ML093430689
| ML093430689 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, Catawba, McGuire  |
| Issue date: | 10/23/2009 |
| From: | Hamiton B Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML093430689 (9) | |
Text
BRUCE H. HAMILTON
~Duke Duke BRUCEPresident Vice President Vice H. HAMILTON Energya rOEnergy Station Nuclear Station McGuire Nuclear McGuire Energy Duke Energy MG01 VP /12700 MG01VP Hagers Ferry
/ 12700 Hagers Road Ferry Road Huntersville.
Huntersville, NC 28078 NC 28078 980-875-5333 980-875-5333 980-875-4809 fax 980-875-4809 bruce. hamilton@duke-energy.corn bruce.hamilton@duke-energy.com October 23, 2009 U.S. Nuclear Regulatory Commission Document Control Desk Document Washington, DC 20555-001 Washington, ATTENTION:
A TIENTION: Document Control Desk
Subject:
Duke Energy Carolinas (DEC), LLC LLC McGuire Nuclear Station, Units 1I and 2 McGuire Docket Nos. 50-369 and 50-370 50-370 Catawba Nuclear Station, Units 1 and 2 Docket Nos.
Docket Nos. 50-413 50-413 and 50-414 50-414 Request (LAR) for Technical License Amendment Request Technical Specification Specification (TS) 3.6.13, Ice Condenser Doors, Response to Request for Additional Information (RAI)
(RAI)
This letter provides provides the response to a second RAI for a LAR submitted October 2, submitted on October 2008 to revise TS 3.6.13 - Ice Condenser Doors for the McGuire McGuire and Catawba Catawba NuclearNuclear Stations. This RAI was sent via electronic electronic mail from Jon Thompson Thompson dated October 5, 2009. The draft response to this RAI was discussed during a conference conference call with the the NRC staff staff on October October 13, 2009. The NRC staff's questions questions and DEC's responses are are provided provided in Enclosure Enclosure 1.
The additional additional information information provided in this RAI does not impact the conclusions conclusions of the the No Significant Significant Hazards Hazards Considerations Considerations and the basis for the categorical categorical exclusion from performing an Environmental/Impact performing Environmental/Impact Statement presented in the October Statement presented October 2, 2008 LAR LAR submittal.
submittal. Specifically, the proposed proposed revisions to TS 3.6.13 3.6.13 do not affect the current current post-accident Containment Response post-accident Response analysis of record. In addition, DEC's August 25, 2009 2009 response response to the first RAI impacted by this RAI response.
RAI is not impacted This This RAI RAJ response response contains no regulatory commitments commitments for McGuire McGuire or Catawba.
Catawba.
SAoo www. duke-energy,com www.duke-energy.com
23, 2009 October 23,2009 Nuclear Regulatory Commission Nuclear Commission Page 22 of 5 Please direct any questions Please questions with regard regard to this matter to Julius W. Bryant at at (980)
(980) 875-4162. '
Very truly yours, H. Hamilton B. H. Hamilton Enclosure Enclosure
October 23,2009 23, 2009
. Nuclear Regulatory Regulatory Commission Page 3 of 5 Page xc wI w/ Enclosures Enclosures L.
L. A. Reyes Reyes Regional Administrator, Region Region IIII U.S. Nuclear Regulatory Commission Nuclear Regulatory Sam Nunn Atlanta Federal Center Center Forsyth St., SW, 61 Forsyth SW, Suite 23T85 Atlanta, GA 30303 J. B. Brady Brady NRC Senior Resident Inspector Resident Inspector McGuire McGuire Nuclear Nuclear Station G. A. Hutto III III Inspector NRC Senior Resident Inspector Catawba Catawba Nuclear Station Station J. H. Thompson (addressee only)
Project Manager Manager (MNS and CNS)
U.S. Nuclear Regulatory Regulatory Commission Commission Mail Stop 0-8 G9A Washington, DC 20555-0001 Washington,
- o. Hall B. 0.
Section Section Chief Division Division of Radiation Radiation Protection Section 1645 Mail Service Center Center Raleigh, Raleigh, NC 27699 27699 S.E. Jenkins Jenkins Section Manager Manager Division of Waste Management Management South Carolina Department of Health and Environmental Carolina Department Environmental Control 2600 Bull St.
Columbia, Columbia, SC 29201
\.J October 23, 2009 October Nuclear Nuclear Regulatory Commission Page 4 of 5 OATH AND AFFIRMATION H. Hamilton Bruce H. Hamilton affirms that he is the person person who subscribed his namename to the the foregoing foregoing statement, and that all the matters matters and a'nd facts set forth herein herein are true and correct to the best of his knowledge.
Bruce H. Hamilton, Site Vice President President sworn to Subscribed and sworn Subscribed me:
to me: G -A3 -01 Date Notary gblic My commission expires: 4- Dat Date
October 23, October 23, 2009 2009 Nuclear Regulatory Commission Nuclear Regulatory Commission Page 55 of Page of 55 Intentionally left Intentionally left blank blank r\
Enclosure, 1 Enclosure.
Response to NRC Staff Second Response Second RAI Related Related to October October 2, 2008 LAR for TS 3.6.13, Ice Ice Condenser Doors Condenser NRC Staff Question Question 1 (Two Parts; la 1a and 1b)
NRC Staff Question Question No.1 No.laa In relation to the last paragraph paragraph of your response dated August 25,2009 25, 2009 to SCVB#1, SCVB#1, please explain explain the sequencing sequencing of when the surveillance would be done to detect lower detect lower inlet door blocking devices unintentionally left during outages?
devices unintentionally outages?
DEC Response Response to NRC Staff Question No.la: No.1a:
The paragraph in the August 25, 2009 letter11 referred to in the above above RAI question is repeated repeated below:
"Underthe proposed
. "Under revision to McGuire/Catawba proposed revision McGuire/Catawba TS 3.6.13, 3.6. 13, the one-hour one-hour Required Completion Time for Action Completion for Condition Condition A would be entered entered only if one or more Lower Inlet Door(s)
Door(s) isis physically restrained restrained from opening.
opening. Such a condition arise if a could arise condition could Inlet Door Lower Inlet device, which is temporarily Door blocking device, temporarilyinstalled installedduring outages to during outages prevent inadvertent prevent inadvertentopening opening of the doors, doors, is unintentionally unintentionallyleft in place and the Unit place and Unit is brought into a Mode of Applicability brought Applicability while in that that configuration."
configuration."
Proposed Proposed and current Technical Specification Surveillance Technical Specification Surveillance Requirement Requirement (TSSR) 3.6.13.4 3.6.13.4 and TSSR 3.6.13.5 performed twice every eighteen 3.6.13.5 are actually performed eighteen months, instead instead of once as required by the TSSRs. The LIDs are tested per TSSR TSSR 3.6.13.4 3.6.13.4 and and TSSR 3.6.13.5 in the as-found condition at the beginning of an outage, and in the as-left as-left condition at the*end outage22',3.
theend of an outage 3.
Since accessing accessing the lower plenum plenum area of the ice ice condenser while in MODES 1-4 is prohibited by plant Technical Technical Specifications, Specifications, both of these LID TSSR performance performance windows are in Mode 5 (one at shutdown and one at restart).
restart).
The as-left LID testing sequence is scheduledscheduled just prior to entering MODE 4 restart to ensure containment containment conditions are as close as practically practically achievable achievable to those expected expected at full power operation. The installation and removal of the LID blocking devices is controlled procedure at both McGuire controlled via procedure Catawba 4',5.
McGuire and Catawba 5 . At the conclusion conclusion of the as-MODE related checklists 6 7 left LID TSSRs, MODE checklists ',7 ensure the procedure procedure for removal removal of the LID LID blocking devices is completed, completed, which ensures ensures all blocking accounted for blocking devices are accounted prior to entering entering a MODE of Applicability.
1 Duke Letter dated August 25, 2009, Enclosure 1, page 1 of 6 1 Duke Letter dated August 25, 2009, Enclosure 1, page 1 of 6 2 MNS Procedure PTIOIAI42001032 (I/C Door Surveillance) 2 MNS Procedure PT/0/N4200/032 (I/C Door Surveillance) 3 CNS Procedure CNS Procedure MP/O/AI7150/006 MP/0IN71501006 (I/C Door Surveillance) 4MNS Procedure SMIIAI85101005 (LID Door 4 MNS Procedure SM/0/N851 0/005 (LID Door Door Block Installation/Removal)
Block Installation/Removal)
Installation/Removal)
CNS Procedure SM/OIA/8510/005 (LID Block 5 CNS Procedure SM/0/N851 0/005 (LID Door Block Installation/Removal) 66 MNS Procedures OP/1&2/A/6100/SU-9 1&2 Mode 4 Checklist OP/1 &2/N61 00/SU-9 (Units 1&2 Checklist Procedures)
Procedures)
Procedures OP/1&2/N6100/q01 7 CNS Procedures OP/1&2/A/6100/001 (Units 1&2 1&2 Controlling Controlling Procedures Procedures For Unit Startup)
Page 1 of 4
Enclosure Enclosure 1 Response to NRC Staff Second RAI Related to October October 2, 2008 LAR for TS 3.6.13, Ice Ice Condenser Doors Condenser Doors During ice condenser condenser MODES of Applicability (i.e., (i.e., MODE 1-4),
1-4), if an event occurs thatthat
,could challenge the LID's ability to open (e.g., aa seismic event), the lower plenum area and LIDs are observable from the Intermediate Intermediate Deck (Upper Plenum). For this this inspection, a camera camera is loweredlowered through the ice bed flow channels channels and directed directed appropriately 8' 9' 10' 11 . Discovery of a physically restrained LID would then require entry appropriatell,9,1o,11.
into Condition Condition A of TS 3.6.13 with a required action completion completion time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
NRC Staff Question Question No.1 No. lbb .
Since the surveillance surveillance would be done done during during outages, how do you apply a one hour hour action statement statement that was meant for MODE 1,2,3 1, 2, 3 and 4? Include in the response, all other surveillances done during outages, at a frequency of 18 18 months (i.e., TSSR months (i.e.,
3.6.13.4, TSSR 3.6.13.5, and TSSR TSSR 3.6.13.7).
Response to NRC Staff Question No.1 DEC Response No.lb:
b:
With regard to any of the TS 3.6.13 surveillancessurveillances with a frequency frequency of 18 months, any condition resulting in a failed TSSR which is identified while not in aa MODE of Applicability Applicability would not require entry into the one hour action statement statement meant for MODE MODE 1, 2, 3, and 4. The conditions resulting in aa failed TSSR would be dispositioned dispositioned such that the applicable TS requirements requirements are satisfied prior to entering a MODE of of.
Applicability.
abnormal situations There are certain abnormal situations where the operability of an ice condenser door could be challenged challenged during an outage while in a MODE of Applicability (e.g. reference reference the above response response to NRC Staff Question #1a). #1a). In these instances, the applicable applicable TS TS 3.6.13 Condition would be entered entered (e.g. Condition A for those situations situations resulting in a LID being physically restrained restrained from opening).
NRC Staff Question Question No.2 No. 2 Are any new analyses analyses (GOTHIC(GOTHIC or otherwise) performed performed in support of the LAR or is the the LAR entirely dependent on previous analyses analyses (including sensitivity runs) only? Are all analyses fully formalized the analyses formalized and documented?
documented?
8 MNS procedure RPIOIA157001007 *Earthquake) 8 MNS procedure RP/O/Al5700/007 '(Earthquake) 99 CNS procedure procedure RP/O/Al5000/007 RPIOIAI50001007 (Natural Disaster and Earthquake)
Earthquake) .
10 MNS procedure MP/O/A/7150/190 (Ice Fallout Due To Seismic Disturbance) 10 MNS procedure MP/O/Al7150/19d (Ice Fallout Due To Seismic Disturbance) 11 CNS procedure MP/0/A/7150/142\(Ice Fallout Due 11 CNS procedure MP/O/Al7150/142\(lce Fallout Due To Seismic Disturbance)
Page 2 of 4
Enclosure 1 Response to NRC Staff Second RAI Related to October 2, 2008 LAR for TS 3.6.13, Ice Ice
. Condenser Condenser Dooffi Doors .
DEC Response to NRC Staff Question No.2:
No new analyses were performed in support of the subject Ice Condenser Doors LAR.
A sensitivity run (GOTHIC),
(GOTHIC), which was performed previously approved performed for a previously LAR approved LAR (TSTF-429, Revision 3), was invoked reaffirm the insensitivity invoked to reaffirm containment insensitivity of containment response to an extreme extreme maldistribution (reference below maldistribution of ice in the ice baskets (reference response to NRC Staff Question Question #4). All analyses support of this LAR are fully analyses in support documented, and have formalized and documented, formalized have been reviewed by NRC staff in previous DEC DEC licensing submittals 12 submittals 12..
NRC Staff Question No. 3 Question No.3 Section 3.3.4 "Additional Considerations", the staff needs further respect to Section With respect between the items discussed in this section and the LAR.
explanation as to the relation between Why would deletion of TSSR 3.6.13.63.6.13.6 have any effect on the items discussed? the discussed? Did the flow-proportioning behavior as an input? If analyses related to these items use the LID flow-proportioning If not, why would they even be affected?
affected?
DEC Response to NRC Staff Question No.3:
Section 3.3.4 of the LAR ("Additional Considerations") was provided to show that the the elimination of current TSSR 3.6.13.6 and the addition of a new proposed elimination requirement in new requirement in TSSR 3.6.13.5 3.6.13.5 would have no effect on existing existing license basis elements or recently elements at McGuire licensing basis elements revised licensing McGuire or Catawba Nuclear Stations. A review of Catawba Nuclear this nature is standard compliance practice.
standard DEC regulatory compliance specifically requested by the NRC to be Most of the items listed in Section 3.3.4 were specifically be included in the LAR. As noted in the LAR, none of the items requested to be evaluated included affected by, or have an impact are affected impact on, the proposed Condenser Doors proposed revision to Ice Condenser Doors TS 3.6.13. No analyses done in support of any of these items used LID flow-analyses done proportioning behavior proportioning behavior as an input.
NRC Staff Question No.4 No. 4 dated October 2, 2008, page 6 of 27, last sentence In letter dated sentence of last full paragraph:
Please explain why requiring Please requiring containment bypassing steam is a containment spray to mitigate the bypassing concern?
concern?
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12 IC Door LAR submitted via Duke correspondence dated October 2, 2008, Attachment 1, Pg 17 of 27 12 Ie Door LAR submitted via Duke borrespondence dated October 2, 2008, Attachment 1, Pg 17 of 27
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Enclosure 1 Response to NRC Staff Second RAI Related to October 2,2008 2, 2008 LAR for TS 3.6.13, Ice Ice Condenser Condenser Doors DEC Response Response to NRC Staff Question No.4:
The subject paragraph in the October subject paragraph October 2, 2008 LAR package referred to in NRC Staff NRC Staff 13 Question Question No. No.4 4 is repeated below ::
"Maldistributionof the ice bed inventory was considered
'iMaldistribution considered a threat threat since a section section of ice loaded with less baskets loaded less total total ice than the othersothers ("light" baskets) would melt first
("Iight" baskets) first during a DBA release, release, even if the release release was evenly distributed.
distributed. The concern concern was thatthat a channel channel in the ice bed could be created, requiringContainment created, requiring ContainmentSpray Spray to mitigate the mitigate the bypassing steam.
bypassing steam." "
This paragraph was provided in the LAR to clarify an original design basis element of Condenser System. During aa Design Basis Accident, if the Ice Condenser if any blowdown energy (in the form of steam) were to bypass bypass the ice bed into the upper compartment(e.g.,
compartment (e.g., via via aa channel melted channel melted through the Containment Spray System bed from bottom to top), the Containment would then becomebecome the needed heat heat sink for the mitigation of this bypassing energy.
Since Since a phase changechange (i.e.,
(i.e., melting ice) is not involved involved when the Containment Spray System System is used to condensecondense steam, it is less effective containment effective in mitigating containment pressure. As such the Ice Ice Condenser Condenser design protects against this scenario for as long a time period as possible, ultimately limiting the peak containment containment shell pressure.
Additional NRC Staff Question (from October 13, 2009 conference conference call)
Are the ANSI N 18.2-1973 18.2-1973 requirements requirements for designing against against the propagation propagation of a small break event to a large break event (i.e., (i.e., concurrent, or "double" referenced in "double" breaks) referenced in McGuire and Catawba the McGuire Catawba UFSARs?
DEC Response to Additional NRC Staff Question:
The McGuire McGuire and Catawba Catawba UFSARs UFSARs both contain descriptions descriptions of the basic design requirements against pipe rupture effects stipulated by GDC 4 and ANSI N requirements 18.2-N18.2-14 1973141 1973 ,15. 5. These descriptions identify descriptions identify that McGuire McGuire and Catawba designed in Catawba are designed accordance accordance with these requirements, which prevents prevents the propagation propagation of small break sizes to larger larger break sizessizes for piping systems within the LOCA LOCA boundary.
i 13 I 13 IC Door LAR LAR submitted Dukelcorrespondence dated October 2, 2008, Attachment submitted via Duke\correspondence Attachment 1, page 6 of 27 27
~I/C ll/C Door TS Revision Revision LAR) i 4 MNS UFSAR Section 3.6.2.1 (see also Section 3.6.6, ref.1: WCAP-8172-A, pp 4 MNS UFSAR Section 3.6.2.1 (see also Section 3.6.6, ref.1: WCAP-8172-A, 1-3 and 1-4) 15 CNS UFSAR Section 3.6.1.1 (see also Section 3.6.3, ref.1: WCAP-8172-A, pp 1-3 and 1-4) 15 CNS UFSAR Section 3.6.1.1 (see also Section 3.6.3, ref. 1: WCAP-8172-A, pp 1-3 and 1-4) .
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