ML082110003
| ML082110003 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 08/12/2008 |
| From: | Vaaler M NRC/NRR/ADRO/DORL/LPLII-2 |
| To: | Walt T Carolina Power & Light Co |
| Vaaler, Marlayna, NRR/DORL 415-1998 | |
| References | |
| GL-08-001, TAC MD7871 | |
| Download: ML082110003 (7) | |
Text
August 12, 2008 Mr. Thomas D. Walt, Vice President H. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550-0790
SUBJECT:
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 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 NO. MD7871)
Dear Mr. Walt:
On January 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems. GL 2008-01 requested licensees 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 of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months 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, as supplemented by letter dated July 25, 2008, Carolina Power and Light Company (the licensee), submitted a 3-month response to GL 2008-01 for the H.B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP). The NRC staffs assessment of the HBRSEP response is enclosed.
T.D. Walt The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance, and concluded that for HBRSEP, with exception of the clarifications and associated requests discussed in the staff assessment, they are acceptable. This letter allows the licensee to implement its proposed alternative course of action provided that implementation is consistent with the clarifications and associated requests discussed in the staff assessment.
If you have any questions regarding this letter, please feel free to contact me at (301) 415-3178.
Sincerely,
/RA/
Marlayna Vaaler, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261
Enclosure:
As stated cc w/enclosure: See next page
T.D. Walt The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance, and concluded that for HBRSEP, with exception of the clarifications and associated requests discussed in the staff assessment, they are acceptable. This letter allows the licensee to implement its proposed alternative course of action provided that implementation is consistent with the clarifications and associated requests discussed in the staff assessment.
If you have any questions regarding this letter, please feel free to contact me at (301) 415-3178.
Sincerely,
/RA/
Marlayna Vaaler, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261
Enclosure:
As stated cc w/enclosure: See next page DISTRIBUTION:
PUBLIC RidsOgcRp RidsNrrDprPgcb LPL2-2 R/F RidsAcrsAcnw&mMailCenter RidsNrrDss RidsNrrDorlLpl2-2 RidsRgn2MailCenter RidsNrrLACSola DBeaulieu, DPR/PGCB RidsNrrPMMVaaler SSun, DSS/SRXB RidsNrrDorlDPR WLyon, DSS/SRXB ADAMS Accession Number: ML082110003 NRR-106 OFFICE LPL2-2:PM LP2-2:LA PGCB:BC DSS:DD LPL2-2:BC NAME MVaaler CSola MMurphy JWermeil TBoyce DATE 08/05/08 087/06/08 08/07/08 08/08/08 08/12/08 OFFICIAL RECORD COPY
Mr. T. D. Walt H. B. Robinson Steam Electric Plant, Carolina Power & Light Company Unit No. 2 cc:
Mr. Ernest J. Kapopoulos, Jr. Mr. J. Paul Fulford Plant General Manager Manager, Performance Evaluation and H. B. Robinson Steam Electric Plant, Regulatory Affairs PEB 5 Unit No. 2 Progress Energy Carolinas, Inc.
Progress Energy Carolinas, Inc. Post Office Box 1551 3581 West Entrance Road Raleigh, North Carolina 27602-1551 Hartsville, South Carolina 29550 Mr. David T. Conley Mr. Eric McCartney Associate General Counsel II - Legal Director of Site Operations Department H. B. Robinson Steam Electric Plant, Progress Energy Service Company, LLC Unit No. 2 Post Office Box 1551 Progress Energy Carolinas, Inc. Raleigh, North Carolina 27602-1551 3581 West Entrance Road Hartsville, South Carolina 29550 Public Service Commission State of South Carolina Mr. Curt Castell Post Office Drawer 11649 Supervisor, Licensing/Regulatory Programs Columbia, South Carolina 29211 H. B. Robinson Steam Electric Plant, Unit No. 2 Ms. Beverly Hall, Section Chief Progress Energy Carolinas, Inc. N.C. Department of Environment 3581 West Entrance Road and Natural Resources Hartsville, South Carolina 29550 Division of Radiation Protection 3825 Barrett Dr.
Mr. C. T. Baucom Raleigh, North Carolina 27609-7721 Manager - Support Services - Nuclear H. B. Robinson Steam Electric Plant, Mr. Robert P. Gruber Unit No. 2 Executive Director Progress Energy Carolinas, Inc. Public Staff - NCUC 3581 West Entrance Road 4326 Mail Service Center Hartsville, South Carolina 29550 Raleigh, North Carolina 27699-4326 Mr. Scott D. West Ms. Susan Jenkins Superintendent - Security South Carolina Department of Health H. B. Robinson Steam Electric Plant, Bureau of Land & Waste Management Unit No. 2 2600 Bull Street Progress Energy Carolinas, Inc. Columbia, South Carolina 29201 3581 West Entrance Road Hartsville, South Carolina 29550 Ms. Margaret A. Force Assistant Attorney General U. S. Nuclear Regulatory Commission State of North Carolina Resident Inspectors Office Post Office Box 629 H. B. Robinson Steam Electric Plant Raleigh, North Carolina 27602 2112 Old Camden Road Hartsville, South Carolina 29550 Mr. John H. ONeill, Jr.
Pillsbury Winthrop Shaw Pittman, LLP 2300 N Street NW.
Washington, DC 20037-1128
NRC STAFF ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261
1.0 BACKGROUND
On January 11, 2008, the U.S. 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 (ADAMS) Accession No. ML072910759). GL 2008-01 requested licensees 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, GL 2008-01 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 requested 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 response 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.
2.0 LICENSEES PROPOSED ALTERNATIVE COURSE OF ACTION By letter dated May 9, 2008 (ADAMS Accession No. ML081340310), as supplemented by letter dated July 25, 2008 (ADAMS Accession No. ML082140613), Carolina Power and Light Company (the licensee), submitted a 3-month response to GL 2008-01 for the H.B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP). The licensee indicated that HBRSEP would complete a significant amount of the requested actions within the 9-month timeframe.
The licensee further stated that the only GL 2008-01 reporting request that would not be completed within the 9-month response time is walkdowns of some segments of piping in the subject systems, including the Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems. The licensee cannot complete the walkdowns because portions of Enclosure
the subject systems are inaccessible during power operation for one or more of the following reasons: (1) the piping is in an area whose dose rates are substantially higher during normal operation as compared to that during plant shutdown conditions; (2) insulation removal is needed to fully characterize relevant geometry and insulation removal is not practical due to environmental qualification limitations; and (3) scaffolding is needed to access the piping to fully characterize relevant geometry and installation of scaffolding could jeopardize operability of adjacent equipment.
As an alternative course of action, the licensee indicated that its 9-month response would include the status of any actions taken or in progress to address GL 2008-01. The licensee would also provide a supplemental response within 90 days following completion of the next HBRSEP refueling outage (RFO-25), which is scheduled to end on November 2, 2008. The supplemental response will describe any changes to the 9-month response resulting from walkdowns and examination of inaccessible piping.
The licensee letter dated July 25, 2008, listed the following commitment:
A submittal that provides the information requested by GL 2008-01 is to be provided on or before October 11, 2008, and a supplemental response to GL 2008-01 is to be provided within 90 days following the completion of Refueling Outage 25 (RO[RFO]-25), currently scheduled to end on November 2, 2008.
The licensee stated that it has confidence the GL 2008-01 subject systems can fulfill their required operability requirements and design functions in the interim, based on continued successful performance of surveillance requirements, including pump testing.
Further, the licensee stated that initial evaluations of inaccessible piping will provide a high degree of confidence that the subject systems will perform their design functions.
The outage walkdowns are expected to be validation activities of the design reviews related to the subject systems.
Based on the above considerations, the licensee concluded that completing detailed walkdowns and examinations outside the required 9-month period, but no later than startup from the next refueling outage, and submission of a supplemental response within 90 days post-outage, is an acceptable course of action.
3.0 NRC STAFF ASSESSMENT Based on its review of the licensees 3-month response, as supplemented, discussed in Section 2 of this assessment, the NRC staff finds that: (1) the stated reasons for the GL 2008-01 response delay are acceptable; (2) the proposed alternative action plan and the commitment to provide a 9-month initial response by October 11, 2008, and a supplemental response within 90 days after startup from the Fall 2008 refueling outage, meet the requested dates for the GL 2008-01 information; and (3) the described operating experience, testing, and corrective actions associated with managing gas accumulation at HBRSEP provide reasonable assurance that the subject systems will remain operable. Therefore, the NRC staff concludes that, with exception of the clarifications and associated requests discussed below, the licensees proposed alternative course of action is acceptable.
The NRC staff noted that the licensees 3-month submittal did not clearly describe the content for the 9-month submittal. The NRC staff requests that the information to be provided be submitted as follows:
(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the next refueling outage, provide all GL 2008-01 requested information to the NRC by October 11, 2008. The NRC staff expects that the information to be submitted include a description of walkdowns and evaluations for all accessible piping within the scope of GL 2008-01.
(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL 2008-01 requested information for the subject systems to the NRC within 90 days following completion of the next refueling outage.
The submittal should serve as a supplement to the October 11, 2008, submittal for completion of the GL 2008-01 response. The NRC staff expects that the supplemental submittal include walkdowns and evaluation of all the previously inaccessible piping within the GL scope, as well as the corrective actions taken, the schedule for completing any remaining actions, and the basis for that schedule.
For each of these two submittals, and consistent with the information requested, the licensee should provide: (1) a description of the results of evaluations that were performed in response to GL 2008-01; (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 submittals did not mention other potential long-term actions that are identified in GL 2008-01. 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 the 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. In addition, technical specification changes may be necessary to reflect the improved understanding achieved during response to GL 2008-01, but these cannot be fully developed for the 9-month initial or supplemental submittals. A future 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.