ML14315A086
| ML14315A086 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 11/05/2014 |
| From: | Martha Barillas Plant Licensing Branch II |
| To: | Hightower R Duke Energy Corp |
| References | |
| MF2717 | |
| Download: ML14315A086 (4) | |
Text
1 NRR-PMDAPEm Resource From:
Barillas, Martha Sent:
Wednesday, November 05, 2014 2:47 PM To:
Richard.Hightower@duke-energy.com
Subject:
DRAFT RAI for TS 3.8.1 LAR (MF2717)
Attachments:
DRAFT RAI TS 3.8.1 STSB MF2717.docx Richard, By letter dated September 10, 2013 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML13261A289), as supplementd by letters dated January 30, 2014 (ADAMS No.
ML14037A105), and June 1, 2014 (ADAMS No. ML14163A480), Duke Energy Progress, Inc. (the licensee),
requested an amendment to Facility Operating License No. DPR-23 for H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2. The proposed license amendment will modify the current HBRSEP Required Actions (RAs) B.3.1, B.3.2.1, and B.3.2.2 of Technical Specification 3.8.1, AC Sources-Operating.
To complete its review, the NRC staff has the following draft request for additional information (RAI) attached to this email.
If you need a clarification call, please contact me to schedule the call as soon as possible.
A response to the attached draft RAI is requested to be provided by December 22, 2014.
A letter is forthcoming.
Respectfully, Martha Barillas Project Manager Shearon Harris & H. B. Robinson NRR/DORL/Licensing Branch II-2 US Nuclear Regulatory Commission 301-415-2760
Hearing Identifier:
NRR_PMDA Email Number:
1680 Mail Envelope Properties (Martha.Barillas@nrc.gov20141105144700)
Subject:
DRAFT RAI for TS 3.8.1 LAR (MF2717)
Sent Date:
11/5/2014 2:47:26 PM Received Date:
11/5/2014 2:47:00 PM From:
Barillas, Martha Created By:
Martha.Barillas@nrc.gov Recipients:
"Richard.Hightower@duke-energy.com" <Richard.Hightower@duke-energy.com>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 1152 11/5/2014 2:47:00 PM DRAFT RAI TS 3.8.1 STSB MF2717.docx 27365 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
DRAFT REQUEST FOR ADDITIONAL INFORMATION H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 LICENSE AMENDMENT REQUEST TO REVISE TS 3.8.1 DIESEL GENERATOR TESTING REQUIREMENTS (TAC NO. MF2717)
By letter dated September 10, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13261A289), as supplements by letters dated January 30, 2014 (ADAMS No. ML14037A105), and June 1, 2014 (ADAMS No. ML14163A480), Duke Energy Progress, Inc. (the licensee), requested an amendment to Facility Operating License No. DPR-23 for H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2. The proposed license amendment will modify the current HBRSEP Required Actions (RAs) B.3.1, B.3.2.1, and B.3.2.2 of Technical Specification 3.8.1, AC Sources-Operating. The RAs specify that Surveillance Requirement (SR) 3.8.1.2 be performed or an assessment to rule out common cause failure along with the SR when one Diesel Generator (DG) is determined inoperable. The proposed change will modify the RAs with a note which states, "Not required to be performed if the cause of the inoperable DG is solely due to pre-planned maintenance or Surveillance testing."
The 10CFR 50.36(a)(1) states, in part: A summary statement of the bases or reason for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the Technical Specifications [TSs]. The licensee submitted a response dated June 1, 2014 to the staff Request for Additional Information (RAI).
The responses show a mismatch of information between the TS and Bases. Clarification is requested such that the TS clearly provide the Required Actions (RAs), and the Bases provide amplifying information only.
STSB RAI-3 License amendment request letter dated September 10, 2013, summary description, Paragraph 2 states, in part:
The Note will exempt performance of this conditional surveillance when the cause of the initial inoperability of the inoperable DC is pre-planned maintenance and testing. The exemption will not apply whenever the cause of the inoperability is corrective maintenance, even if the problem required corrective maintenance is discovered during the execution of the original pre-planned maintenance and testing.
Clarify RAs 3.8.1.B.3.1, B.3.2.1 and B.3.2.2 to indicate the circumstances under which Condition B must be initially entered and re-entered for correct maintenance issues identified during preventative maintenance activities.
STSB RAI-4 In the RAI response dated June 1, 2014, the following inconsistencies have been identified:
The mark-up page indicates the Note will be positioned above the AND. On the clean page the Note is below the AND.
According to the Bases 3.8.1 Insert 1, A NOTE has been added to take exception to perform REQUIRED ACTION B.3.1 or B.3.2 In STS, a Note
only applies to the Required Action directly below it, unless directly specified in the Note. Therefore the Note only applies to B.3.1. Please clarify where the Note is applicable.
Clarify corrections to the mark-up and clean pages so that the intent of the TS is clear.
STSB RAI-5 In the RAI response dated June 1, 2014, only the proposed TS pages were submitted. Please revise your submittal to reflect a description and evaluation of all proposed changes to the TS.