ML13309A446

E-mail from R.Guzman to T.Byrne Request for Additional Information on Errors Reported Per 10 CFR 50.46 (TACs ME9119, ME9120, ME9121)

ML13309A446
Person / Time
Site:	Oconee
Issue date:	09/12/2013
From:	Richard Guzman Plant Licensing Branch II
To:	Byrne T Duke Energy Carolinas
Guzman R
References
TAC ME9119, TAC ME9120, TAC ME9121
Download: ML13309A446 (1)

Text

{{#Wiki_filter:From: Guzman, Richard Sent: Thursday, September 12, 2013 6:43 AM To: 'Byrne, Tom R.' Cc: 'Alter, Kent R'; Sreenivas, V

Subject:

Oconee Units 1, 2, and 3, NRC Request for Additional Information on Errors Reported per 10 CFR 50.46 (TACs ME9119, ME9120, ME9121)

Tom, As we discussed, I understand the subject request for additional information (RAI) that was transmitted on August 23, 2013 (ADAMS Accession No. ML13237A002), referenced an incorrect version of an NRC staff issued RAI. Shown below is the revised RAI with the correct reference. This RAI supersedes the one issued on August 23, 2013. Please provide a response to the below RAI by October 11, 2013 (this corresponds to approximately 30 days following TMIs receipt of their equivalent RAI as requested in your September 10, 2013, email).

Please contact me if you have any questions. Rich Guzman Sr. Project Manager NRR/DORL/LPL1-1 US NRC 301-415-1030

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On March 9, 2012, Duke Energy Carolinas, LLC (Duke), submitted a report on emergency core cooling system (ECCS) analysis errors, ADAMS Accession No. ML12073A354, for Oconee Nuclear Station, Units 1, 2, and 3. On October 26, 2012, the Nuclear Regulatory Commission (NRC) staff issued a request for additional information (RAI), ML12300A201. On December 7, 2012, Duke replied to the RAI, ML12348A055. The NRC staff is reviewing the submittal and has determined that additional information is needed to complete its review. The specific questions are found below. Please provide a response to this RAI by October 11, 2013. REQUEST FOR ADDITIONAL INFORMATION: On October 26, 2012, the staff issued a Request for Additional Information (RAI) to the licensee (ADAMS Accession Number ML12300A201) regarding the 30-day report which stated the following: 10 CFR 50.46(a)(3)(ii) states: "... If the change or error is significant, the applicant or licensee shall provide this report within 30 days and include with the report a proposed schedule for providing a reanalysis or taking other action as may be needed to show compliance with 50.46 requirements... " The PCT for LBLOCA for Oconee has changed by an absolute value of 160°F since the analysis was performed. Simply reporting the changes and errors in the methodology does not satisfy the intent of the regulation.

Justify not providing a schedule for reanalysis or taking other action to show compliance with Section 50.46. The licensee responded to the RAI on December 7, 2012 (ADAMS Accession Number ML12348A055). The RAI response does not include a proposed schedule for providing a reanalysis. In the response, the licensee states that the PCT error evaluations are supported by explicit analyses using the B&W plant ECCS evaluation model. Since a schedule for reanalysis was not provided, justify how generic analysis for the B&W plant ECCS evaluation model constitutes taking other action to show compliance with Section 50.46. In particular, while the submitted RAI response addresses the acceptance criteria contained in 10 CFR 50.46(b), the response does not address the requirement, at 10 CFR 50.46(a)(1)(i), to calculate ECCS cooling performance in accordance with an acceptable evaluation model. In light of the presently reported, significant, estimated effects of errors and changes, explain how the present ECCS cooling performance has been calculated in accordance with an acceptable evaluation model, such that any other action, as provided in 10 CFR 50.46(a)(3), has been taken to show compliance with 10 CFR 50.46 requirements, including those contained in 10 CFR 50.46(a)(1). Alternatively, submit a schedule for providing a reanalysis or taking other action as may be necessary to show compliance with 10 CFR 50.46 requirements.

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