ML082110423
| ML082110423 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/08/2008 |
| From: | Vaaler M NRC/NRR/ADRO/DORL/LPLII-2 |
| To: | Burton C Carolina Power & Light Co |
| Vaaler, Marlayna, NRO/DNRL 415-3178 | |
| References | |
| TAC MD7832 | |
| Download: ML082110423 (8) | |
Text
August 8, 2008 Chris L. Burton, Vice President Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Code: Zone 1 New Hill, North Carolina 27562-0165
SUBJECT:
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 (TAC NO. MD7832)
Dear Mr. Burton:
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, Carolina Power and Light Company, now doing business as Progress Energy Carolinas, Inc. (the licensee), submitted a 3-month response to GL 2008-01 for the Shearon Harris Nuclear Power Plant, Unit 1 (HNP). The NRC staffs assessment of the HNP response is enclosed.
The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance, and concluded that for HNP, 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. 50-400
Enclosure:
As stated cc w/enclosure: See next page
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. 50-400
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: ML082110423 NRR-106 OFFICE LPL2-2:PM LP2-2:LA PGCB:BC DSS:DD LPL2-2:BC NAME MVaaler CSola MMurphy JWermeil TBoyce DATE 08/06/08 08/06/08 08/07/08 08/08/08 08/08/08 OFFICIAL RECORD COPY
Mr. Chris L. Burton Shearon Harris Nuclear Power Plant, Carolina Power & Light Company Unit No. 1 cc:
Mr. Kelvin Henderson Mr. Robert P. Gruber Plant General Manager Executive Director Shearon Harris Nuclear Power Plant Public Staff NCUC Progress Energy Carolinas, Inc. 4326 Mail Service Center Post Office Box 165, Mail Zone 3 Raleigh, North Carolina 27699-4326 New Hill, North Carolina 27562-0165 Ms. Margaret A. Force Director of Site Operations Assistant Attorney General Shearon Harris Nuclear Power Plant State of North Carolina Progress Energy Carolinas, Inc. Post Office Box 629 Post Office Box 165, Mail Zone 1 Raleigh, North Carolina 27602 New Hill, North Carolina 27562-0165 Mr. Tony Gurley, Chair Mr. David H. Corlett, Supervisor Board of County Commissioners Licensing/Regulatory Programs of Wake County Shearon Harris Nuclear Power Plant Post Office Box 550 Progress Energy Carolinas, Inc. Raleigh, North Carolina 27602 Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165 Mr. Carl Thompson, Chair Board of County Commissioners Ms. Kimberly A. Harshaw, Manager of Chatham County Support Services Post Office Box 87 Shearon Harris Nuclear Power Plant Pittsboro, North Carolina 27312 Progress Energy Carolinas, Inc.
Post Office Box 165, Mail Zone 1 Mr. John H. ONeill, Jr.
New Hill, North Carolina 27562-0165 Pillsbury Winthrop Shaw Pittman, LLP 2300 N Street NW.
Resident Inspector / Harris NPS Washington, DC 20037-1128 c/o U. S. Nuclear Regulatory Commission 5421 Shearon Harris Road Mr. John D. Runkle New Hill, North Carolina 27562-9998 Attorney at Law Post Office Box 3793 Mr. J. Paul Fulford Chapel Hill, North Carolina 27515-3793 Manager, Performance Evaluation and Regulatory Affairs PEB 5 Mr. Jim Warren Progress Energy Carolinas, Inc. NC Waste Awareness & Reduction Network Post Office Box 1551 Post Office Box 61051 Raleigh, North Carolina 27602-1551 Durham, North Carolina 27715-1051 Mr. David T. Conley Chairman of the North Carolina Associate General Counsel II - Utilities Commission Legal Department Post Office Box 29510 Progress Energy Service Company, LLC Raleigh, North Carolina 27626-0510 Post Office Box 1551 Public Service Commission Raleigh, North Carolina 27602-1551 State of South Carolina Post Office Drawer 11649 Ms. Beverly Hall, Section Chief Columbia, South Carolina 29211 Division of Radiation Protection N.C. Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, North Carolina 27609-7721
NRC STAFF ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400
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 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 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. ML081360497), Carolina Power and Light Company, now doing business as Progress Energy Carolinas, Inc. (the licensee), submitted a 3-month response to GL 2008-01 for the Shearon Harris Nuclear Power Plant, Unit 1 (HNP).
The licensee indicated that HNP would complete a significant amount of the requested actions within the 9-month timeframe, including evaluation of licensing basis, design, testing, and corrective actions.
The licensee indicated 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 Enclosure
systems, including the Emergency Core Cooling, Residual Heat Removal, and Containment Spray (CS) Systems. The licensee cannot complete the walkdowns because portions of 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) the piping is in containment; (3) insulation removal is needed to fully characterize relevant geometry and insulation removal is not practical due to environmental qualification limitations; and (4) 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 evaluations 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. The licensee would provide a supplemental response within 90 days following completion of the next HNP refueling outage (RFO-15), which is planned for April 2009. The supplemental response will describe any changes to the 9-month response resulting from walkdowns and ultrasonic examination of inaccessible piping.
The licensee letter dated May 9, 2008, listed the following commitments:
(1) Complete detailed walkdowns and 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 next refueling outage (RFO-15),
currently scheduled to begin on April 4, 2009.
(2) Provide a supplemental response to GL-2008-01 to the NRC within 90 days following the completion of the next refueling outage. This supplemental response will describe any changes to the 9-month response resulting from walkdowns and any necessary ultrasonic examination of inaccessible piping.
The licensee stated that it has confidence the GL 2008-01 subject systems can fulfill their required design functions, based on the following:
(1) 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.
(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).
(4) The plant has performed modifications to install vent valves on High Head Safety Injection, Low Head Safety Injection and CS systems. The operations surveillance procedure for monthly venting utilizes vent valves installed by these modifications.
Further, the licensee stated that it will complete all of the GL 2008-01 actions for the subject systems, with the exception of final verification of the pipe segments requiring a refueling outage to access, within the 9-month timeframe. 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 ultrasonic 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 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 commitments to provide a 9-month initial response by October 11, 2008, and a supplemental response within 90 days after startup from the early 2009 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 HNP 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 the licensee submit the information requested in GL 2008-01 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.
(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.
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 submittal dated May 9, 2008, 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 followup inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.