacy in accordance with the requirements of Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems."
Harris Nuclear Plant expects to be able to complete the GL requested actions involving evaluation of licensing basis, design, testing, and corrective actions to a significant extent.
However, the GL requested evaluations also necessitate detailed physical walkdowns of the subject piping systems to confirm pertinent design details (e.g., locations of high point vents),
confirm as-built configurations (e.g., pipe elevations and slope) and ultrasonic examinations at locations potentially susceptible to gas accumulation. Portions of the subject piping systems are inaccessible during power operation due to one or more of the following reasons:
The piping is in an area where dose rates are substantially higher during normal operation as compared to during plant shutdown conditions; The piping is in containment; Insulation removal is needed to fully characterize relevant geometry and insulation removal is not practical due to environmental qualification limitations; Scaffolding is needed to access the piping to fully characterize relevant geometry and installation of scaffolding could jeopardize operability of adjacent equipment.
Harris Nuclear Plant does not currently have a planned refueling outage to conduct the walkdowns of inaccessible piping within the nine-month period requested by the GL (i.e., by October 11, 2008). The next such opportunity will be Refueling Outage 15 (RFO-15), scheduled for Spring 2009. Therefore, HNP's nine-month response to GL 2008-01 will include evaluations Page Al-i of 2 to SERIAL: HNP-08-047 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 GENERIC LETTER 2008-01 THREE MONTH RESPONSE of non-accessible piping based on the existing plant as-built design drawings as well as system operating experience and any previously performed walkdown information.
Subsequently, a supplemental response to GL 2008-01will be provided 90 days following HNP's completion of RFO-15. This supplemental response will describe any changes to the nine-month response resulting from walkdowns and ultrasonic examination of inaccessible piping.
Harris Nuclear Plant has confidence that the ECCS, Decay Heat Removal, and Containment Spray Systems can fulfill their required design functions, based upon the following:
The majority of inaccessible piping will be on the pump discharge where potential impact of gas accumulation is generally less than for pump suction piping.
- Based on reviews completed to date, no historical examples of events related to gas accumulation have been identified for the inaccessible piping.
Successful performance of surveillance requirements (such as periodic venting and pump testing).
- The plant has performed modifications to install vent valves on High Head Safety Injection, Low Head Safety Injection and Containment Spray Systems. The operations surveillance procedure for monthly venting utilizes vent valves installed by these modifications.
Harris Nuclear Plant will complete the Generic Letter actions for these systems with the exception of the final verification walkdown of the pipe segments requiring a refueling outage to access. Preliminary evaluations of inaccessible piping will provide a high degree of confidence that these systems will perform their design functions. The outage walkdowns are expected to be validation activities of these design reviews.
Based upon the above, PEC believes that completing detailed walkdowns and ultrasonic examinations outside the requested nine-month period, but no later than startup from the next refueling outage and submission of a supplemental response to the Generic Letter 90 days post-outage, is an acceptable course of action. contains the two commitments associated with this response.
Page A1-2 of 2 to SERIAL: HNP-08-047 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 GENERIC LETTER 2008-01 THREE MONTH RESPONSE COMMITMENTS I Commitment(s)
Scheduled CompletiouDt
- 1. HNP will complete detailed walkdowns and ultrasonic Prior to startup from REO-15, examinations of inaccessible piping at locations potentially currently scheduled to begin susceptible to gas accumulation for systems within the scope of Generic Letter (GL) 2008-01 prior to startup from on April 04, 2009.
the next refueling outage (RFO-15).
- 2. HNP will submit a supplemental response to GL 2008-01 to the NRC within 90 days following the completion of the HNP RFO-15. This supplemental response will describe Within 90 days of completion any changes to the nine-month response resulting from of HNP RFO-15.
walkdowns and any necessary ultrasonic examination of inaccessible HNP piping.
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