ML13032A065

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Withdrawal of the License Amendment Request for a One-Time Change to Technical Specification 3.8.4, DC Sources-Operating, to Support Shared Vital Battery Replacement
ML13032A065
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 01/17/2013
From: Capps S
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML13032A065 (2)


Text

Duke STEVEN D. CAPPS Vice President

[PPEnergy, McGuire Nuclear StaItion Duke Energy MGO1VP / 12700 Hagers Ferry Rd.

Huntersville, NC 28078 980-875-4805 980-875-4809 fax Steven. Capps@duke-energy. com January 17, 2013 10 CFR 50.90 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

Subject:

Duke Energy Carolinas, LLC McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 Withdrawal of the License Amendment Request for a One-Time Change to Technical Specification 3.8.4, "DC Sources-Operating," to Support Shared Vital Battery Replacement By letter dated August 9, 2012, Duke Energy Carolinas, LLC (Duke Energy) submitted a License Amendment Request (LAR) for McGuire Nuclear Station, Units 1 and 2 (McGuire). The proposed LAR would have revised the McGuire Technical Specification (TS) 3.8.4, Condition A Completion Time (CT), to allow replacement of the existing 125 Volt DC Shared Vital Batteries while at power.

By letter dated October 18, 2012, Duke Energy provided supplemental information in support of the NRC's acceptance review process. In a follow-up conference call with the NRC staff on December 13, 2012, the NRC staff expressed concems with the Fire Probabilistic Risk Assessment (PRA) portion of the LAR.

Background:

The Fire PRA for McGuire was completed and had undergone an Industry Peer Review in September 2009 to support risk informed applications such as this one-time change to the Vital Battery Technical Specification CT. The Fire PRA has also been developed to support the McGuire LAR for transition to NFPA 805. The Fire PRA used for the Battery CT extension LAR contains what has been determined to be an Un-reviewed Analysis Method (UAM), as the method is not included in NUREG/CR-6850-EPRI TR1011989: "Fire PRA Methodology for Nuclear Power Facilities."

The McGuire NFPA 805 LAR, planned to be submitted in 2013 (with a supporting Fire PRA), will have this UAM removed. It should be noted that the risk impact with UAM removed was evaluated and provided to the NRC staff showing that the proposed Battery extended CT would continue to meet the NRC acceptance metrics established in Regulatory Guide 1.174 Rev. 2:

"An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant Specific Changes to the Licensing Basis" and RG 1.177 Rev. I "An Approach for Plant-Specific, An I www. duke-energy. corn

January 17, 2013 Nuclear Regulatory Commission Page 2 Risk-Informed Decisionmaking: Technical Specifications."

As a defense in depth measure, the proposed LAR added a temporary full size battery, which was not credited in the risk analysis provided.

Based on the NRC's concerns, Duke Energy has decided to withdraw the referenced LAR and resubmit in the near future with a more deterministic justification.

Please contact Lee A. Hentz at 980-875-4187 if additional questions arise.

Sincerely, Steven D. Capps cc w/ 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. Zeiler NRC Senior Resident Inspector McGuire Nuclear Station J. H. Thompson, Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 G9A Rockville, MD 20852-2738 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