ML081650598
| ML081650598 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 09/25/2008 |
| From: | Farideh Saba NRC/NRR/ADRO/DORL/LPLII-2 |
| To: | Waldrep B Carolina Power & Light Co |
| Saba, F | |
| References | |
| GL-08-001, TAC MD7802, TAC MD7803 | |
| Download: ML081650598 (4) | |
Text
September 25, 2008 Mr. Benjamin Waldrep, Vice President Brunswick Steam Electric Plant Carolina Power & Light Company Post Office Box 10429 Southport, North Carolina 28461
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, PROPOSED ALTERNATIVE COURSE OF ACTION (TAC NOS. MD7802 AND MD7803)
Dear Mr. Waldrep:
On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations, GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month submittal date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
By letter dated May 9, 2008, Carolina Power and Light (the licensee) provided a 3-month submittal to GL 2008-01 for Brunswick Steam Electric Plant (BSEP), Units 1 and 2. The NRC staffs assessment of the responses for BSEP, Units 1 and 2 is contained in the enclosure to this letter.
The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance and concluded that for BSEP, Units 1 and 2, with the exception of the clarifications and associated requests discussed in the enclosure, they are acceptable. This letter allows the licensee to implement its proposed alternative course of action provided implementation is consistent with the clarifications and associated requests discussed in the enclosure.
B. Waldrep If you have any questions regarding this letter, please feel free to contact me at (301) 415-1447.
Sincerely,
/RA/
Farideh E. Saba, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324
Enclosure:
As stated cc w/encl: See next page
B. Waldrep If you have any questions regarding this letter, please feel free to contact me at (301) 415-1447.
Sincerely,
/RA/
Farideh E. Saba, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324
Enclosure:
As stated Distribution:
PUBLIC LPL2-2 Rdg RidsNrrDorlLpl2-2 RidsNrrPMFSaba RidsNrrLACSola (Hard Copy) RidsOgcRp RidsAcrsAcnw_MailCTR RidsRgn2MailCenter (PFredrickson) RidsNrrDss RidsNrrDorlDpr RidsNrrDprPgcb ADAMS Accession Number: ML081650598 *See previous concurrence NRR-106 OFFICE LPL2-2/PM LPL2-2/LA PGCB/BC DSS/DD LPL2-2/BC NAME FSaba CSola MMurphy* JWermeil* TBoyce DATE 9/25/08 9/25/08 09/22/08 09/19/08 9/25/08 OFFICIAL RECORD COPY
Carolina Power & Light Company Brunswick Steam Electric Plant Units 1 and 2 cc:
David T. Conley Mr. Robert P. Gruber Associate General Counsel II - Executive Director Legal Department Public Staff - NCUC Progress Energy Service Company, LLC 4326 Mail Service Center Post Office Box 1551 Raleigh, North Carolina 27699-4326 Raleigh, North Carolina 27602-1551 Director, Site Operations Mr. William M. Sue, Chairperson Brunswick Steam Electric Plant Brunswick County Board of Commissioners Carolina Power & Light Company Post Office Box 249 Post Office Box 10429 Bolivia, North Carolina 28422 Southport, North Carolina 28461-0429 Resident Inspector Sandra Spencer, Mayor U. S. Nuclear Regulatory Commission City of Southport 8470 River Road 201 East Moore Street Southport, North Carolina 28461 Southport, North Carolina 28461 Mr. John H. ONeill, Jr. Mr. Warren Lee Pillsbury Winthrop Shaw Pittman, LLP Emergency Management Director 2300 N Street NW. New Hanover County Department of Washington, DC 20037-1128 Emergency Management Post Office Box 1525 Ms. Beverly Hall, Section Chief Wilmington, North Carolina 28402-1525 Division of Radiation Protection N.C. Department of Environment Mr. J. Paul Fulford and Natural Resources Manager, Performance Evaluation and 3825 Barrett Dr. Regulatory Affairs PEB5 Raleigh, North Carolina 27609-7721 Carolina Power & Light Company Post Office Box 1551 Mr. Edward L. Wills, Jr. Raleigh, North Carolina 27602-1551 Plant General Manager Brunswick Steam Electric Plant Robert J. Duncan II Carolina Power & Light Company Vice President, Nuclear Operations Post Office Box 10429 Progress Energy Southport, North Carolina 28461-0429 Post Office Box 1551 Raleigh, North Carolina 27602-1551 Public Service Commission State of South Carolina Brian C. McCabe Post Office Drawer 11649 Manager, Nuclear Regulatory Affairs Columbia, South Carolina 29211 Progress Energy Post Office Box 1551 Ms. Margaret A. Force Raleigh, North Carolina 27602-1551 Assistant Attorney General State of North Carolina Post Office Box 629 Raleigh, North Carolina 27602
U.S. NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 DOCKET NOS. 50-325 and 50-324
1. Background
On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations, GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month submittal date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
- 2. Licensees Proposed Alternative Course of Action By letter dated May 9, 2008, Carolina Power and Light (the licensee) provided a 3-month submittal to GL 2008-01 for Brunswick Steam Electric Plant (BSEP), Units 1 and 2. In of its submittal, the licensee indicates that BSEP, Units 1 and 2 are able to complete the GL-requested actions involving evaluation of licensing basis, design, testing, and corrective actions to a significant extent. However, it also indicates that walkdowns of some segments of piping for the subject systems cannot be completed within the GL-required time.
The licensee stated that the walkdowns cannot be completed because portions of the GL subject systems are inaccessible during power operation for the following reasons:
- 1) The piping is in an area where dose rates are significantly higher during normal operation as compared to that during plant shutdown conditions.
Enclosure
- 2) The piping is in drywell, the main steam tunnel, or the suppression pool.
- 3) Insulation removal may be required to fully characterize relevant geometry and insulation removal is not practical.
- 4) Scaffolding may be needed to access the piping to fully characterize relevant geometry and installation of scaffolding could jeopardize operability of adjacent equipment.
For BSEP Unit 1, a recent refueling outage (B117R1) was completed on March 15, 2008.
During the refueling outage, the licensee performed walkdowns of inaccessible piping within the scope of the GL to confirm as-built configurations (e.g., pipe elevations and slope) at locations potentially susceptible to gas accumulation. However, the pipe insulation was not removed during B117R1 inspections. The licensee indicates that all required walkdowns could not be completed during this refueling outage because of insufficient lead-time to perform the proper pre-planning prior to the outage. It proposes to complete additional walkdowns of those areas only accessible during an outage in the next refueling outage (B118R1) scheduled for February 27, 2010.
For BSEP Unit 2, the licensee plans to complete walkdowns of those areas only accessible during an outage in the next refueling outage (B219R1) scheduled for February 28, 2009.
In Enclosure 2 of its submittal, the licensee provided the following commitments for completion of the GL response:
A. For BSEP Unit 1 -
- 1) Complete any necessary ultrasonic examinations or additional inspections of inaccessible piping at locations potentially susceptible to gas accumulation for systems within the scope of GL 2008-01, prior to startup of the B118R1 planned for February 27, 2010.
- 2) Submit a supplemental response to GL 2008-01 within 90 days following the completion of the B118R1. The supplemental response will describe any changes to the 9-month submittal resulting from walkdowns and ultrasonic examination of inaccessible BSEP Unit 1 piping.
B. For BSEP Unit 2 -
- 1) Complete detailed walkdowns and necessary ultrasonic examinations of inaccessible piping at locations potentially susceptible to gas accumulation for systems within the scope of GL 2008-01, prior to startup from the B219R1 planned for February 28, 2009.
- 2) Submit a supplemental response to GL 2008-01 within 90 days following the completion of the B219R1. The supplemental response will describe any changes to the 9-month submittal resulting from walkdowns and ultrasonic examination of inaccessible BSEP Unit 2 piping.
The licensee stated that the alternative course of action is acceptable based on the following:
- 1. The majority of inaccessible piping is on the pump discharge where potential impact of gas accumulation is generally less than pump suction piping.
- 2. Based on reviews completed to date, no historical examples of events related to gas accumulation have been identified for the inaccessible piping.
- 3. Successful performance of surveillance requirements, such as periodic venting and pump testing.
Based on the above considerations, the licensee stated that it has confidence that the BSEP, Units 1 and 2, subject systems can fulfill their required design functions. As such, the licensee concluded that completing performance of the detailed walkdowns of a portion of piping sections outside of the requested 9-month timeframe is an acceptable alternative course of action.
- 3. NRC Staff Assessment The NRC staff finds that with the exception of the clarifications and associated requests discussed below, the licensees proposed alternative course of action is acceptable based on the above-described evaluation, operating experience, and testing associated with managing gas accumulation at BSEP, Units 1 and 2.
The NRC staff notes examples where the licensees 3-month submittal dated May 9, 2008, does not clearly describe the content and/or schedule for the 9-month submittals. Specifically, the licensee does not provide information indicating if it will submit the walkdowns and evaluations of the accessible piping within the GL scope by the timeframe prescribed in the GL (i.e., by October 11, 2008).
The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:
(1) 9-Month Initial Submittal - Provide to the NRC by October 11, 2008, all GL-requested information for the portions of the subject systems that are accessible prior to the BSEP, Units 1 and 2, refueling outages.
(2) 9-Month Supplemental (Post-Outage) Submittals - Except for the long-term items described below, provide all remaining GL-requested information for the subject systems to the NRC within 90 days following the completion of each refueling outages B118R1 and B219R1 at BSEP, Units 1 and 2, respectively.
For each of these submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensees should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding
which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
The NRC staff noted that the licensees submittal dated May 9, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.