ML11231A953

Proposed Exigent Technical Specification (TS) Amendment to TS 3.10.1, Standby Shutdown Facility, License Amendment Request (LAR) No. 2011-09, Supplement 2

ML11231A953
Person / Time
Site:	Oconee
Issue date:	08/18/2011
From:	Pitesa J Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML11231A953 (13)

Text

T. PRESTON GILLESPIE, JR.

Vice President alkEnegy. Oconee Nuclear Station.

Duke Energy ON01 VP / 7800 Rochester Hwy.

Seneca, SC 29672 864-873-4478 August 18, 2011 864-873-4208 fax T.Gillespie@duke-energy.corn Document Control Desk U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Numbers 50-269, 50-270, and 50-287 Proposed Exigent Technical Specification (TS) Amendment to TS 3.10.1, "Standby Shutdown Facility" License Amendment Request (LAR) No. 2011-09, Supplement 2 On August 12, 2011, Duke Energy Carolinas, LLC (Duke Energy) submitted a License Amendment Request (LAR) to request approval of a one-time exigent change to extend the Completion Time (CT) of Technical Specification (TS) 3.10.1, Condition F. Duke Energy supplemented this request to provide a revised significant hazards consideration evaluation on August 15, 2011. After discussions with the NRC on August 17, 2011, Duke Energy is supplementing the LAR to revise the amount of additional time requested. This supplement provides additional information that clarifies the LAR but does not expand the scope of the LAR.

The revised change is bounded by the revised determination of no significant hazards consideration submitted in Supplement 1. Enclosure 1 provides the revised change and supporting justification. Regulatory Commitments are provided in Enclosure 2. Attachment 1 provides the revised retyped TS pages. Attachment 2 provides the revised marked up TS pages.

Should you have any questions concerning this information, please call K. R. Alter at (864) 873-3255.

I declare under penalty of perjury that the foregoing is true and correct. Executed on August 18, 2011.

Sincerely, 4

VLV 6 ;

John W. Pitesa Senior Vice President Nuclear Operations 6I Ic(

www. duke-energy.com A06 I

Document Control Desk August 18, 2011 Page 2 Enclosures and Attachments: - Supplemental Information for LAR 2011-09 - List of Regulatory Commitments - Retyped Technical Specification Pages - Marked-Up Technical Specification Pages xc (with Enclosures/Attachments):

V. M. McCree, Administrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 J. F. Stang, Senior Project Manager (ONS)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 8G9A Rockville, MD 20852-2738 A. T. Sabisch, Senior Resident Inspector U.S. Nuclear Regulatory Commission Oconee Nuclear Station S. E. Jenkins, Manager Division of Radioactive Waste Management Bureau of Land and Waste Management Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201

Document Control Desk August 18, 2011 Page 3 bxc (with Enclosures/Attachments):

T. P. Gillespie, Jr.

S. L. Batson T. D. Ray R. H. Guy T. L. Patterson K. R. Alter C. A. Gray S. C. Newman R. D. Hart K. L. Ashe C. J. Thomas Nuclear Safety Review Board ONS Information Service and Compliance ELL

ENCLOSURE 1 SUPPLEMENTAL INFORMATION FOR LAR 2011-09

August 18, 2011 Page 1 Enclosure Supplemental Information Associated for LAR 2011-09 1.0 Introduction Duke Energy proposes a one-time exigent change to extend the Oconee Nuclear Station (ONS), Units 1, 2 and 3 Technical Specification (TS) 3.10.1 Required Action (RA) F.1 Completion Time (CT) by 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. The additional time is needed to complete the process of restoring the fully tested pressurizer heater circuit fuses to OPERABLE status. This testing is currently expected to be completed by 1025 hours0.0119 days <br />0.285 hours <br />0.00169 weeks <br />3.900125e-4 months <br /> on August 19, 2011. Required Action F.1 CT will expire on August 22, 2011. Before entering the extended Completion Time, the fuses and fuse blocks will be installed and functional to support the SSF Auxiliary Service Water (ASW) safety function. This proposed change does not result in a reduction in a commitment in the Duke QA Program.

2.0 Description of Proposed Changes Duke Energy proposes the addition of the following to Note in the Completion Time for TS 3.10.1 Required Action F.1:

An additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is allowed to complete the process of restoring the fully tested pressurizer heater circuit fuses to OPERABLE status. This extension expires on August 24, 2011 at 1610 hours0.0186 days <br />0.447 hours <br />0.00266 weeks <br />6.12605e-4 months <br />.

This note (*) will modify the 45 days in the Note and the Completion Time. This extension will allow time to complete the process of restoring the fully tested pressurizer heater circuit fuses to OPERABLE status.

3.0 Justification for Proposed Change The proposed change extends the CT for TS 3.10.1 Required Action F.1 by 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. The additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is applicable only after installation and functional testing of the fuses and fuse blocks are complete. During the extended CT, the fuses and fuse blocks will be functional and capable of supporting the SSF ASW safety function. The remaining tasks required to declare the SSF ASW System operable are listed below (the times listed are best estimate):

• Completion of post LOCA chamber testing - 8/19 at 1025 hours0.0119 days <br />0.285 hours <br />0.00169 weeks <br />3.900125e-4 months <br />

• Review and resolution of test data - 8/20 at 0600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> (anomalies encountered during Duke Energy review and acceptance may increase this time by 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />)

" Receipt of Certificates of Conformance from vendor - 8/20 at 0600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br />

• Incorporate qualifications of fuses into the modification packages and declare SSF operable - 8/20 at 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> (an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is added should problems be encountered during the review process that would cause a reiteration of this effort) -

This activity includes the following activities, which are being performed in parallel:

o Revising modification package o Revising associated 50.59 screening

" Review and obtain signatures - 08/20 at 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> o Operations Shift Manager review and concur with SSF operability - 8/20 at 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> The best estimate above shows the SSF being restored to operability by August 20, 2011, at 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br />. Duke Energy has listed additional time (in parenthesis after the activities listed

- Supplemental Information for LAR 2011-09 August 18, 2011 Page 2 above) that may be needed to address potential problems encountered during the period between completion of the functional testing and declaring the SSF ASW System operable. This adds 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to the schedule and is the basis for extended TS Completion Time.

During the extended time period Duke Energy will begin shutting down the ONS Units 1, 2, and 3 immediately if a determination is made that the fuses and fuse blocks become non functional. Duke will not perform any activities that will affect or degrade the functionality of the fuses and fuse blocks. There are no activities required that would affect the functionality of the fuses and fuse blocks during the period between completion of the functional testing and declaring the SSF ASW System operable. The physical condition of the fuses are not affected during the transition period. The modification was performed under the 10 CFR 50.59 process and the fuses are being tested in accordance with Duke Energy's QA-1 plan.

The temperature being used for fuse testing bounds the maximum temperatures for the duration of a 4-hour Station Blackout (SBO) event and a 72-hour period with loss of containment cooling.

Duke Energy will also take compensatory measures, as described below, to minimize the impact of events that could cause a loss of containment cooling.

4.0 Compensatory Measures to Minimize Impact of Events During the extended Completion Time, Duke Energy will take compensatory measures described below to minimize the likelihood and impact of events that could cause a loss of AC power to the normal and backup containment cooling systems for an extended period of time.

High Energy Line Break (HELB)

A high energy line break in auxiliary steam and main feedwater piping adjacent to the 4 kV Switchgear could cause a loss of all AC power to containment cooling systems on a unit specific basis. Duke Energy will perform walkdowns, once per shift, to inspect for degraded conditions (the presence of steam) affecting the likelihood of a HELB that could affect 4 kV Switchgear.

Turbine Building (TB) flood TB flood events are not dominant SSF scenarios and would not lead to a loss of all AC power. In this case, the normal containment cooling system would be expected to be available for all but the most severe TB floods which cause failure of the LPSW pumps needed for Reactor Building Cooling Unit (RBCU) operation. Duke Energy will perform walkdowns, each shift to inspect visible portions of Condenser Circulating Water (CCW), for degraded conditions affecting the likelihood of a TB Flood in the following areas:

1. CCW Condenser Inlet Piping

2. CCW Condenser Inlet Expansion Joint

3. CCW Condenser Outlet Piping

4. CCW Condenser Outlet Expansion Joint

5. CCW Emergency Discharge Piping (24" and 30" diameter piping only)

6. CCW Crossover / LPSW Suction Piping

- Supplemental Information for LAR 2011-09 August 18, 2011 Page 3

7. CCW Unwatering Piping

8. CCW Condensate Cooler Inlet Piping

9. CCW Condensate Cooler Outlet Piping

10. CCW RCW Inlet Piping (18" diameter or larger)

11. CCW RCW Outlet Piping (18" diameter or larger)

TB Fire A TB fire could cause of loss of all AC power to the containment cooling systems. Duke Energy currently performs fire watches in the TB (until NFPA 805 is implemented; not scheduled within this time frame) and will continue these fire watches during the extended Completion Time.

Tornado The period of reduced susceptibility to the occurrence of a tornado at the ONS site is during the late summer when tornado activity and intensity in the southeastern US is significantly lower. Historical data shows that the Oconee tornado strike frequency is approximately 2.8 times lower than the annual average value during this time. The tornado would have to take out normal power as well as Keowee and the Lee Combustion Turbines (LCT). As part of the Natural Phenomenon Barrier System, Duke Energy has installed Fiber Reinforced Polymer (FRP) material on Auxiliary Building walls to protect SSF equipment located in the west penetration room from the effects of damage due to differential loads from a design basis tornado.

External Flood Duke Energy has implemented various compensatory measures to mitigate the effects of an external flood.

Loss of all AC Power Events To provide compensatory measures for the loss of AC power events similar to those described above, the Keowee Hydro Station will be a protected power source, and there will be a dedicated line from the LCT. The use of the Protected Equipment Program for the Keowee Hydro Station will avoid adverse impacts to the hydroelectric station. In addition, the Protected Train Program will also be applied to the Keowee Hydro Unit Underground Path, the Switchyard, the Turbine-Driven Emergency Feedwater Pump, 4kV Switchgears B1T and B2T, and Engineered Safeguards Buses TC, TD, and TE on each unit.

The Protected Train Program is defined by ONS procedures and is designed to:

• Prevent plant transients

• Prevent inadvertent entry into TS 3.0.3

• Prevent loss of equipment required to ensure safe shutdown conditions, and

" To control overall plant risk during evolutions, maintenance, or testing.

- Supplemental Information for LAR 2011-09 August 18, 2011 Page 4 The primary purpose of protecting equipment under this program is to ensure that the equipment is available for normal operations and for mitigating abnormal or emergency conditions. The protected equipment for this extended AOT period will be posted at the equipment and communicated to Operations Shift personnel at the beginning of each shift, and to the rest of the site at the Plan of the Day meeting, and will be listed on the Operations Daily Status Sheets. In-place protected equipment postings will be discussed during all turnovers and checked on Nuclear Equipment Operator rounds to ensure postings are in place, unauthorized work is not in progress, and work is not in progress in the vicinity that could impact the equipment being protected. Physical barriers will be used whenever possible, especially if bumping into a component may cause an inadvertent trip or system transient. Surveillances or intrusive work on posted protected equipment is normally not allowed, and if permitted, must be approved by Duty Superintendent of Operations or the on duty Operations Shift Manager, respectively.

August 18, 2011 Page 1 ENCLOSURE2 LIST OF REGULATORY COMMITMENTS The following commitment table identifies those actions committed to by Duke Energy Carolinas, LLC (Duke Energy) in this submittal. Other actions discussed in the submittal represent intended or planned actions by Duke Energy. They are described to the Nuclear Regulatory Commission (NRC) for the NRC's information and are not regulatory commitments.

"..Commitment:', Completion Date, Duke Energy will begin shutting down the ONS Units 1, 2, and 3 During extended immediately if a determination is made that the fuses and fuse Completion Time blocks become non functional.

Duke Energy will perform walkdowns, once per shift, to inspect During extended 2 for degraded conditions (the presence of steam) affecting the Completion Time likelihood of a HELB that could affect 4 kV Switchgear.

Duke Energy will perform walkdowns, each shift to inspect During extended visible portions of Condenser Circulating Water (CCW), for Completion Time degraded conditions affecting the likelihood of a TB Flood in the following areas:

1. CCW Condenser Inlet Piping

2. CCW Condenser Inlet Expansion Joint

3. CCW Condenser Outlet Piping

4. CCW Condenser Outlet Expansion Joint

5. CCW Emergency Discharge Piping (24" and 30" diameter piping only)

6. CCW Crossover / LPSW Suction Piping

7. CCW Unwatering Piping

8. CCW Condensate Cooler Inlet Piping

9. CCW Condensate Cooler Outlet Piping

10. CCW RCW Inlet Piping (18" diameter or larger)

11. CCW RCW Outlet Piping (18" diameter or larger)

The Keowee Hydro Station will be a protected power source, During extended and there will be a dedicated line from the LCT. The use of the Completion Time Protected Equipment Program for the Keowee Hydro Station will avoid adverse impacts to the hydroelectric station. In addition, the Protected Train Program will also be applied to the Keowee Hydro Unit Underground Path, the Switchyard, the Turbine-Driven Emergency Feedwater Pump, 4kV Switchgears B1T and B2T, and Engineered Safeguards Buses TC, TD, and TE on each unit.

Existing commitment: Duke Energy currently performs fire Ongoing watches in the TB (until NFPA 805 is implemented; not scheduled within this time frame) and will continue these fire watches during the extended Completion Time.

Existing commitment: Duke Energy has implemented various Ongoing compensatory measures to mitigate the effects of an external flood.

ATTACHMENT 1 RETYPED TECHNICAL SPECIFICATION PAGES

SSF 3.10.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. SSF Reactor Coolant C.1 Restore SSF Reactor 7 days Makeup System Coolant Makeup inoperable. System to OPERABLE status.

D. SSF Power System D.1 Restore SSF Power 7 days inoperable. System to OPERABLE status.

E. SSF Instrumentation E.1 Restore SSF 7 days inoperable. Instrumentation to OPERABLE status.

F. Required Action and F.1 Restore to OPERABLE ----------NOTE--------

associated Completion status. Not to exceed 45 days Time of Condition A, B, cumulative per calendar C, D, or E not met year*

when SSF Systems or Instrumentation are inoperable due to 45 days from discovery of maintenance. initial inoperability* I G. Required Action and G.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition F not AND met.

G.2 Be in MODE 4. 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> OR Required Action and associated Completion Time of Condition A, B, C, D, or E not met for reasons other than Condition F.

• An additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is allowed to complete the process of restoring the fully tested pressurizer heater circuit fuses to OPERABLE status. This extension expires on August 24, 2011 at 1610 hours0.0186 days <br />0.447 hours <br />0.00266 weeks <br />6.12605e-4 months <br />.

OCONEE UNITS 1, 2, & 3 3.10.1-2 Amendment Nos. , ,

ATTACHMENT 2 MARKED-UP TECHNICAL SPECIFICATION PAGES

SSF 3.10.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. SSF Reactor Coolant C. 1 Restore SSF Reactor 7 days Makeup System Coolant Makeup inoperable. System to OPERABLE status.

D. SSF Power System D.1 Restore SSF Power 7 days inoperable. System to OPERABLE status.

E. SSF Instrumentation E.I Restore SSF 7 days inoperable. Instrumentation to OPERABLE status.

F. Required Action and F.1 Restore to OPERABLE NOTE associated Completion status. Not to xceed days Time of Condition A, B, cumu tive per lendar C, D, or E not met year when SSF Systems or Instrumentation are inoperable due to 45 days from dis very of maintenance. initial inoperability G. Required Action and G.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition F not AND met.

G.2 Be in MODE 4. 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> OR Required Action and associated Completion Time of Condition A, B, C, D, or E not met for reasons other than Condition F.

An additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is allowed to complete the process of restoring the fully tested pressurizer heater circuit fuses to OPERABLE status. This extension expires on August 24, 2011 at 1610 hours0.0186 days <br />0.447 hours <br />0.00266 weeks <br />6.12605e-4 months <br />.

OCONEE UNITS 1, 2, & 3 3.10.1-2 Amendment Nos. 300, WG0, & WO0

-ý ; i A