ONS-2015-095, Tornado Regulatory Commitments 15T and 17T - Due Date Revision

From kanterella
(Redirected from ML15278A019)
Jump to navigation Jump to search
Tornado Regulatory Commitments 15T and 17T - Due Date Revision
ML15278A019
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 09/29/2015
From: Batson S
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
ONS-2015-095
Download: ML15278A019 (12)
v • d • e


Text

Scott L. Balson ENERGYS..

Oconee Nuclear Station

~DUKE Duke Energ QNOIVP I 7600 RochesterHwy Seneca, SC 29672 o: 864.873.3274

f. 864.873. 4208 Scott.Batson@duke-energy.com ONS-201 5-095 September 29, 2015 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Duke Energy Carolinas, LLC (Duke Energy)

Oconee Nuclear Station, Units 1, 2 and 3 Docket Numbers 50-269, 50-270, 50-287 Renewed License Numbers DPR-38, DPR-47, and DPR-55

Subject:

Tornado Regulatory Commitments 15T and 17T - Due Date Revision

References:

1. Duke Energy Letter, "Tornado/HELB Mitigation Strategies and Regu/atory Commitments,"

dated November 30, 2006.

2. Duke Energy Letter, "Revision to Tormado/HELB Mitigation Strategies and Regulatory Commitment 177","dated December 19, 2014.

Duke Energy's initial commitments related to tornado mitigation strategies are documented in a November 30, 2006 submittal (Ref. 1). This commitment list was most recently updated in a Duke Energy submittal dated December 19, 2014 (Ref. 2). As contained in that December 19, 2014 letter, Duke Energy was to provide a completion date for tornado commitment 17T. Commitment 17T is to improve the tornado protection of the Standby Shutdown Facility (SSF) double doors.

The SSF Double Door is an 8 foot wide by 12-foot high opening in the SSF building at the south end that is surrounded by a protective concrete enclosure on all sides except toward the east.

In order to provide enhanced protection of the double doors, a robust steel enclosure structure will be built, consisting of a passive design founded on an independent foundation system located immediately adjacent to the SSF Patio/Flood wall. This modification will be completed by March 31, 2017, and will improve the station's ability to withstand a damaging tornado missile. The attachment to this submittal contains the complete Tornado and High Energy Line Break (HELB)~commitment list and status.

In addition, tornado commitment 15T, which analyzes the double column set outside the containment building supporting each unit's Main Steam lines and provides modifications to meet tornado protection criteria, was inadvertently marked as complete on the list. Specifically, although the analyses had been completed, the associated modifications remain to be implemented. Consequently, Duke Energy has revised the list to show the commitment open with a due date of December 7, 2017.

  • U. S. Nuclear Regulatory Commission September 29, 2015 Page 2 In accordance with tornado commitment 10T, Duke Energy has verbally notifed James M. Trapp, Deputy Director, Division of Operating Reactor Licensing, of this commitment change via telephone on September 29, 2015.

If you have any questions in regard to this letter, please contact Stephen C. Newman, Oconee Nuclear Station, Regulatory Affairs Group at (864) 873-4388.

Sincerely, Scott Batson Vice President, Oconee Nuclear Station attachment

I U. S. Nuclear Regulatory Commission September 29, 2015 Page 3 cc (w/attachment):

Mr. Leonard D. Wert Jr.

Administrator Region II (Acting)

U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, Georgia 30303-1257 Mr. James R. Hall Senior Project Manager (by electronic mail only)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop O-8G9A Rockville, Maryland 20852 Mr. J. A. Whited Project Manager (by electronic mail only)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop O-8G9A Rockville, Maryland 20852 Mr. Eddy Crowe NRC Senior Resident Inspector Oconee Nuclear Station Ms. Susan E. Jenkins, Manager Radioactive & Infectious Waste Management SC Dept. of Health and Environmental Control 2600 Bull St.

Columbia, SC 29201

Attachment Tornado and HELB Commitment List

Attachment - Tornado and HELB Commitment List September 29, 2015 Page 6 IT U3 Control Room North Wall Modification. Y 2T SSF Diesel Fuel Vent Modification. -Y 3T SSF and CT-5 Trenches Intersection Modification 3SF Trench at north y end of SSF (TORMIS).

4T Borated Water Storage Tank Modifications. -Y 5T West Penetration Room (WPR) and Cask Decontamination Tank Room y

___(CDTR) Wall Modifications.

6T Fiber Reinforced Polymer (FRP) LAR for strengthening selected masonry y walls for tornado wind and AP.

7T Tornado Mitigation Strategy LAR. -Y 8T PSW/HPI modifications. 2-4-2016 N 9T Missile inventory program developed. Y Verbally notify in advance the Deputy Director, Division of Reactor Licensing of the NRC, followed by a written communication, of significant I10T changes in the scope and/or completion dates of the commitments. The 2022 N notification will include the reason for the changes and the modified commitments and/or schedule.

l1T Installation of MSIVs. Ul: 2020 I 2T U2: 2021 N I13T U3: 2022 14T Fiber Reinforced Polymer (FRP) LAR for strengthening selected "brick" y masonry walls for tornado wind and AP.

Analyze the double column set which support each unit's Main Steam 15T lines outside of the containment building, and provide modifications, as 12-7-2017 N necessary, to meet tornado criteria Physically protect the Atmospheric Dump Valve's (ADV's) function per UIl: 2020 16T RGI1.76, Rev. 1. U2: 2021 N U3: 2022 Improve protection of the Standby Shutdown Facility (3SF) double doors 17T (large 8'x12' doors located on the south side of the 3SF structure) per 3-31-2017 N UFSAR SSF tornado criteria.

Revise and clarify the tornado LB description as documented in UFSAR Afe Section 3.2.2; add the TORMIS methodology results to UFSAR Section isac 18T 3.5.1.3, and correct inaccurate tornado design information for the Auxiliary of the Building Cable and Electrical Equipment Rooms as described in UFSAR SR Table 3-23.

The SSF BASES for TS 3.10.1 will be clarified to address degradation of Afe passive civil features as not applying to operability under Technical isac 19T Specifications Limiting Condition for Operation (TS LCO) 3*10.1, "Standby of the Shutdown Facility," but rather as UFSAR commitments outside of the SR ONS TS.

Attachment - Tornado and HELB Commitment List September 29, 2015 Page77

-- "- :E: . .... ... . . . ...""-: * - * .. .. ' ... .. . ' ... . - " " C o m p lete No..  : . ..------ Tornado Commitments.- '-*"- -- Due Date " (YIN)

Duke Energy will perform qualification testing and reporting in accordance 20T1 with ICC AC125 [Reference 5 of Enclosure 2] for the selected FRP -Y System.

Duke Energy will perform and document a technical evaluation of the FRP system (fibers and polymeric resin) in accordance with Duke Energy's Supply Chain Directive SCD230 [Reference 7 of Enclosure 2] to 21T demonstrate that:y

1. The item qualifies as a commercial grade item.
2. The supplier is capable of supplying a quality product.
3. The quality of the item can be reasonably assured.

Duke Energy will utilize technical procedures to control testing of concrete 22T substrate and installation and inspection of the FRP system in accordancey with ICC AC125 [Reference 5 of Enclosure 2], ACI 440.2R-02 [Reference 6 of Enclosure 2], and ICC AC178 [Reference 8 of Enclosure 2].

Duke Energy will perform long-term inspection of the FRP system as described in UFSAR Section 18.3.13 and EDM-410, and in accordance with ICC AC125 [Reference 5 of Enclosure 2], ACl 440.2R-02 [Reference 6 of Enclosure 2], and ICC AC178 [Reference 8 of Enclosure 2], on a nominal 5 year interval. This inspection frequency may be reduced to a nominal 10 year interval with appropriate justification based on the structure, environment, and previous long-term inspection results.

23T Inspections of the installed FRP system will include:Y

  • visual inspections of test walls and selected portions of WPR walls for changes in color, debonding, peeling, blistering, cracking, crazing, deflections and other anomalies; and,
  • tension adhesion testing of cored samples taken from test walls using methods specified in ASTM D4541 [Reference 9 of Enclosure 2] or ACI 530R-02 [Reference 16 of Enclosure 2].

Duke Energy will perform qualification testing and reporting in accordance 24T2 with ICC AC125 [Approved 10/2006, Effective 1/1/2007] for the selected -Y FRP System.

Duke Energy will perform and document a technical evaluation of the FRP system (fibers and polymeric resin) in accordance with Duke Energy's Supply Chain Directive SCD23O [Reference 7 of Enclosure 2] to 25T demonstrate that:y

  • The supplier is capable of supplying a quality product.
  • The quality of the item can be reasonably assured.

Duke Energy will utilize technical procedures to control testing of concrete substrate and installation and inspection of the FRP system in accordance 26T with ICC AC125 [Approved 10/2006, Effective 1/1/2007], ACl 440.2R-02 -Y

[Effective 7/1/2002], and ICC AC178 [Approved 6/2003, Effective 7/1/2003, editorially revised 6/2008].

Tornado commitments 20-23 originate from the FRP LAR dated 6-1 -2006 (NRC SER dated 2-21-2008).

2 Tornado commitments 20-26 are addressed inthe NRC's FRP SER for brick masonry dated 6-27-2011.

Attachment - Tornado and HELB Commitment List September 29, 2015 Page 8 No.I ," ., ....----- . .Tornado Commitments-- -1i;-: Due Date. "(YIN)-

Duke Energy will implement a long-term inspection program of the FRP system that will be described in UFSAR Section 18.3.13 and EDM-410, meet the requirements of ICC AC 125 [Approved 10/2006, Effective 1/1/2007], ACI 440.2R-02 [Effective 7/1/2002], and ICC AC178 [Approved 6/2003, Effective 7/1/2003, editorially revised 6/2008], on the following schedule: at each unit's outage cycle for the first six years from 2012 through 2017, then, if justified based on no observed FRP degradation, transition to every-other outage cycle for the next four years from 2018 through 2021, then, if justified based on continued no observed FRP degradation, transition to every third outage cycle thereafter from 2022 until end of license in July 2034. Inspections of the installed FRP system will include:

  • visual inspections of test walls and portions (both random and controlled locations) of WPR in-service walls for changes in color, debonding, peeling, blistering, cracking, 27T *crazing, deflections and other anomalies; 27T
  • tension adhesion testing of cored samples taken from"Y designated test walls using methods specified in ASTM 07234; and,
  • visual inspections of mortar joints located along the bottom edge of FRP-strengthened masonry walls.

For each inspection interval, the portions of FRP-strengthened masonry walls to be inspected will be chosen in accordance with a sampling plan developed from guidance provided by a) Draft Regulatory Guide DG-1070, 'Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for use in Nuclear Power Plants", and b) EPRI NP-7218 document "Guidelines for the Utilization of Sampling Plans for Commercial Grade Item Acceptance" (NCIG-1 9), as implemented at ONS by Supply Chain Directive SCD-290 [(new) Reference 21 of Enclosure 2].

Note: This response replaces the five (5) year inspection commitment made in FRP LAR (No. 2009-05) dated June 29, 2009, and will apply to the FRP application for both block and brick.

Duke Energy will install mechanical shear restraints along the brick 28T masonry wall perimeter (top and sides only) and block masonry wall _y perimeter (top only) to remediate potentially limiting conditions of construction.

29T Duke Energy will incorporate the FRP testing and inspection program intoy Oconee Nuclear Station's Aging Management Program.

As discussed with the Staff, Fyfe Company, LLC, the manufacturer of the 30T FRP products, will provide Duke Energy with a Certificate of Compliancey certifying that both the FRP product and its installation meet all applicable requirements.

Attachment - Tornado and HELB Commitment List September 29, 2015 Page 9

' .. " ... .. . .. . ." . . .. ... i* * * * :Com plete SNo., .* - .. - -- HELB Commitments .... "i-,"  ;"--DUe Date. ..- YN -

1H Implement an inspection program for the Aux Bldg MS and -Y FW girth and accessible attachment welds.

2H Implement an inspection program for other Aux. Bldg high -Y

____energy piping critical crack locations at welds.

3H Initial ASME Section Xl ISI interval UT of the Aux. Bldg MS -Y and FW girth welds and accessible attachment welds.

4H Initial ASME Section Xl ISI interval UT of other Aux. Bldg -Y high energy piping critical crack locations at welds.

5H Implement an inspection program for accessible piping -Y base metal downstream of the FW isolation valves located in the EPR.

6H Implement an inspection program for accessible piping -Y base metal of other Aux. Bldg high energy piping critical crack locations not at welds.

7H Initial ASME Section Xl ISI interval UT inspection of piping -Y base metal downstream of FW isolation valves located in the EPR.

8H Initial ASME Section Xl ISI interval UT inspection for Y accessible piping base metal of other Aux. Bldg high energy piping critical crack locations not at welds.

9H Implement an inspection program of accessible attachment -Y welds at the terminal ends inside the FW guard pipe.

I0H Initial visual inspections of accessible attachment welds at -Y the terminal ends inside the FW guard pipe.

I11H Inspect and repair the Unit 2 East Penetration Room Y electrical penetration termination enclosures to their correct configuration. Missing and/or damaged covers, gaskets, and fasteners will be repaired or replaced.

12H Inspect and repair the Unit I East Penetration Room Y electrical penetration termination enclosures to their correct configuration. Missing and/or damaged covers, gaskets, and fasteners will be repaired or replaced.

13H Inspect and repair the Unit 3 East Penetration Room Y electrical penetration termination enclosures to their correct configuration. Missing and/or damaged covers, gaskets, and fasteners will be repaired or replaced.

14H Create an inspection plan to select a portion of Units 1, 2 -Y and 3 enclosures to open and inspect for signs of internal debris and corrosion.

15H Revise station procedures and processes as needed to - Y ensure penetration termination enclosures are maintained in their correct configurations.

16H Complete the design and installation of flood outlet devices - Y for the Unit I East Penetration Room.

Attachment - Tornado and HELB Commitment List September 29, 2015 Page 10 No. - --- HELB*Commitments... - ..-. Due Date- Complete-17H Complete the design and installation of flood outlet devices -Y for the Unit 2 East Penetration Room.

I18H Complete the design and installation of flood outlet devices -Y for the Unit 3 East Penetration Room.

19H Complete the design and installation of flood impoundment -Y and exterior door flood improvement features for the Unit I East Penetration Room 20H Complete the design and installation of flood impoundment -Y and exterior door flood improvement features for the Unit 2 East Penetration Room.

2IH Complete the design and installation of flood impoundment -Y and exterior door flood improvement features for the Unit 3 East Penetration Room.

22H- HELB LB and Mitigation Strategy LARs. Y 23H 24H 25H Verbally notify in advance the Deputy Director, Division of 2022 N Reactor Licensing of the NRC, followed by a written communication, of significant changes in the scope and/or completion dates of the commitments. The notification will include the reason for the changes and the modified commitments and/or schedule.

26H The inlet isolation valves to the Letdown Coolers on the To be provided toN Letdown Line (1HP-I & I1HP-2) will be upgraded to permit the Staff upon their use following a postulated HELB on the Letdown Line issuance of the at Containment Penetration No. 6. With these valves SER.

upgraded, either could then be closed if either of the inboard containment isolation valves (1HP-3 & IHP-4) fails to close in order to mitigate the postulated HELB on the Letdown line.

27H The ducting near the Control Complex is being upgraded To be provided to N with duct registers or cover plates to prevent the potential the Staff upon propagation of the HELB generated environment in the issuance of the East Penetration Room to the Control Complex. SER.

28H The valves (I HP-i103 & 1HP-1 07) on the individual suction -Y lines to the "A" & "B" High Pressure Injection (HPI) pumps are being upgraded to allow the remote operation (operated outside the HPI pump room) of these valves.

The remote operation of these valves allow the isolation of postulated HELBs on the discharge side of the HPI Pumps without compromising the availability of the other HPI Pumps and the need for maintaining the Letdown Storage Tank aligned to the HPI Pump suction piping. For a single active failure of either valve 1lHP-103 or 1 HP-107 to close, a redundant, remotely operated valve is provided on each of the HPI Pumps "A" and "B" to assure HELB mitigation.

Attachment - Tornado and HELB Commitment List September 29, 2015 Page 11

.No." *, ,.-.

-.- ... - ... HELB.. Commitments . .. ... i- '.: '*" ... Due_Date Comp(YIete 29H The position of several Plant Heating System isolation - Y valves is being changed from "OPEN' to "CLOSED." This position change will eliminate the need to postulate Plant Heating System HELBs in the East Penetration Room and West Penetration Room, because these piping lines will isolated during normal plant conditions of the station.

30H Turbine Building structural support column 0-26 will be To be provided to N modified by adding a brace to the column. This brace is the Staff upon necessary to prevent potential failure of the column, when issuance of the subjected to a pipe whip load. This upgrade prevents the SER.

loss of the routing to get temporary cabling to the Low Pressure Injection and Low Pressure Service Water pump motors.

31 H The existing Condenser Circulating Water (CCW) To be provided to N discharge stop gates will be replaced and four (4) new stop the Staff upon gates will be obtained. These stop gates will be used to issuance of the terminate all reverse flow through HELB damaged Low SER.

Pressure Service Water and CCW piping. This modification is required, in order to recover from a Turbine Building flood event caused by a postulated HELB therein.

32H Evaluate the ability of the Standby Shutdown Facility to - Y perform its safety functions with a compromised main steam pressure boundary due to potential breaks in the main steam system and other HELBs.

33H Weep holes will be installed in the bottom of the outside- - Y containment junction box enclosures for the Viking Electrical Penetrations. Also, the electrical penetration inspection procedure is being amended to inspect the weep holes for blockage 34H The inlet isolation valves to the Letdown Coolers on the To be provided to N Letdown Line (2HP-I& 2HP-2) will be upgraded to permit the Staff upon their use following a postulated HELB on the Letdown Line issuance of the at Containment Penetration No. 6. With these valves SER.

upgraded, either could then be closed ifeither of the inboard containment isolation valves (2HP-3 & 2HP-4) fails to close in order to mitigate the postulated HELB on the Letdown line.

35H The Unit 2 HVAC ducting near the Control Complex is To be provided to N being upgraded with duct registers or cover plates to the Staff upon prevent the potential propagation of the HELB generated issuance of the environment in the East Penetration Room to the Control SER.

___Complex. ________

Attachment - Tornado and HELB Commitment List September 29, 2015 Page 12 I 36H The valves (2HP-103 & 2HP-1 07) on the individual suction To be provided to N lines to the "A"& "B" High Pressure Injection (HPI) pumps the Staff upon are being upgraded to allow the remote operation issuance of the (operated outside the HPI pump room) of these valves. SER.

The remote operation of these valves allow the isolation of postulated HELBs on the discharge side of the HPI pumps without compromising the availability of the other HPI Pumps and the need for maintain the Letdown Storage Tank aligned to the HPI Pump suction piping. For a single active failure of either valves 2HP-103 or 2HP-1 07 to close, a redundant, remotely operated valves is provided on each of the HPI Pumps "A"and "B"to assure HELB mitigation.

37H The position of several Unit 2 Plant Heating System Y isolation valves is being changed from "OPEN" to "CLOSED." This position change will eliminate the need to postulate Plant Heating System HELBs in the East Penetration Room and West Penetration Room, because these piping lines will be isolated during normal plant conditions of the station.

38H Turbine Building structural support Column 0-29 & D-31 To be provided to N will be modified by adding a brace to the column. This the Staff upon brace is necessary to prevent potential failure of the issuance of the column, when subjected to a pipe whip load. SER.

39H Weep holes will be installed in the bottom of the Unit 2 -Y outside-containment junction box enclosures for the Viking Electrical Penetrations. Also, the electrical penetration inspection procedure is being amended to inspect the weep holes for blockage. ________

40H The inlet isolation valves to the Letdown Coolers on the To be provided to N Letdown Line (3H P-i and 3HP-2) will be upgraded to the Staff upon permit their use following a postulated HELB on the issuance of the Letdown Line at Containment Penetration No. 6. With SER.

these valves upgraded, either could then be closed ifeither of the inboard containment isolation valves (3HP-3 and 3HP-4) fails to close in order to mitigate the postulated HELB on the Letdown Line.

41 H The Unit 3 Auxiliary Building HVAC ducting near the Unit 3 To be provided to N Control Complex is being upgraded with duct registers or the Staff upon cover plates to prevent the potential propagation of the issuance of the HELB generated environment in the East Penetration SER.

Room to the Unit 3 Control Complex.

Attachment - Tornado and HELB Commitment List September 29, 2015 Page 13 42H The valves (3HP-103 and 3HP-1 07) on the individual Y suction lines to the "A"and "B" High Pressure Injection (HP1) pumps are being upgraded to allow the remote operation (operated outside the HPI pump room) of these valves. The remote operation of these valves allow the isolation of postulated HELBs on the discharge side of the HPI Pumps without compromising the availability of the other HPI Pumps and the need for maintaining the Letdown Storage Tank aligned to the HPI Pump suction piping. For a single active failure of either valve 3HP-1 03 or 3HP-1 07 to close, a redundant, remotely operated valve is provided on each of the HPI Pumps "A"and "B" to assure HELB mitigation.__ _____

43H The position of the Unit 3 Plant Heating System isolation -Y valve 3AS-1 82 being changed from "OPEN" to "CLOSED."

This position change will eliminate the need to postulate Plant Heating System HELBs in the East Penetration Room and West Penetration Room, because these piping lines will be isolated during Normal Plant Conditions of the station.

44H Turbine Building structural support columns M-20 (Unit 1), To be provided to N M-35 (Unit 2), D-43 and D-45 (Unit 3), M-49 (Unit 3), and L- the Staff upon 47 (Unit 3) will be modified by adding a brace or issuance of the reinforcement to each column. These modifications are SER.

necessary to prevent potential failure of the column(s),

when subjected to a pipe whip load.

45H Weep holes will be installed in the bottom of the Unit 3 -Y outside-containment junction box enclosures for the Viking Electrical Penetrations. Also, the electrical penetration inspection procedure is being amended to inspect the weep holes for blockage._______________

Retrieved from "https://kanterella.com/w/index.php?title=ONS-2015-095,_Tornado_Regulatory_Commitments_15T_and_17T_-_Due_Date_Revision&oldid=2028333"