RA-22-0105, Subsequent License Renewal Application - Responses to NRC Requests for Confirmation of Information - Set 4

Subsequent License Renewal Application - Responses to NRC Requests for Confirmation of Information - Set 4

ML22081A027
Person / Time
Site:	Oconee
Issue date:	03/22/2022
From:	Snider S Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-22-0105
Download: ML22081A027 (9)

Text

Steven M. Snider Vice President Oconee Nuclear Station Duke Energy ON01VP l 7800 Rochester Hwy Seneca, SC 29672 o: 864.873.3478 f: 864.873.5791 RA-22-0105 Steve.Snider @duke-energy.com March 22, 2022 10 CFR 50.4 10 CFR Part 54 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Duke Energy Carolinas, LLC (Duke Energy)

Oconee Nuclear Station (ONS), Units 1, 2, and 3 Docket Numbers 50-269, 50-270, 50-287 Renewed License Numbers DPR-38, DPR-47, DPR-55 Subsequent License Renewal Application Responses to NRC Requests for Confirmation of Information - Set 4

References:

1. Duke Energy Letter (RA-21-0132) dated June 7, 2021, Application for Subsequent Renewed Operating Licenses, (ADAMS Accession Number ML21158A193)

2. NRC Letter dated July 22, 2021, Oconee Nuclear Station, Units 1, 2, and 3 - Determination of Acceptability and Sufficiency for Docketing, Proposed Review Schedule, and Opportunity for a Hearing Regarding Duke Energy Carolinas Application for Subsequent License Renewal (ADAMS Accession Number ML21194A245)

3. NRC E-mail dated November 4, 2021, Oconee SLRA - Requests for Confirmation of Information

- Set 1 (ADAMS Accession Number ML21313A233 and ML21313A234)

4. Duke Energy Letter dated December 2, 2021, Oconee Nuclear Station, Units 1, 2, and 3 -

Response to NRC Requests for Confirmation of Information - Set 1 (ADAMS Accession Number ML21336A001)

5. NRC E-mail dated November 23, 2021, Oconee SLRA - Requests for Confirmation of Information - Set 2 (ADAMS Accession Number ML21330A018)

6. Duke Energy Letter dated December 17, 2021, Oconee Nuclear Station, Units 1, 2, and 3 -

Response to NRC Requests for Confirmation of Information - Set 2 (ADAMS Accession Number ML21351A000)

7. NRC E-mail dated January 5, 2022, Oconee SLRA - Requests for Confirmation of Information -

Set 3 (ADAMS Accession Number ML22010A112 and ML22010A113)

8. Duke Energy Letter dated January 21, 2022, Oconee SLRA - Response to NRC Requests for Confirmation of Information - Set 3 (ADAM Accession Number ML22021A000)

9. NRC E-mail dated March 8, 2022, Oconee SLRA - Requests for Confirmation of Information -

Set 4 (ADAMS Accession Number ML22069A001)

U.S. Nuclear Regulatory Commission March 22, 2022 Page 2 Ladies and Gentlemen:

By letter dated June 7, 2021 (Reference 1), Duke Energy Carolinas, LLC (Duke Energy) submitted an application for the subsequent license renewal of Renewed Facility Operating License Numbers DPR-38, DPR-47, and DPR-55 for the Oconee Nuclear Station (ONS), Units 1, 2, and 3 to the U.S. Nuclear Regulatory Commission (NRC). On July 22, 2021 (Reference 2), the NRC determined that ONS subsequent license renewal application (SLRA) was acceptable and sufficient for docketing. In emails from Angela X. Wu (NRC) to Steve Snider (Duke Energy) (References 3, 5, and 7), the NRC transmitted Sets 1, 2 and 3, respectively, of specific requests for confirmation of information (RCl) to support completion of the Safety Review. Duke Energy responded to the RCIs in letters dated December 2, 2021, December 17, 2021, and January 21, 2022 (References 4, 6, and 8), respectively.

In an email from Angela X. Wu (NRC) to Steve Snider (Duke Energy) dated March 8, 2022 (Reference 9), the NRC transmitted set 4 of specific RCls to support completion of the Safety Review. The responses to RCI Set 4 are provided in Enclosure 1.

Should you have any questions regarding this submittal, please contact Paul Guill at (704) 382-4753 or by email at paul.guill@duke-energy.com.

I declare under penalty of perjury that the foregoing is true and correct. Executed on March 22, 2022.

Sincerely, Steven M. Snider Site Vice President Oconee Nuclear Station

Enclosures:

Responses to Requests for Confirmation of Information - Set 4

U.S. Nuclear Regulatory Commission March 22, 2022 Page 3 CC: W/O

Enclosures:

Laura A. Dudes Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 Angela X. Wu, Project manager (by electronic mail only)

U.S. Nuclear Regulatory Commission Mail Stop 11 G3 11555 Rockville Pike Rockville, Maryland 20852 Shawn A. Williams, Project Manager (by electronic mail only)

U.S. Nuclear Regulatory Commission Mail Stop 8 B1A 11555 Rockville Pike Rockville, Maryland 20852 Jared Nadel (by electronic mail only)

NRC Senior Resident Inspector Oconee Nuclear Station Anuradha Nair-Gimmi, (by electronic mail only: naira@dhec.sc.gov)

Bureau Environmental Health Services Department of Health & Environmental Control 2600 Bull Street Columbia, South Carolina 29201

U.S. Nuclear Regulatory Commission March 22, 2022 Page 4 BCC: W/O

Enclosures:

T.P. Gillespie K. Henderson S.D. Capps T.M. Hamilton P.V. Fisk H.T. Grant D.A. Wilson M.C. Nolan S.M. Snider R.K. Nader G.D. Robison T.M. LeRoy P.F. Guill R.V. Gambrell File: (Corporate)

Electronic Licensing Library (ELL)

ENCLOSURE 1 OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 SUBSEQUENT LICENSE RENEWAL APPLICATION RESPONSES TO REQUESTS FOR CONFIRMATION OF INFORMATION - SET 4

Oconee Nuclear Station, Units 1, 2, and 3 Subsequent License Renewal Application Responses to Requests for Confirmation of Information - Set 4 Enclosure 1 Subsequent License Renewal Application Responses to Requests for Confirmation of Information - Set 4 Regulatory Basis:

Part 54 of Title 10 of the Code of Federal Regulations (10 CFR), Requirements for Renewal of Operating Licenses for Nuclear Power Plants, is designed to elicit application information that will enable the U.S. Nuclear Regulatory Commission (NRC) staff to perform an adequate safety review and the Commission to make the necessary findings. Reliability of application information is important and advanced by requirements that license applications be submitted in writing under oath or affirmation and that information provided to the NRC by a license renewal applicant or required to be maintained by NRC regulations be complete and accurate in all material respects. Information that must be submitted in writing under oath or affirmation includes the technical information required under 10 CFR 54.21(a) related to assessment of the aging effects on structures, systems, and components subject to an aging management review. Thus, both the general submission requirements for license renewal applications and the specific technical application information requirements require that submission of information material to NRCs safety findings (see 10 CFR 54.29 standards for issuance of a renewed license) be submitted by an applicant as part of the application.

Background:

By letter dated June 7, 2021 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML21158A193), as supplemented by letters dated October 22, 2021 (ADAMS Accession No. ML21295A035), October 28, 2021 (ADAMS Accession No. ML21302A208), November 11, 2021 (ADAMS Accession No. ML21315A012), December 2, 2021 (ADAMS Accession No. ML21336A001),

December 15, 2021 (ADAMS Accession No. ML21349A005), and December 17, 2021 (ADAMS Accession No. ML21351A000), January 7, 2022 (ADAMS Accession No. ML22066A771), January 21, 2022 (ADAMS Accession No. ML22021A000), February 14, 2022 (ADAMS Accession No. ML22066A773), and February 21, 2022 (ADAMS Accession No. ML22052A002), Duke Energy Carolinas, LLC (Duke Energy) submitted to the U.S. Nuclear Regulatory Commission (NRC or staff) an application to renew the Renewed Facility Operating License Nos. DPR-38, DPR-47, and DPR-55 for Oconee Nuclear Station (ONS), Units 1, 2, and 3. Duke Energy submitted the application pursuant to 1

Oconee Nuclear Station, Units 1, 2, and 3 Subsequent License Renewal Application Responses to Requests for Confirmation of Information - Set 4 10 CFR Parts 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, for subsequent license renewal.

Between July 26 and October 8, 2021, the NRC staff conducted audits of Duke Energys records to confirm information submitted in the ONS subsequent license renewal application.

Request:

During the audit, the staff reviewed several documents that contain information which will likely be used in conclusions documented in the Safety Evaluation Report (SER). To the best of the staff's knowledge, this information is not on the docket. Any information used to reach a conclusion in the SER must be included on the docket by the applicant. We request that you submit confirmation that the information gathered from the documents and listed below is correct or provide the associated corrected information.

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Oconee Nuclear Station, Units 1, 2, and 3 Subsequent License Renewal Application Responses to Requests for Confirmation of Information - Set 4 Request for Confirmation of Information (RCI) B2.1.15-1-A:

Based on the review of the response to Request for Additional Information (RAI) B2.1.15-1, dated February 14, 2022 (ADAMS Accession No. ML22066A773), the staff noted that the masonry walls in the Turbine Building and the Auxiliary Building are constructed of concrete block and have structural support; shelter, protection; and fire barrier intended functions. The response also states, Both alignments [AMR items 3.5.1-070 (III.A3.T-12) and 3.3.1-179 (VII.G.A-626)] are utilized to capture all potential aging mechanisms for the Masonry Walls that contain a fire barrier function.

Confirm that the Fire Protection program is credited for ensuring that the fire barrier intended function is maintained during the subsequent period of extended operation. Also, confirm that the Masonry Walls program is credited for ensuring that the structural support and the shelter, protection intended functions are maintained during the subsequent period of extended operation for the masonry wall component type (two materials - masonry wall and concrete block).

Response to RCI B2.1.15-1-A:

This information has been confirmed to be correct as stated.

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Oconee Nuclear Station, Units 1, 2, and 3 Subsequent License Renewal Application Responses to Requests for Confirmation of Information - Set 4 Request for Confirmation of Information (RCI) B2.1.15-2-A:

Based on the review of the response to RAI B2.1.15-2, dated February 14, 2022 (ADAMS Accession No. ML22066A773), the staff noted that Armaflex does not have a fire barrier intended function and Subsequent License Renewal Application Section 2.4.8.2 was revised to state that it is not credited as a fire barrier. The response also states, The Structures Monitoring program is not credited for ensuring the intended function of fire barrier materials.

While reviewing the table in Section 4.4 of Enclosure 9.5, Fire Barrier Penetration Configuration Identification, in implementing procedures MP/1/A/1705/018, MP/2/A/1705/018, and MP/3/A/1705/018, Fire Protection - Penetration - Fire and Flood Barrier - Inspection and Minor Repair, the staff noted that these implementing procedures appear to include other sealant types that are approved for both fire barriers and flood barriers. Because the above implementing procedures for the Fire Protection program do not appear to be cited or referenced in any other aging management program (i.e.,

Structures Monitoring program), confirm that the associated inspections conducted under the Fire Protection program are not being credited for the inspections of penetration seals with a flood barrier intended function.

Response to RCI B2.1.15-2-A:

This information has been confirmed to be correct as stated.

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