ML14254A246

Issuance of Amendments Regarding Quality Assurance Requirements for the Standby Shutdown Facility Equipment

ML14254A246
Person / Time
Site:	Oconee
Issue date:	09/25/2014
From:	Hall J Plant Licensing Branch II
To:	Batson S Duke Energy Carolinas
Hall J
References
TAC MF3000, TAC MF3001, TAC MF3002
Download: ML14254A246 (17)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 25, 2014 Mr. Scott Batson Site Vice President

• Oconee Nuclear Station Duke Energy Carolinas, LLC 7800 Rochester Highway Seneca, SC 29672-0752

SUBJECT:

OCONEE NUCLEAR STATION,' UNITS 1, 2 AND 3, ISSUANCE OF AMENDMENTS REGARDING QUALITY ASSURANCE REQUIREMENTS FOR THE STANDBY SHUTDOWN FACILITY EQUIPMENT (TAG NOS. MF3000, MF3001 , AND MF3002)

Dear Mr. Batson:

The U.S. Nuclear-Regulatory Commission (NRC) has issued the enclosed Amendment Nos. 387, 389, and 388 to Renewed Facility Operating Licenses DPR-38, DPR-47, and DPR-55, for the Oconee Nuclear Station (ONS), Units 1, 2, and 3, respectively. The amendments consist of changes to the ONS operating licenses and Updated Final Safety Analysis Report (UFSAR) in response to the application from Duke Energy Carolinas, LLC (Duke Energy), dated October 24, 2013 (Agencywide- Documents Access ?nd Management System (ADAMS) Accession No. ML13304A511 ), as supplemented by letter dated June 30, 2014 (ADAMS Accession' No. ML14184B385). These amendments clarify the_ Quality Assurance (QA) requirements for Standby Shutdown Facility (SSF) equipment as described in UFSAR Section 3.1.1.1. The proposed change revises ONS UFSAR Section 3.1.1.1 to clarify that the QA requirements applied to certain equipment relied upon to perform the SSF function that existed prior to the construction of the SSF, will be consistent with the original QA requirements for that equipment.

A copy of the NRC staff's related Safety Evaluation providing the technical bases for the staff's approval of the amendments is also enclosed.

S. Batson A Notice of Issuance will be included in the Commission's biweekly Federal Register notice. If you have any questions, please contact me at 301-415-4032.

Sincerely, J~l~*ni(,~

Plant Licensing Branch 11-1 Manager Division of Operating Reactor Licensing Office of ,Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287

Enclosures:

1. Amendment No. 387 to DPR-38

2. Amendment No. 389 to DPR-47

3. Amendment No. 388 to DPR-55

4. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY CAROLINAS, LLC DOCKET NO. 50-269 OCONEE NUCLEAR STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 387 Renewed License No. DPR-38

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment to the Oconee Nuclear Station, Unit 1 (the facility),

Renewed Facility Operating License No. DPR-38, filed by Duke Energy Carolinas, LLC (the licensee), dated October 24, 2013, as supplemented by letter dated June 30, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. . Accordingly, the license is hereby amended by* page changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 3.8 of Renewed Facility Operating License No. DPR-38 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised

. through Amendment No. 387, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Robert J. Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. DPR-38 and the Technical Specifications Date of Issuance: September 25, 2014

/

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY CAROLINAS, LLC DOCKET NO. 50-270 OCONEE NUCLEAR STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 389 Renewed License No. DPR-47

1. The Nuclear Regulatory Commission (the Commission) has found that:

A The application for amendment to the Oconee Nuclear Station, Unit 2 (the facility),

Renewed Facility Operating License No. DPR-47, filed by Duke Energy Carolinas, LLC (the licensee), dated October 24, 2013, as supplemented by letter dated June 30, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I; B. *The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 2

2. Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 3.B of Renewed Facility Operating License No. DPR-47 is hereby amended to read as follows:

• B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 389, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Robert J. Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. DPR-47 and the Technical Specifications Date of Issuance: September 25, 2014

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY CAROLINAS, LLC DOCKET NO. 50-287 OCONEE NUCLEAR STATION, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 388 Renewed License No. DPR-55

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment to the Oconee Nuclear Station, Unit 3 (the facility),

Renewed Facility Operating License No. DPR-55, filed by Duke Energy Carolinas, LLC (the licensee), dated October 24, 2013, as supplemented by letter dated June 30, 2014, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 3

2. Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 3.B of Renewed Facility Operating License No. DPR-55 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 388, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Robert J. Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. DPR-55 and the Technical Specifications Date of Issuance: September 25, 2014

ATTACHMENT TO LICENSE AMENDMENT NO. 387 RENEWED FACILITY OPERATING LICENSE NO. DPR-38 DOCKET NO. 50-269 LICENSE AMENDMENT NO. 389 RENEWED FACILITY OPERATING LICENSE NO. DPR-47 DOCKET NO. 50-270 AND LICENSE AMENDMENT NO. 388 RENEWED FACILITY OPERATING LICENSENO. DPR-55 DOCKET NO. 50-287 Replace the following pages of the Renewed Facility Operating Licenses and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages Licenses Licenses License No. DPR-38, page 3 License No. DPR-38, page 3 License No. DPR-47, page 3 License No. DPR-47, page 3 License No. DPR-55, page 3 License No. DPR-55, page 3

A. Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2568 megawatts thermal.

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 387 are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

C. This license is subject to the following antitrust conditions:

Applicant makes the commitments contained herein, recognizing that bulk power supply arrangements between neighboring entities normally tend to serve the public interest. In addition, where there are net benefits to all participants, such arrangements also serve the best interests of each of the participants. Among the benefits of such transactions are increased electric system reliability, a reduction in the cost of electric power, and' minimization of the environmental effects of the production and sale of electricity.

Any particular bulk power supply transaction may afford greater benefits to one participant than to another. The benefits realized by a small system may be proportionately greater than those realized by a larger system. The relative benefits to be derived by the parties from a proposed transaction, however, should not be controlling upon a decision with respect to the desirability of participating in the transaction. Accordingly, applicant will enter into proposed bulk power transactions of the types hereinafter described which, on balance, provide net benefits to applicant. There are net benefits in a transaction if applicant recovers the cost of the transaction (as defined in ,-r1 (d) hereof) and there is no demonstrable net detriment to applicant arising from that transaction.

1. As used herein:

(a) "Bulk Power" means electric power and any attendant energy, supplied or made available at transmission or sub-transmission voltage by one electric system to another.

(b) "Neighboring Entity" means a private or public corporation, a governmental agency or authority, a municipality, a cooperative, or a lawful association of any of the foregoing owning or operating, or proposing to own or operate, facilities for the generation and transmission of electricity which meets each of Renewed License No. DPR-38 Amendment No. 387

A. Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2568 megawatts thermal.

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 389 are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Tech.nical Specifications.

C. This license is subject to the following antitrust conditions:

Applicant makes the commitments contained herein, recognizing that bulk power supply arrangements between neighboring entities normally tend to serve the public interest. In addition, where there are net benefits to all participants, such arrangements also serve the best interests of each of the participants. Among the benefits of such transactions are increased electric system reliability, a reduction in the cost of electric power, and minimization of the environmental effects of the production and sale of electricity.

Any particular bulk power supply transaction may afford greater benefits to one participant than to another. The benefits realized by a small system may be proportionately greater than those realized by a larger system. The relative benefits to be derived by the parties from a proposed transaction, however, should not be controlling upon a decision with respect to the desirability of participating in the transaction. Accordingly, applicant will enter into proposed bulk power transactions of the types hereinafter described which, on balance, provide net benefits to applicant. There are net benefits in a transaction if applicant recovers the cost of the transaction (as defined in ~1 (d) hereof) and there is no demonstrable net detriment to applicant arising from that transaction.

1. As used herein:

(a) "Bulk Power" means electric power and any attendant energy, supplied or made available at transmission or sub-transmission voltage by one electric system to another.

(b) "Neighboring Entity" means a private or public corporation, a governmental agency or authority, a municipality, a cooperative, or a lawful association of any of the foregoing owning or operating, or proposing to own or operate, facilities for the generation and transmission of electricity which meets each of.

Renewed License No. DPR-47 Amendment No. 389

A. Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2568 megawatts thermal.

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 388 are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

C. This license is subject to the following antitrust conditions:

Applicant makes the commitments contained herein, recognizing that bulk power supply arrangements between neighboring entities normally tend to serve the public interest. In addition, where there are net benefits to all participants, such arrangements also serve the best interests of each of the participants. Among the benefits of such transactions are increased electric system reliability, a reduction in the cost of electric power, and minimization of the environmental effects of the production and sale of electricity.

Any particular bulk power supply transaction may afford greater benefits to one participant than to another. The benefits realized by a small system may be proportionately greater than those realized by a larger system. The relative benefits to be derived by the parties from a proposed transaction, however, should not be controlling upon a decision with respect to the desirability of participating in the transaction. Accordingly, applicant will enter into proposed bulk power

• transactions of the types hereinafter described which, on balance, provide net benefits to applicant. There are net benefits in a transaction if applicant recovers the cost of the transaction (as defined in ~1 (d) hereof) and there is no demonstrable net detriment to applicant arising from that transaction.

1. As used herein:

(a) "Bulk Power" means electric power and any attendant energy, supplied or made available at transmission or sub-transmission voltage by one electric system to another.

(b) "Neighboring Entity" means a private or public corporation, a governmental agency or authority, a municipality, a cooperative, or a lawful association of any of the foregoing owning or operating, or proposing to own or operate, facilities for the generation and transmission of electricity which meets each of Renewed License No. DPR-55 Amendment No. 388

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0.001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 387 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-38 AMENDMENT NO. 389 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-47 AND AMENDMENT NO. 388 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-55 DUKE ENERGY CAROLINAS, LLC OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 DOCKET NOS. 50-269, 50-270, AND 50-287

1.0 INTRODUCTION

By letter dated October 24, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13304A511), as supplemented by letter dated June 30, 2014 (ADAMS ML14184B385), Duke Energy Carolinas, LLC (the licensee) submitted a license amendment request (LAR) to revise the quality assurance (QA) requirements for Standby Shutdown Facility (SSF) equipment as described in the Oconee Nuclear Station (ONS) Updated Final Safety Analysis Report (UFSAR), s*ection 3.1.1.1. The proposed change revises ONS UFSAR Section 3.1.1.1 to clarify that the QA requirements applied to certain equipment relied upon to perform the SSF function that existed prior to the construction of the SSF, will be consistent with the original QA requirements for that equipment.

The supplemental letter dated June 30, 2014, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's proposed no significant hazards consideration determination as published in the Federal Register on February 19, 2014 (79 FR 9493).

2.0 REGULATORY EVALUATION

10 CFR 50 Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," requires each licensee to develop and maintain a QA program. Licensees must identify the structures, systems and components (SSCs) covered by the QA program and the QA program must provide control over activities affecting the quality of those SSCs to an extent consistent with their importance to safety. The ONS QA-1 program is defined to meet the

requirements of 10 CFR 50 Appendix R The QA-1 program is applied to systems and components that are essential to the prevention of accidents which could affect the public health and safety. Additional systems and components have been included in the QA-1 program in the time since ONS was initially licensed, based on their importance to safety. The systems and components included in the QA-1 program are identified in ONS UFSAR Section 3.1.1.1.

3.0 TECHNICAL EVALUATION

The SSF provides an alternate means of achieving and maintaining hot shutdown conditions

. following postulated fire, sabotage, or flooding events. The SSF is further described in ONS UFSAR :Section 9.6. ONS UFSAR Section 3.1.1.1 identifies the equipment added to the QA-1

_program subsequent to the original licensing of the plant. This section currently includes the statement:

"Duke is taking the position that all portions of the SSF required for mitigation of a seismic-induced Turbine Building flood shall be QA-1."

The LAR proposed a revision of that statement in ONS UFSAR Section 3.1.1.1, to state:

"The SSF equipment required for mitigation of a seismic-induced Turbine Building flood shall be QA-1, with the exception of plant equipment used for the SSF function that was not QA-1 prior to the construction of the SSF (e.g., pressurizer heaters) and the SSF Portable Pumping System."

The licensee stated in the LAR that the proposed revision clarifies the design philosophy applied to the SSF at the time of its licensing. SSF equipment that was newly installed was included in the QA-1 program, but existing equipment was not intended to be upgraded or replaced with QA-1 equipment. In support of this statement, the licensee referenced communications with the U.S.

Nuclear Regulatory Commission (NRC) at the time of the original SSF licensing.

The NRC staff reviewed the requests for additional information (RAis ), the corresponding responses, and the staff's Safety Evaluation (SE) associated with the original licensing of the SSF.

In that review, the NRC staff did not find any documentation indicating that pre-existing non-QA-1 equipment was required to be replaced or upgraded to QA-1 requirements. The licensee also stated that pre-existing non-QA-1 equipment was not replaced or upgraded when the ONS UFSAR was revised to add the statement, "Duke is taking the position that all portions of the SSF required for mitigation of a seismic-induced Turbine Building flood shall be QA-1."

While pre-existing equipment was not required to be included in the QA-1 program, this equipment is required to perform its intended function under the expected conditions of the events for which it is credited. The NRC staff's RAI, dated June 4, 2014, stated that equipment that is relied upon to support the SSF function should remain functional in those scenarios where the SSF is credited, and the quality assurance requirements applied to this equipment should establish assurance that the equipment will function properly.

In its response to the NRC staff's RAI, dated June 30, 2014, the licensee described its evaluation of the performance of non-QA-1 components under the conditions associated with SSF-mitigated events. Thelicensee stated, " ... all the identified non-QA-1 components are fully capable of performing their required functions with the seismic and environmental conditions to which they

may be exposed." In that sallie RAI response, the licensee further described its process for assigning non-QA-1 components to either non-QA status or its QA-5 program. This process was intended to ensure the ability of non-QA-1 components to perform their intended function in an accident scenario, and the process was approved by the NRC staff in a letter dated August 3, 1995. Additionally, the licensee described the ONS QA-5 program in the LAR, as follows:

"[T]he ONS QA-5 program is an augmented QA program that is applied to SSCs that do not fall under the scope of the QA-1 program but which may be required to mitigate the impact of certain postulated accidents/events including the Turbine Building flood event. Duke Energy has committed to the NRC to include certain equipment within the scope of the QA-5 program. The QA~5 program does not require SSCsto be procured per 10 CFR.50, Appendix B requirements but the procured components are to be "equal or better quality:* based on engineering judgment. For QA-5 SSCs, testing and maintenance is to be performed in a manner similar to that performed for QA-1 SSCs in accordance with selected Appendix B criteria. Equipment that is classified as QA-5 is treated as non-QA from a material, design and procurement aspect but is treated comparable to QA-1 components for maintenance and testing aspects."

As an example of the application of its QA review process to SSF-related equipment, the licensee stated that the electrical function of the SSF-powered Group B and Group C pressurizer heaters was upgraded to QA-5. Activities involving the non-QA-1 components will continue to be controlled in accordance with the licensee's existing QA program. Therefore, the NRC staff finds that inclusion of pre-existing non-QA-1 equipment into the QA-1 program is not required to assure that equipment's capability to perform as intended. ** *

.Based on its review of the licensing documentation for the SSF, the NRC staff has concluded that pre-existing non-QA-1 components supporting the SSF functions were not previously required to be upgraded or replaced with QA-1 components. The proposed revision of ONS UFSAR Section 3.1.1.1 does not relax the current QA requirements for pre-existing non-QA-1 equipment supporting the SSF function. All pre-existing non.,.QA-1 components supporting the SSF function were determined by the licensee to be capable of performing their intended functions in the environments associated with SSF-mitigated events. The application of the ONS QA program ensures that activities involving pre-existing non-QA-1 components that support the SSF functiqn are controlled to an extent consistent with their importance to safety. The NRC staff therefore

• finds that the proposed revision to ONS UFSAR Section 3.1.1.1 is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the South Carolina State official was notified of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite,, and that there is no significant increase in individual or cumulative occupational radiation ~xposure. The Commission

has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding, which was published in the Federal Register on February 19, 2014 (79 FR 9493). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded; based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: E. Davidson Date: September 25, 2014

S. Batson A Notice of Issuance will be included in the Commission's biweekly Federal Register notice. If you have any questions, please contact me at 301-415-4032.

Sincerely,

/RA James R. Hall, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287

Enclosures:

1. Amendment No. 387 to DPR-38

2. Amendment No. 389 to DPR-47

3. Amendment No. 388 to DPR-55 4: Safety Evaluation cc w/ends: Distribution via Listserv DISTRIBUTION:

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