ML15314A359

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Duke Energy Draft RAIs Request to Adopt TSTF-523 (CAC Nos. MF6413-MF6422)
ML15314A359
Person / Time
Site: Oconee, Mcguire, Catawba, Harris, Brunswick, McGuire  Duke Energy icon.png
Issue date: 11/10/2015
From: Jeffrey Whited
Plant Licensing Branch II
To:
Whited J
References
Download: ML15314A359 (2)


Text

DRAFT DRAFT REQUEST FOR ADDITIONAL INFORMATION OFFICE OF NUCLEAR REACTOR REGULATION LICENSE AMENDMENT REQUEST TO ADOPT TSTF-523 DUKE ENERGY CAROLINAS, LLC AND DUKE ENERGY PROGRESS, INC BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 CATAWBA NUCLEAR STATION, UNITS 1 AND 2 MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 DOCKET NOS. 50-325, 50-324, 50-400, 50-413, 50-414, 50-369, 50-370, 50-269, 50-270, AND 50-287 By letter dated June 24, 2015,1 Duke Energy Progress, Inc., and Duke Energy Carolinas, LLC (Duke Energy) submitted a license amendment request (LAR) for U.S. Nuclear Regulatory Commission (NRC) approval for the subject sites. The proposed change revises or adds Surveillance Requirements (SRs) to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification. These changes are requested to address the concerns discussed in NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems.2 Duke Energy stated in their LAR that the proposal was consistent with Technical Specifications Task Force (TSTF) Traveler

- 523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation.3 Contrary to the above statement, in its LAR, Duke Energy proposed a 92 day surveillance frequency for Brunswick SRs 3.5.1.1, 3.5.3.1, and 3.6.2.3.3 and Shearon Harris SR 4.6.2.1.e.

This differs from the 31 day surveillance frequency for the SRs requested for the other referenced sites. The NRC Model Safety Evaluation,4 specifies a 31 day surveillance frequency for the SRs. The NRC staff has reviewed the licensees submittal and determined that responses to the following Request for Additional Information (RAI) questions are needed to clarify the proposed 92 day frequency, and to complete our review.

1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML15175A438.

2 ADAMS Accession No. ML072910759.

3 ADAMS Accession No. ML13053A075.

4 ADAMS Accession No. ML13255A169.

RAI 1: Provide the Brunswick surveillance history regarding managing gas accumulation, starting in 2008, that includes the surveillance date; the location; the measured, allowable, and as-left void volumes; the number of days since the last surveillance; the TS surveillance frequency; and clarification comments. Do not include surveillance detail that determined existence of a water-solid condition. Include the total number of Brunswick surveillances.

RAI 2: The proposed Technical Specification Bases for Brunswick SR 3.4.7.2, as submitted with the LAR, state, in part, that:

Gas accumulation in the RHR shutdown cooling (SDC) suction flow path is satisfactorily addressed by procedures which fill the system prior to placing SDC in service.

Is a follow-up measurement of high point voids conducted to assess the acceptability of the filling process?

RAI 3: Provide justification for selection of a 92 day frequency in Shearon Harris SR 4.6.2.1.e.

Include the RAI 1 and 2 information categories in the response when applicable.

DRAFT DRAFT REQUEST FOR ADDITIONAL INFORMATION OFFICE OF NUCLEAR REACTOR REGULATION LICENSE AMENDMENT REQUEST TO ADOPT TSTF-523 DUKE ENERGY CAROLINAS, LLC AND DUKE ENERGY PROGRESS, INC BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 CATAWBA NUCLEAR STATION, UNITS 1 AND 2 MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 DOCKET NOS. 50-325, 50-324, 50-400, 50-413, 50-414, 50-369, 50-370, 50-269, 50-270, AND 50-287 By letter dated June 24, 2015,1 Duke Energy Progress, Inc., and Duke Energy Carolinas, LLC (Duke Energy) submitted a license amendment request (LAR) for U.S. Nuclear Regulatory Commission (NRC) approval for the subject sites. The proposed change revises or adds Surveillance Requirements (SRs) to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances which permit performance of the verification. These changes are requested to address the concerns discussed in NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems.2 Duke Energy stated in their LAR that the proposal was consistent with Technical Specifications Task Force (TSTF) Traveler

- 523, Revision 2, Generic Letter 2008-01, Managing Gas Accumulation.3 Contrary to the above statement, in its LAR, Duke Energy proposed a 92 day surveillance frequency for Brunswick SRs 3.5.1.1, 3.5.3.1, and 3.6.2.3.3 and Shearon Harris SR 4.6.2.1.e.

This differs from the 31 day surveillance frequency for the SRs requested for the other referenced sites. The NRC Model Safety Evaluation,4 specifies a 31 day surveillance frequency for the SRs. The NRC staff has reviewed the licensees submittal and determined that responses to the following Request for Additional Information (RAI) questions are needed to clarify the proposed 92 day frequency, and to complete our review.

1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML15175A438.

2 ADAMS Accession No. ML072910759.

3 ADAMS Accession No. ML13053A075.

4 ADAMS Accession No. ML13255A169.

RAI 1: Provide the Brunswick surveillance history regarding managing gas accumulation, starting in 2008, that includes the surveillance date; the location; the measured, allowable, and as-left void volumes; the number of days since the last surveillance; the TS surveillance frequency; and clarification comments. Do not include surveillance detail that determined existence of a water-solid condition. Include the total number of Brunswick surveillances.

RAI 2: The proposed Technical Specification Bases for Brunswick SR 3.4.7.2, as submitted with the LAR, state, in part, that:

Gas accumulation in the RHR shutdown cooling (SDC) suction flow path is satisfactorily addressed by procedures which fill the system prior to placing SDC in service.

Is a follow-up measurement of high point voids conducted to assess the acceptability of the filling process?

RAI 3: Provide justification for selection of a 92 day frequency in Shearon Harris SR 4.6.2.1.e.

Include the RAI 1 and 2 information categories in the response when applicable.