ML22046A088

Audit Summary Report in Support of the License Amendment Request for One-Time Note to Technical Specification 3.7.7, Low Pressure Service Water (LPSW) System

ML22046A088
Person / Time
Site:	Oconee
Issue date:	03/11/2022
From:	Shawn Williams Plant Licensing Branch II
To:	Snider S Duke Energy Carolinas
Williams S
References
EPID L-2021-LLA-0157
Download: ML22046A088 (6)

Text

March 11, 2022 Mr. Steven M. Snider Site Vice President Duke Energy Carolinas, LLC 7800 Rochester Highway Seneca, SC 29672-0752

SUBJECT:

OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 - AUDIT

SUMMARY

REPORT IN SUPPORT OF THE LICENSE AMENDMENT REQUEST FOR ONE-TIME NOTE TO TECHNICAL SPECIFICATION 3.7.7, LOW PRESSURE SERVICE WATER (LPSW) SYSTEM (EPID L-2021-LLA-0157)

Dear Mr. Snider:

On September 2, 2021 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML21245A210), Duke Energy Carolinas, LLC (Duke Energy) submitted a license amendment request (LAR) to revise Technical Specification (TS) 3.7.7, Low Pressure Service Water (LPSW) System, to extend the completion time for one required inoperable LPSW Pump on a temporary basis for Oconee Nuclear Station (ONS, Oconee), Units 1, 2, and 3. The proposed LAR would add a Note modifying the completion time associated with TS 3.7.7, Condition A, Required Action A.1, to 288 hours0.00333 days <br />0.08 hours <br />4.761905e-4 weeks <br />1.09584e-4 months <br /> during ONS Unit 2, Refuel 31 (fall 2023) to allow for the tie-in and testing of an alternate suction source to the shared Unit 1 and Unit 2 A and B LPSW pumps. Duke Energy stated that the alternate suction source to the shared Unit 1 and Unit 2 A and B LPSW pumps is needed to permit draining of the Condenser Circulating Water (CCW) System cross-connect header for the replacement of three CCW valves.

The U.S. Nuclear Regulatory Commission (NRC) staff determined that an audit was needed.

By letter dated January 6, 2022 (ADAMS Accession No. ML21362A753), the NRC staff issued the Audit Plan. On February 10, 2022, the NRC staff conducted a virtual audit in accordance with the Audit Plan. The audit remained opened until March 4, 2022, to provide NRC staff time to view documents on the licensees Portal. The Audit was closed at the conclusion of a March 4, 2022, call to discuss the proposed Requests for Additional Information.

Attached is the Audit Summary Report.

If you have any questions, please contact me at 301-415-1009 or via e-mail at Shawn.Williams@nrc.gov.

Sincerely, Digitally signed by Shawn Shawn A. A. Williams Date: 2022.03.11 Williams 10:19:50 -05'00' Shawn A. Williams, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287

Enclosure:

Audit Summary Report cc: Listserv

AUDIT

SUMMARY

REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION 3.7.7, LOW PRESSURE SERVICE WATER (LPSW) SYSTEM DUKE ENERGY CAROLINAS, LLC OCONEE NUCLEAR STATION, UNITS NO. 1, 2, AND 3 DOCKET NOS. 50-269, 50-270, AND 50-287

1.0 BACKGROUND

By [[letter::RA-21-0005, Application to Revise Technical Specification 3.7.7, Low Pressure Service Water (LPSW) System, to Extend the Completion Time for One Required Inoperable LPSW Pump on a Temporary Basis|letter dated September 2, 2021]] (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21245A210), Duke Energy Carolinas, LLC (Duke Energy, licensee) submitted a license amendment request (LAR) to revise Technical Specification (TS) 3.7.7, Low Pressure Service Water (LPSW) System, to extend the completion time for one required inoperable LPSW Pump on a temporary basis for Oconee Nuclear Station (ONS, Oconee),

Units 1, 2, and 3. Specifically, the proposed change would add a Note modifying the Completion Time associated with TS 3.7.7, Condition A, Required Action A.1, to 288 hours0.00333 days <br />0.08 hours <br />4.761905e-4 weeks <br />1.09584e-4 months <br /> during ONS Unit 2, Refuel 31 (fall 2023) to allow for the tie-in and testing of an alternate suction source to the shared Unit 1 and Unit 2 A and B LPSW pumps. Duke Energy stated that the alternate suction source to the shared Unit 1 and Unit 2 LPSW A and B pumps is needed to permit draining of the Condenser Circulating Water (CCW) System cross-connect header for the replacement of three CCW valves.

The U. S. Nuclear Regulatory Commission (NRC) staff determined that an audit was needed.

By letter dated January 6, 2022 (ADAMS Accession No. ML21362A753), the NRC staff issued the Audit Plan. From February 10 to March 4, 2022, the NRC staff conducted an audit in accordance with the NRR Office Instruction LIC-111, Regulatory Audits (ADAMS Accession No. ML19226A274). The NRC staff conducted the audit virtually with the following objectives:

• Gain a better understanding of the license amendment request.

• Gain a better understanding of the actions taken for a failure of the LPSW C pump during the proposed 288 hour0.00333 days <br />0.08 hours <br />4.761905e-4 weeks <br />1.09584e-4 months <br /> limiting condition for operation (LCO).

• Gain a better understanding of the risk insights.

• Discuss audit questions and determine the need for formal requests for additional information.

An opening audit meeting was held on February 10 that followed the audit plan. The licensee added documents to a read-only portal for NRC staff review as described in Section 3.0 below.

The audit was closed following the meeting on March 4 after a discussion regarding the proposed Requests for Additional Information. A request for additional information was issued on March 4, 2022 (ADAMS Accession No. ML22063A450).

Enclosure

2.0 AUDIT PARTICIPANTS NRC Micheal Markley, Chief, Office of Nuclear Reactor Regulation (NRR), Division of Reactor Licensing (DORL), Plant Licensing Branch II-1 (LPLII-1)

Stephanie Devlin-Gill, Project Manager, NRR, DORL, LPLII-1 Shawn Williams, Project Manager, NRR, DORL, LPLII-1 Zackary Stone, Project Manager, NRR, DORL, LPLII-1 Steve Jones, Acting Chief, NRR, Division of Safety Systems (DSS), Containment and Plant Systems Branch (SCPB)

Hanry Wagage, Technical Reviewer, DSS, SCPB Nan Chien, Technical Reviewer, DSS, SCPB Robert Elliott, Technical Reviewer, DSS, Technical Specifications Branch (STSB)

Caroline Tilton, Technical Reviewer, DSS, STSB Ahsan Sallman, NRR, DSS, Nuclear Systems Performance Branch (SNSB)

Thomas Scarbrough, Technical Reviewer, NRR, Division of Engineering and External Hazards (DEX), Mechanical Engineering and Inservice Testing Branch (EMIB)

Naeem Iqbal, Technical Reviewer, Division of Risk Assessment Kamishan Martin, Technical Reviewer, NRR, Division of Reactor Oversight (DRO), Operator Licensing and Human Factors Branch (IOLB)

Jared Nadel, ONS Senior Resident Inspector Adam Ruh, ONS Resident Inspector Duke Energy Lee Grzeck Jordan Vaughan Michael Grams Tony Green Alan Lee Jared Pittman Stephen Roe Charles Stroupe Aaron Swanson Thomas Yadon David Dobson Henry Harling 3.0 AUDIT

SUMMARY

During the February 10, 2022, audit call, Duke Energy presented the information requested in the Audit Plan. The NRC staff and the licensee then discussed the audit questions outlined in of the Audit Plan.

From February 10 to March 4, 2022, the NRC staff reviewed the following documents that were placed on the licensees Certrec on-line Portal as read-only for the purpose of determining

information needed to be submitted on the docket in a formal response for additional information.

Duke Energys Audit Presentation and responses to the Audit Discussion Topics Accident Analysis Clarification Question LPSW Design Basis Document (OSS-0254.00-00-1039, Revision 60)

The December 30, 1997, Final Safety Analysis Report (FSAR) 50.59 Evaluation associated with the LPSW cross-connect between from Unit 1/2 and Unit 3.

On March 4, 2022, the licensee and NRC staff held a clarification call to discuss the proposed request for additional information to ensure mutual understanding. The audit was closed at the conclusion of the March 4 meeting. A formal request for additional information was issued on March 4, 2022.

ML22046A088 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DSS/STSB/BC NAME SWilliams KGoldstein VCusumano DATE 03/8/2022 03/08/2022 03/10/2022 OFFICE NRR/DSS/SNSB/BC NRR/DEX/EMIB/BC(A) NRR/DSS/SCPB/BC NAME SKrepel ITseng BWittick DATE 03/08/2022 03/10/2022 03/09/2022 OFFICE NRR/DORL/ LPL2-1/BC NRR/DORL/LPL2-1/PM NAME MMarkley SWilliams DATE 03/10/2022 03/11/2022