ML12340A073

Response to Request for Additional Information Regarding License Amendment Related to Revising Technical Specification 3.7.7, Nuclear Service Water System

ML12340A073
Person / Time
Site:	McGuire, Mcguire
Issue date:	11/13/2012
From:	Capps S Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML12340A073 (14)

Text

Duke STEVEN D CAPPS

. ~Energy, Vice President McGuire Nuclear Station Duke Energy MG01 VP I 12700 Hagers Ferry Rd.

Huntersville, NC 28078 980-875-4805 980-875-4809 fax Steven. Capps@duke-energy.corn November 13, 2012 10 CFR 50.90 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ATTENTION: Document Control Desk

SUBJECT:

Duke Energy Carolinas, LLC (Duke Energy)

McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 Response to Request for Additional Information Regarding License Amendment Related to Revising Technical Specification 3.7.7, "Nuclear Service Water System" (TAC Nos. ME8118 and ME8119)

By letter dated February 22, 2012 Duke Energy requested a license amendment to revise the McGuire Nuclear Station (MNS) Technical Specifications (TS) for Limiting Condition for Operation (LCO) 3.7.7, "Nuclear Service Water System" (NSWS). The License Amendment Request (LAR) will allow the use of the NSWS Pump discharge crossover valves and associated piping to cross tie Unit 1 and 2 NSWS Trains to mitigate a Loss of Service Water (LOSW) event at MNS Units 1 or 2.

By letter dated September 24, 2012 Nuclear Regulatory Commission (NRC) staff requested additional information needed to complete their review of the proposed LAR. The enclosed document provides Duke Energy's responses and contains no regulatory commitments.

Pursuant to 10 CFR 50.91, a copy of this LAR is being sent to the designated officials of the State of North Carolina.

If there are any questions or if additional information is needed, please contact Mr. R. E. Abbott at (980) 875-4685.

Sino rely Steven .Cap(

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U.S. Nuclear Regulatory Commission November 13, 2012 Page 2 xc: with enclosure:

V. M. McCree Regional Administrator, Region II U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, .GA 30303-1257 J. Zeiler NRC Senior Resident Inspector McGuire Nuclear Station J. H. Thompson (addressee only)

NRC Senior Project Manager (McGuire)

U.S. Nuclear Regulatory Commission Mail Stop 0-8 G9A Washington, DC 20555-0001 W. L. Cox III, Section Chief North Carolina Department of Environment and Natural Resources Division of Environmental Health Radiation Protection Section 1645 Mail Service Center Raleigh, NC 27699-1645

U.S. Nuclear Regulatory Commission November 13, 2012 Page 3 Steven D. Capps affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

Steven D. Capps, \ resident, McGuire Nuclear Station Subscribed and sworn to me: r)OL/Mb '/ ]ý, 701Dat Date 6fmuiýr (9 Notary Public My commission expires: (-l/*//I-'/

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ENCLOSURE Responses to Request for Additional Information

Subject:

License Amendment Request to Revise Technical Specification 3.7.7, "Nuclear Service Water System" dated February 22, 2012.

NRC Request for Additional Information:

1. The licensee stated in the LAR that one train of the shared Service Water (SW) system in the operable Unit would be used to supply the SW system of the affected Unit experiencing a Loss of Service Water (LOSW) event. The licensee also stated that abnormal procedures will limit the flow rate from the shared SW train during a LOSW event to the surplus capacity existing after adequate cooling capacity is retained to support the availability of the train's dedicated Unit Emergency Diesel Generator (EDG) and long-term operation of the shared NSWS pump. The LAR does not describe how much flow is needed from one SW train to support the operation of the shared Unit EDG and NSWS pump throughout the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time as indicated in Condition A of TS 3.7.7. The LAR also does not describe how the procedures will monitor the shared SW train flow into the affected Unit.

The NRC staff requests for the licensee to provide additional information on:

a. How much SW flow is needed to supply the EDG and NSWS pump in the sharing unit and how much surplus capacity of the remaining SW flow will be available for the unit experiencing the LOSW event?

Response

Net positive suction head (NPSH) calculations show each Nuclear Service Water System (NSWS) pump is capable of delivering at least 14,000 gallons per minute (gpm).

The minimum required flow to the EDG and NSWS pump is 750 gpm. An additional flow requirement is backwash supply, which requires 400 gpm minimum, for total nuclear service water (NSW) flow required for the sharing unit of 1,150 gpm. The current analysis assumes that 2000 gpm is maintained on the sharing unit leaving a minimum of 12,000 gpm surplus capacity available for the unit experiencing the LOSW event.

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b. How the unit experiencing the LOSW event will utilize the shared SW to mitigate the LOSW event over the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time period?

Response

Cooling water will be supplied to critical components needed to support LOSW unit shutdown. Cooling water may also be supplied to the Reactor Building to support Reactor Coolant Pump operation and Reactor Building Ventilation.

c. How the operators will utilize abnormal procedures to monitor the SW flow from the sharing unit to the affected Unit over the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time period? In addition, explain whether these abnormal procedures will be developed specifically for this alignment.

(SBPB 1)

Response

Operators will control the evolution by maintaining the shared NSW Pump total flow rate less than 14,000 gpm and aligning valves as necessary to ensure flow is only maintained to critical components on the sharing train. Specific abnormal procedure (AP) guidance will be developed for supplying cooling water from one unit to the other.

Operators on the sharing unit will monitor NSW flow throughout the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time period using flow instruments currently installed in the Control Room.

NRC Request for Additional Information:

2. The licensee is requesting to revise TS 3.7.7, "Limiting Condition of Operations", Condition A by adding a Note, "A NSWS train may be shared with another unit to mitigate a LOSW event." The licensee stated that the placement of the Note in TS 3.7.7 Condition A restricts the exception to the activities allowed in TS 3.0.2 LCO Bases and to a LOSW event. The licensee also stated in the LAR that the location of the Note also limits the shared alignment to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> consistent with the Completion Time (CT) established for an inoperable NSWS system I train per unit.

However, the staff considers the proposed Note as written in the TS markup pages could possibly allow subsequent entries into Condition A of TS 3.7.7 after the initial 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time period has elapsed. Multiple entries into Condition A of TS 3.7.7 could negatively impact the inventory needed to support the SW system for the sharing unit.

The NRC staff requests that the licensee reassess and provide justification that the proposed Note for Condition A prevents multiple entries into TS 3.7.7 for the sharing unit after the initial 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of a LOSW event. (SBPB 2)

Response

McGuire's Technical Specifications were converted to NUREG-1431, "Standard Technical Specifications - Westinghouse Plants" (STS), Revision 1, dated April 1995 and approved by the NRC September 30, 1998 (TAC # M98964 and M98965). Consistent with the NUREG, the proposed note for Condition A conforms to the use and application of TS 1.3 Completion Times (CT). With respect to the use of Notes, McGuire's TS 1.3 states, in part, "Ifthis method of modifying how the Completion Time is tracked was 2

applicable only to a specific Condition, the Note would appear in that Condition rather than at the top of the ACTIONS Table." Accordingly, proposed LAR located the Note in Condition A to limit the use of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> CT to a LOSW Event.

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time (CT) is the amount of time allowed for completing a Required Action and is referenced to the time of the inoperable condition. TS 1.3 require that Action Conditions remain in effect and the Required Action continue to apply until the condition no longer exists or the unit is not within the LCO Applicability. Therefore, if the LOSW event is not mitigated at or before 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the shared train must be restored to OPERABLE or the unit must enter Condition B and brought to Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. As stated in the proposed LAR, "Condition A allows operation with one OPERABLE NSWS Train for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before action to restore the inoperable train to operable must be complete or unit shutdown is required." The LAR proposed Required Action (A2), "Restore the NSWS Pump Discharge Crossover Valves to the closed position" and the associated bases stated, in part, "Required Action A.2 ensures the Pump Discharge Crossover Valves are restored to the normal alignment within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; thus, restoring compliance to GDC-5 and Condition A." Based on McGuire TSs and Duke Energy's understanding of NUREG-1431, the placement of the Note was appropriate.

With respect to multiple TS entries, McGuire's TS 3.0.2 and associated Bases require that intentional use of TS ACTIONS must be done in a manner that does not compromise safety. Multiple entries into Condition A of TS 3.7.7 that could negatively impact the inventory needed to support the SW system would not be allowed if it would compromise safety.

NRC Request for Additional Information:

3. The licensee stated in the LAR that the NSWS pump discharge header crossover manual valves are normally closed and that the valves can be aligned to use one of two available NSWS trains to the unit experiencing a LOSW event. The LAR does not describe how long it will take for operators to utilize this alignment after a LOSW event occurs and what other actions will be needed throughout the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period.

The staff requests that the licensee describe the crosstie alignment process, as far as how long it will take for operators to manually align the crossover valves after a LOSW occurs and if other manual actions are needed during the LOSW event. The staff also requests information on training and testing completed that substantiates those operator actions can be completed within the times necessary to mitigate a LOSW event. (SBPB 3)

,Response:

Time critical operator actions to cross-tie NSWS between units are already validated using periodic test PT/O/A/4600/113 (Operator Time Critical Task Verification) and PT/I &2/AI4600/030 (Cycling Time Critical Manually Operated Valves). Operators are allowed 60 minutes from initial LOSW until the cross-tie alignment is complete and cooling water is flowing to the affected unit. Local operator actions to open the NSWS pump discharge header crossover manual valves are included in this time requirement and are required to be performed in less than 25 minutes. Previous validations have 3

shown that these times can be met and are documented in these periodic tests (PTs).

Additionally, all non-licensed operators are required to locate the manual cross-tie valves in the plant as part of training and qualification (T&Q) Guide MO-8004. (Response to RAI #13 provides related insight).

NRC Request for Additional Information:

4. Describe the required operator actions that support implementation of the proposed LAR.

(AHPB 1)

Response

Operators will align valves from the Control Room as necessary to supply cooling water from the desired train on the sharing unit to the desired train on the affected unit. Operators will ensure the shared train maintains required loads. Additionally, operators will be dispatched to locally operate the specific NSWS pump discharge header crossover manual valves to complete the alignment.

NRC Request for Additional Information:

5. Are there any additions to, deletions of, or changes to current operator actions required to support this LAR? If yes, continue. If no, provide the answers to Questions 1 and 2 only.

(AHPB 2)

Response

APs will be revised to include all operator actions required to cross-tie NSWS trains between units.

NRC Request for Additional Information:

6. What are the changes, deletions, or additions to procedures associated with this LAR?

(AHPB 3)

Response

APs will be revised to include operator actions required to cross-tie NSWS trains between units. No other changes are anticipated.

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NRC Request for Additional Information:

7. Are there any changes to the time available for the affected actions or the time required to complete the action(s)? If yes, what are the available times and the observed completion times (seconds, minutes, hours) associated with performing the action(s) before and after the LAR? (AHPB 4)

Response

No, controls of time critical actions are controlled by Nuclear System Directives (NSD 514).

The time available or required to perform actions to cross connect units is not affected. (RAI

1. 3 and #11 responses provide related insight).

NRC Request for Additional Information:

8. What cues and/or alarms will be provided for required operator action(s) identified in Question 1, above? (AHPB 5)

Response

Operators are trained to implement APs based on "symptoms" listed at the beginning of the AP. Control Room indications of SW flow, SW pressure, and SW pump status are included in the AP's list of symptoms and would be used by the operator to diagnose a LOSW condition. Implementation of this LAR does not require any additional alarms or cues to be added to the AP.

NRC Request for Additional Information:

9. Will there be any control room or remote shutdown panel modifications associated with this request? If so, what changes will take place, and when? (AHPB 6)

Response

No control room or remote shutdown panel modifications will be needed for this LAR.

NRC Request for Additional Information:

10. Will the required actions be performed by one operator or more than one? Will it require the coordination of an operator at each unit? (AHPB 7)

Response

Cross connecting SW between units will require one Control Room operator on each unit to make the necessary valve and pump alignments. Additionally, it will take at least one operator in the plant to locally open required crossover manual valves. The AP will be written such that all operator actions are coordinated appropriately.

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NRC Reauest for Additional Information:

11. Will the task analysis that is the basis for the Emergency Operating Procedures (EOPs),

control room equipment, training, and qualification require revision? If not, how will the operators' needs be determined? (AHPB 8)

Response

No revision to the operator task analysis will be required. The task analysis supporting previous AP guidance to cross connect NSWS during a LOSW event will be used to restore the AP guidance. This task analysis is not expected to change. (Response to RAI #18 provides additional insight).

NRC Request for Additional Information:

12. How will personnel know when to initiate the action(s)? (AHPB 9)

Response

Actions to cross-tie SW between units will be controlled by AP. The actions to cross-tie SW between units will be initiated once Control Room personnel are (1) unsuccessful at starting a SW pump on the affected unit and (2) unsuccessful at establishing adequate cooling water flow from a backup cooling water source (i.e. Containment Ventilation Cooling Water System).

NRC Request for Additional Information:

13. How will personnel know that the action(s) was performed correctly? (AHPB 10)

Response

After the SW cross-tie alignment has been made AP will have a Control Room operator action on the LOSW unit to verify temperature indications are within a normal range for critical components receiving cooling water from the sharing unit. Alarms and alarm responses will ensure the shared train is operated within normal parameters.

NRC Request for Additional Information:

14. How will personnel know when the action(s) should be terminated? (AHPB 11)

Response

AP will contain guidance to terminate the alignment after the affected unit restores a SW pump to service.

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I NRC Request for Additional Information:

15. Have likely human errors and their potential consequences been identified? If yes, describe errors analyzed. If no, why not? (AHPB 12)

Response

Yes. When an AP is revised, it goes through the verification and validation process per Operations Management Procedure (OMP) 4-7 (Verification Process for Abnormal and Emergency Procedures) and OMP 4-8 (Validation of the Emergency Response Capability System). This process ensures procedures are technically correct and written such that operators understand the actions required. If an operator error does occur during the alignment, the AP will contain actions for control room operators to monitor plant conditions on both units to ensure proper system response.

NRC Request for Additional Information:

16. Will the proposed action(s) require additional staffing or qualification? (AHPB 13)

Response

No additional staffing or qualification will be required.

NRC Request for Additional Information:

17. Can the action(s) be performed within the analyzed time constraints?

a. With minimum control room staffing?

Response

Yes. Actions can be performed with minimum Control Room staffing.

b. With normal control room staffing?

Response

Yes. Actions can be performed with normal Control Room staffing.

c. Under environmental conditions expected, e.g. emergency lighting, noise, heat, outdoor elements?

Response

Yes. The NSWS pump discharge header crossover manual valves are located in a common area of the Auxiliary Building that is routinely accessed during all modes of 7

operation. The operator will be able to manipulate the valves during all expected environmental conditions.

d. Using required equipment, such as self-contained breathing apparatus, PCs, hand-carried meters, or tools? (AHPB 14)

Response

Yes. A step ladder is the only tool required to locally operate the NSWS pump discharge header crossover manual valves. The ladder will be pre-staged in the area, and the AP will tell the operator where to obtain it.

NRC Request for Additional Information:

18. Was a review of operating experience (OE) done to support the LAR? If yes, what insights were derived? If OE not reviewed. Why not? (AHPB 15)

Response

The proposed LAR was predominately influenced by NRC issued violations related to McGuire's intended use of the NSWS Pump Discharge Crossover Valves and related cause evaluations. The March 4, 2011, "Final Response to Task Interface Agreement - McGuire Nuclear Station Service Water System Unit Crossties Relative to Sharing/Donating in Abnormal Procedures (TIA 2009-011)" developed by the Office of Nuclear Reactor Regulation was the single largest contributor used as the basis for the proposed LAR.

Additionally, license amendments issued in response to NRC Generic Letter 91-13, "Request for Information Related to the Resolution of Generic Issue 130, Essential Service Water System Failures at Multi-Unit Sites" including Byron and Braidwood Stations (TAC #

M85240, M85239, M85237 & M85238) and Comanche Peak (TAC # M80210 & M84709) were reviewed; however, applicable insights from these approved amendments was of limited use. The proposed LAR was primarily derived from the following experiences:

Generic Letter (GL) 91-13, Essential Service Water System Failures at Multi-Unit Sites, encouraged multi-unit sites to develop administrative-type improvements, including Technical Specification amendments and emergency procedure upgrade, to enhance the availability of NSWS Trains for the purpose of mitigating a LOSW event on the opposite unit.

The improvements suggested in GL 91-13 were warranted in view of the safety benefit to be derived.

Insight: McGuire recognized the benefit of cross tying NSWS between units in the event one unit experienced a LOSW event; however, the site's initial response was not adequate. Specifically, the original GL 91-13 evaluation failed to recognize the significance of procedurally specifying the use of the portions of the NSWS not designed to meet Appendix A to 10 CFR 50, General Design Criteria 5 (Sharing of structures, systems, and components). Several subsequent NRC violations emphasized the need for prior NRC approval before NSWS could be shared between units to mitigate a LOSW event as intended by GL 91-13.

June 27, 1986; McGuire received a violation of 10 CFR 50.59 requirements for cross-connecting NSWS Trains between the units (NRC Inspection Report 50-369 / 85-38 and 50-8

Y 370 / 85-39). It was determined the cross tie was prohibited by the unit's Technical Specifications. The NSWS Pump Discharge Cross-Over Valves were not identified as shared components within the TSs and therefore should not have been used to share system flows.

Insight: The NSWS Pump Discharge Cross-Over Valves cannot be used without prior NRC approval. Following the approval of the proposed LAR, McGuire will be able to support development of a procedure under 10 CFR 50.59.

April 24, 2008; McGuire received a violation for failure to adequately establish and maintain procedures required by TS 5.4.1 (NRC Integrated Inspection Report 05000369 / 2008002 and 05000370 / 2008002). Specifically, McGuire failed to adequately establish and maintain AP for LOSW (APIIIA/5500/20 & AP/2/A/5500/20), in that the procedure required operation of the NSWS outside the bounds of the approved licensing basis. The AP directed operators to cross-connect an operable NSWS train from one unit to the NSWS on the other unit without a safety analysis showing that such sharing would not significantly impair the NSWS's ability to perform its intended safety function for its original assigned unit.

Insight: The safety implications associated with sharing the NSWS between units using the NSWS Pump Discharge Cross-Over Valves must be described in the UFSAR in accordance with Regulatory Guide 1.70. Following the approval of the proposed LAR, McGuire plans to describe applicable aspects of sharing NSWS between units in the UFSAR.

March 4, 2011; The NRC Office of Nuclear Reactor Regulation answered questions related to sharing NSWS between units via NSWS Pump Discharge Crossover Valves (Final Response to Task Interface Agreement - "McGuire Nuclear Station Service Water System Unit Crossties Relative to Sharing/Donating in Abnormal Procedures (TIA 2009-011))".

Insight: The TIA confirmed a LAR was needed to share a NSWS train during a LOSW event, sharing a NSWS train was not allowed by TS 3.0.2, and the current UFSAR description and procedure guidance were not supported by an adequate 50.59 evaluation.

Following issuance of the TIA, McGuire received two additional violations on May 6, 2011 (NRC Integrated Inspection Report 05000369 / 2011002 and 05000370 / 2011002). A violation of 10 CFR 50.71 (e) was identified for failure to update the UFSAR to reflect the site response to Generic Letter (GL) 91-13, Essential Service Water System Failures at Multi-Unit Sites, which described capabilities in existing procedures for cross-connecting NSW between units. Also, a violation of 10 CFR 50.59 was identified for changes to the UFSAR and AP-20, without prior NRC approval. The changes allowed one train of NSW to be aligned to the opposite unit to mitigate a LOSW event by opening NSWS Pump Discharge Crossover Valves.

Insight: McGuire restored compliance by eliminating the AP allowing a NSWS train to be shared during a LOSW event and removed the description from the UFSAR. It is Duke Energy's intent to restore procedure guidance and revise the UFSAR following NRC approval of the proposed amendment.

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NRC Request for Additional Information:

19. Was a Human Reliability Analysis (HRA) done to support this LAR? If yes, what insights were derived? If HRA not performed, why not? (AHPB 16)

Response

A specific human reliability analysis was not performed because the LAR is not a risk-informed submittal. The proposed changes would allow recovery actions for alignment of the NSWS pump discharge crossover header to be placed in plant procedures.

Proceduralized actions are considered more reliable and thus the proposed changes are expected to improve plant safety.

NRC Request for Additional Information:

20. Were additions, deletions, or changes made to the training program? If yes, describe. If no, justify why not. (AHPB 17)

Response

No. Operators are already trained on the time critical nature of this evolution as required by nuclear station directive NSD 514 (Control of Time Critical Tasks). Operators will be trained that the use of the NSWS crossover is restored using AP guidance.

NRC Request for Additional Information:

21. Was any verification and validation of operator actions performed, or is any planned? (AHPB 18)

Response

When an AP is revised, it goes through the verification and validation process per OMP 4-7 (Verification Process For Abnormal and Emergency Procedures) and 4-8 (Validation Of The Emergency Response Capability System). This process ensures procedures are technically correct and written such that operators understand the actions required.

Time critical operator actions to cross-tie NSWS between units are already periodically validated in PT/O/AI4600/113 (Operator Time Critical Task Verification) and PT/1 &2/A/4600/030 (Cycling Time Critical Manually Operated Valves).

NRC Request for Additional Information:

22. Is any follow-up or long-term monitoring of this change planned? (AHPB 19)

Response

10

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Yes. Time critical operator actions to cross-tie NSWS between units will be periodically validated in PT/OIA14600/113 (Operator Time Critical Task Verification) and PT/1&2/A/4600/030 (Cycling Time Critical Manually Operated Valves). Additionally, the NSWS cross-tie piping will continue to be periodically flushed to ensure it is free of debris per PT/OIAI43501063 (Flushing of NSWS System Discharge Crossover Piping).

NRC Request for Additional Information:

23. Who has the responsibility to establish the crosstie that is needed? (AHPB 20)

Response

The Operations group has the responsibility to make the necessary cross-tie alignment during a LOSW event.

NRC Request for Additional Information:

24. You rely on the Frequency Control Program to define the frequency with which surveillance is done. Please describe the program. (AHPB 21)

Response

The Duke Energy Surveillance Frequency Control Program (SFCP) provides a process for the evaluation, implementation, and management of TS risk-informed surveillance requirement (SR) frequency changes. The SFCP is administered by Nuclear Station Directive (NSD) 419, Revision 0.

The SFCP process provides for a risk analysis, commitment review, deterministic evaluation (test history, maintenance history, manufacturer's recommendations, codes and standards adherence, and operating experience), documentation, and performance monitoring of changes. This process is referred to as a STRIDE (Surveillance Test, Risk-Informed, Documented, Evaluation). The Duke Energy SFCP was benchmarked against the industry.

A multi-disciplinary Independent Decision Making Panel (IDP) is utilized to initially evaluate determinations of proposed surveillance frequencies changes. Final review and approval of a STRIDE is performed by the Plant Operations Review Committee (PORC).

The Duke Energy SFCP was developed in accordance with Technical Specification Task Force (TSTF) 425, Revision 3 "Relocate Surveillance Frequencies to Licensee Control-RITSTF Initiative 5b" and Nuclear Energy Institute (NEI) 04-10, Risk-Informed Method for Control of Surveillance Frequencies,Revision 1. McGuire submitted a license amendment in accordance with the TSTF and the NRC model safety evaluation and it was approved by NRC on March 29, 2011. Also per the TSTF, a new program was added to the Administrative Controls section of the Technical Specifications, TS 5.5.17, which describes the process at a high level.

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