RA-17-0030, Response to Request for Additional Information Regarding Application to Reverse Technical Specifications to Adopt Multiple Technical Specification Task Force Travelers

Response to Request for Additional Information Regarding Application to Reverse Technical Specifications to Adopt Multiple Technical Specification Task Force Travelers

ML17159A688
Person / Time
Site:	Mcguire, McGuire
Issue date:	06/08/2017
From:	Capps S Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-17-0030
Download: ML17159A688 (6)

Text

Steven D. Cspps

( -, DUKE Vice Ptesident ENERGY. McGuire Nuclear Station Duke Energy MG01 VP 112700 Hagers Ferry Road Huntersville, NC 28078

a. 980.875.4805 f: 704.875.4809 Steven.Capps@cluke-energy ~

Serial: RA-17-0030 10 CFR50.90 June 8, 2017 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

MCGUIRE NUCLEAR STATION, UNITS 1AND2 DOCKET NOS. 50.369 AND 50*370 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT MULTIPLE TECHNICAL SPECIFICATION TASK FORCE TRAVELERS

REFERENCES:

1. Duke Energy letter RA-17-0003, McGuire Nuclear Station, Units 1 and 2, Application to Revise Technical Specifications to Adopt Multiple Technical Specification Task Force Travelers, dated January 11, 2017 (ADAMS Accession No. ML17025A069)

2. NRC electronic mail, M. Mahoney to Duke Energy's A. Zaremba, Request for Additional Information-McGuire TSTF-197, dated May 12, 2017 By letter dated January 11, 2017 (Reference 1). Duke Energy Carolinas, LLC, referred to henceforth as "Duke Energy," submitted a request for amendments to the Technical Specmcations (TSs) for McGuire Nuclear Station, Units 1and2 (MNS). In Reference 2, the NRC staff provided a Request for Additional Information (RAI) regarding the January 11, 2017, license amendment application, applicable to MNS. The Attachment provides Duke Energy's response to this RAI.

The information provided in this letter does not affect the conclusions of the significant hazards consideration or the environmental consideration included in the January 11, 2017, license amendment application.

This submittal contains no new regulatory commitments. In accordance with 10 CFR 50.91, Duke Energy is transmitting a copy of this letter and attachment to the designated State Officials.

Should you have any questions concerning this letter, or require additional information, please contact Art Zaremba, Manager - Nuclear Fleet Licensing, at (980) 373-2062.

U.S. Nuclear Regulatory Commission RA-17-0030 Page2 I declare under penalty of perjury that the foregoing is true and correct. Executed on June a.

2017.

Sincerely, Steven Capps Vice President - McGuire Nuclear Station NOE

Attachment:

Response to NRC Request for Additional Information xc (with Attachment):

C. Haney, USNRC Region II - Regional Administrator G. A. Hutto. USNRC Senior Resident Inspector - MNS M. Mahoney, NRR Project Manager - MNS W. L Cox Ill, Section Chief, NC Dept. of Health and Human Services, Radiation Protection Section

Attachment RA-17-0030 Page 1of4 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION NRC Comment: By letter dated January 11. 2017 (Agencywide Documents Access Management System (ADAMS) Accession No. ML17025A069). Duke Energy (the licensee),

submitted an application to revise McGuire Nuclear Station, Units 1 and 2 (MNS) Technical Specifications (TS) to adopt multiple Technical Specification Task Force (TSTF) Travelers, specifically TSTF-197-A, Revision 2, "Require containment closure when shutdown cooling requirements are not met," (CAC Nos. MF9110 and MF9111).

In order to complete its review, the U.S. Nuclear Regulatory Commission staff requests the following additional infonnation. Please provide your response to the attached request for additional Information within 30 days of the date of this correspondence.

RAl-1 The Improved Standard TS markups for TS 3.9.5 Required Action A.6.2 and TS 3.9.6 Required Action 8 .5.2, as Included in TSTF-197-A for NUREG-1431, are proposed to read: "Verify each penetration is capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System." The LAR proposes the new MNS TS 3.9.5 Required Action A.6.2 and TS 3.9.6 Required Action B.5.2 to deviate from the TSTF-197-A language, as follows: "Verify each penetration is capable of being closed on a high containment radiation signal." It is stated, in part, in your application, "MNS does not have a Containment Purge Exhaust Isolation System." However, section 9.4.5.2 of MNS's Updated Final Safety Analysis Report (USFAR) describes the "Containment Purge and Ventilation System."

A. Explain why your application states that MNS does not have a Containment Purge and Exhaust System Isolation System when USFAR 9.4.5.2 suggests such a system exists.

B. Does MNS have a system that performs the function of containment purge and exhaust isolation?

C. If so, please explain why the proposed new MNS Required Actions A.6.2 and 8.5.2 require verification that each penetration is capable of being closed on a high containment radiation signal, and not by the system that performs the function of containment purge and exhaust isolation.

Duke Energy Response:

Page 8 of Enclosure 1 of the January 11, 2017 license amendment application states, in part:

At MNS, as described in UFSAR Section 6.2.4.1, the containment purge valves close on a Phase A Containment Isolation Signal (SI) or a high containment activity signal.

Also note that per TS Table 3.3.2-1. Safety Injection (SI) is required to be operable only In Modes 1 through 4, whereas TS 3.9.5 and TS 3.9.6 are applicable in Mode 6.

Therefore, the relevant containment purge valve closure signal in Mode 6 is the high containment activity signal. The containment high radiation monitor is addressed in Selected Licensee Commitment (SLC) 16.7.6, URadiation Monitoring for Plant Operationsn. but not in TS.

MNS UFSAR Section 6.2.4 discusses the containment isolation systems. UFSAR Section 6.2.4.1 states, in part:

Attachment RA-17-0030 Page 2of4 Upon receipt of either a phase A(T) Containment isolation signal which is derived from the safety injection signal or a phase B(P) Containment Isolation signal which is derived from the high-high Containment pressure signal, the Containment Isolation System closes fluid line penetrations not required for Engineered Safety Features operation. The valves which are used to isolate purge line penetrations opening directly to the Containment atmosphere close upon occurrence of a phase A Containment isolation signal or a high Containment activity (H) signal.

In addition to UFSAR Section 6.2.4, relevant information is provided elsewhere in the MNS UFSAR. UFSAR Section 9.4 describes various air conditioning, heating. cooling and ventilation systems. UFSAR Section 9.4.5 describes those systems applicable to the containment.

UFSAR Section 9.4.5.1 states, in part:

The Containment Purge and Ventilation System is designed to maintain temperature in the various portions of the Containment within acceptable limits for operation of equipment and for personnel access for inspection, maintenance and testing as required. It also has capability for purging the Containment atmosphere to the environment via the unit vent. The system is not an Engineered Safety Feature.

As stated in UFSAR Section 9.4.5.2, the "Containment Purge Supply and Exhausr is a subsystem of the Containment Purge and Ventilation System. UFSAR 9.4.5.2 includes these additional details:

There are five purge air supply penetrations and four purge air exhaust penetrations in the Containment. These penetrations are in the upper compartment, lower compartment and lncore Instrumentation area. Two normally closed isolation valves in each penetration provide Containment isolation.

During normal Plant operation. Modes 1-4, the containment purge and exhaust isolation valves are sealed closed. Generally. purging of Upper Containment and Lower Containment is performed during Mode 5, Mode 6 and may be performed during No Mode. The option to purge the lncore Instrumentation Area is not typically exercised. During fuel movement evolutions, purges normally last about 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> for unloading and 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> for loading.

UFSAR Section 9.4.5.2 does not describe how the containment penetrations associated with the purge system are isolated; however, UFSAR Section 9.4.5.3 includes the following details:

The purge systems isolation valves are normally sealed closed during unit operation, but the valves would close automatically on Containment isolation.

Safety injection and high radiation signals are provided to initiate the isolation of the Containment Purge Ventilation System. The safety injection signal includes high containment pressure signal actuation and is designed and qualified to Class 1E criteria.

In an accident. the containment purge and exhaust isolation valves are assumed to be closed (Modes 1-4).

A fuel handling accident inside containment has been analyzed assuming the purge

Attachment RA-17-0030 Page 3of 4 system is in operation during refueling operations. This analysis is described ln Section 15.7.4.

TS Table 3.3.2-1, "Engineered Safety Feature Actuation System Instrumentation," Function 3.a, provides the requirements for the Phase A containment isolation instrumentation, including the requirement for manual initiation capability in Modes 1 through 4, and automatic initiation upon a Safety Injection signal (referencing Function 1). Function 1 of TS Table 3.3.2-1 provides the requirements for the Safety Injection instrumentation, including the requirement for manual initiation capability in Modes 1 through 4, automatic initiation upon a Containment Pressure -

High signal in Modes 1 through 3, and automatic initiation upon a Pressurizer Pressure - Low Low signal in Modes 1 through 3 above the P-11 (Pressurizer Pressure) interlock. Note that none of this instrumentation is required to be operable in Modes 5 and 6. As noted in the license amendment application, the containment high radiation monitor is addressed in SLC 16.7.6 "Radiation Monitoring for Plant Operations." The same radiation monitor is also addressed in SLC 16.11 .7, "Radioactive Gaseous Effluent Monitoring Instrumentation." The SLC requirements for this radiation monitor apply in Modes 1 through 6. Although the containment purge penetrations receive an automatic isolation signal on a Phase A Containment Isolation Signal or a high containment activity signal, the Phase A signal is only applicable in Modes 1through4, and TS 3.9.5 and 3.9.6, are only applicable in Mode 6.

Accordingly, only the high containment activity signal is relevant to TS 3.9.5 and 3.9.6.

Use of the "Containment Purge and Exhaust Isolation System" terminology in TSTF-197 is consistent with Standard TS (STS) 3.3.6. "Containment Purge and Exhaust Isolation Instrumentation." The MNS TS previously Included the corresponding TS 3.3.6, "Containment Purge and Exhaust Isolation Instrumentation;" however, this TS was removed via License Amendments 243 and 224 on July 26, 2007 (ADAMS Accession No. ML071830539), and this terminology is no longer in use in the MNS TS.

In summary, use of the "Containment Purge and Exhaust Isolation System" terminology is outdated for MNS. Instrumentation is provided which performs the function of sending a signal to isolate the containment purge penetrations, and this instrumentation, as described in UFSAR Section 6.2.4.1, UFSAR Section 9.4.5.3, and TS Table 3.3.2-1, includes the Phase A Containment Isolation Signal and the high containment activity signal. The Phase A Containment Isolation Signal is only applicable in Modes 1 through 4, whereas the high containment activity signal is applicable in Modes 1 through 6. The proposed changes related to TSTF-197 involve MNS TS 3.9.5 and 3.9.6, both of which apply only in Mode 6. Therefore, the relevant containment purge valve closure signal is the high containment activity signal, and the proposed changes regarding TS 3.9.5 Required Action A.6.2 and TS 3.9.6 Required Action 8.5.2 are worded appropriately.

RAl-2 TS 3.9.5. Condition A, Required Action A.4 and TS 3.9.6, Condition B, Required Action B.3 are proposed to be revised. Part of the proposed changes are to add new Required Actions A.6.2 and B.5.2. Required Actions A.6.2 and 8.5.2 are proposed to state, "Verify each penetration is capable of being closed on a high containment radiation signal," with a Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Further, according to the licensee, the containment high radiation monitor is addressed in Selected Licensee Commitment (SLC) 16.7.10, "Radiation Monitoring for Plant Operations", but not in TS.

Attachment RA-17-0030 Page 4 of 4 Since the containment high radiation monitors are not addressed in TSs, explain how each penetration is verified as being capable of being closed on a high containment radiation signal in MODE 6 and how it is ensured that a high containment radiation signal is available and capable of performing its intended safety function.

Duke Energy Response:

As stated in the license amendment application, the containment high radiation monitor is addressed in SLC 16.7.6, "Radiation Monitoring for Plant Operations." The same radiation monitor is also addressed in SLC 16.11.7, "Radioactive Gaseous Effluent Monitoring Instrumentation." As background, the MNS SLC Manual is designated as Chapter 16 of the UFSAR and contains previous TS requirements which did not meet the criteria for inclusion in the TSs and hence, were relocated to this manual, as well as additional operational related commitments. Changes to the SLCs are considered a change in an NRC commitment and shall be made only in accordance with the requirements of an administrative procedure, which includes use of the 10 CFR 50.59 process. The intent of the SLCs Is to provide information regarding systems that are a part of the licensing basis, as described in the UFSAR, but are not of such a level of importance that they need to be under the rigorous control provided by TSs.

Most of the industry uses the term "Technical Requirements Manual (TRM)" rather than the term "SLC".

SLC 16.11.7 includes requirements for a collection of radiation monitoring instrumentation, including the Containment Purge System - Noble Gas Activity Monitor (Low Range - EMF-39).

The radioactive gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases of gaseous effluents. The monitors provide continuous display of process parameters with appropriate alarms and trip setpoints established. When the high radiation setpoint for the Containment Purge System - Noble Gas Activity Monitor is exceeded, signals are provided to both trains of Solid State Protection System (SSPS) to initiate a Containment Purge Ventilation system isolation. The SLC requires purging or venting to be suspended immediately if this monitor is non-functional.

SLC 16.7.6 includes requirements for a collection of radiation monitoring instrumentation used during plant operations, including the Containment Atmosphere Gaseous Radioactivity - High Monitor (Low Range- EMF-39). These radiation monitors sense radiation levels in selected plant systems and locations and determine whether or not predetermined limits are being exceeded. If they are, the signals are combined into logic matrices sensitive to combinations indicative of various accidents and abnormal conditions. Once the required logic combination is completed, the system sends actuation signals to initiate alarms or automatic isolation action and actuation of Emergency Exhaust or Ventilation Systems. If the Containment Atmosphere Gaseous Radioactivity- High monitor is non-functional, the SLC requires immediate verification that the containment purge system valves are maintained closed.

The SLCs include appropriate testing requirements (TRs). TR 16.11.7.6 and TR 16.7.6.2 require that a Channel Operational Test (COT) be performed every 92 days. which includes demonstration of the automatic isolation of the containment purge pathway.

In summary, SLC 16.7.6 and SLC 16.11.7 include the appropriate requirements to ensure that each containment purge penetration is capable of being closed in Mode 6 by a functional high containment radiation signal.