MNS-16-009, Response to NRC Letter Dated December 9, 2015, Request for Additional Information Regarding Request for Exemption from Title 10 of the Code of Federal Regulations (10 CFR) Part 74.19(c)

Response to NRC Letter Dated December 9, 2015, Request for Additional Information Regarding Request for Exemption from Title 10 of the Code of Federal Regulations (10 CFR) Part 74.19(c)

ML16041A172
Person / Time
Site:	McGuire, Mcguire
Issue date:	02/04/2016
From:	Capps S Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
MNS-16-009, TAC MF6693, TAC MF6694
Download: ML16041A172 (8)

Text

Steven D. Capps DUKEENEP GYMcGuire Vice President Nuclear Station Duke Energy MG01VP I112700 Hagers Ferry Road Huntersville, NC 28078 o: 980.875.4805 f- 980.875.4809 Steven.Capps@duke-energy.com 10 CFR 74.7 February 04, 2016 Serial: MNS-16-009 U.S. Nuclear Regulatory Commission Washington, DC 20555-001 ATTENTION: Document Control Desk Duke Energy Carolinas, LLC (Duke Energy)

McGuire Nuclear Station, Units I and 2 Docket Nos. 50-369 and 50-370 Renewed License Nos. NPF-9 and NPF-17

Subject:

Response to NRC letter dated December 9, 2015, "McGuire Nuclear Station, Units 1 AND 2: Request for Additional Information Regarding Request for Exemption from Title 10 of the Code of Federal Regulations (10 CFR)

Part 74.19(c) (TAC Nos. MF6693 and MF6694)

By letter dated August 17, 2015, as supplemented by letter dated October 6, 2015, McGuire submitted a request for exemption from 10 CFR Part 74.19(c). The exemption would allow an alternative to the physical inventory requirements for movable incore detectors.

The regulations in 10 CFR 74.19 specify recordkeeping requirements applicable to Special Nuclear Material (SNM). The regulatory requirement in 10 CFR 74.19(c) stipulates that licensees must conduct a physical inventory of all SNM in their possession under license at intervals not to exceed 12 months.

The NRC staff reviewed the exemption request and determined that additional information was necessary to enable the staff to disposition the request. provides the requested information. identifies two regulatory commitments in support of the exemption.

U.S. Nuclear Regulatory Commission February 04, 2016 Page 2 Questions regarding this submittal should be directed to George Murphy, McGuire Regulatory Affairs at (980) 875-5715.

Sincerely, Steven D. Capps

Attachment:

1. Response to Request for Additional Information

2. Regulatory Commitments

• U.S. Nuclear Regulatory Commission February 04, 2016 Page 3 cc w/

Attachment:

C. Haney Administrator, Region II

• U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 J. Zeiler NRC Senior Resident Inspector McGuire N~iclear Station G. E. Miller, Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 G9A Rockville, MD 20852-2738

ATTACHMENT 1 Response to Request for Additional Information

REQUEST FOR ADDITIONAL INFORMATION OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO REQUEST FOR EXEMPTION FROM TITLE 10 OF THE CODE OF FEDERAL REGULATIONS PART 74.19(c)

.DUKE ENERGY CAROLINAS, LLC MCGUIRE NUCLEAR STATION. UNITS 1 AND 2 DOCKET NOS. 50-369 AND 50-376 By letter dated August 17, 2015, as supplemented by letter dated October 6, 2015 (Agencywide Documents Access and Management'System (ADAMS) Accession Nos. ML152398240 and" ML15300A282, respectively), Duke Energy Carolinas, LLC (Duke) requested the U.S. Nuclear Regulatory Commission (NRC) to authorize exemption from the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 74.19(c) for the McGuire Nuclear Station, Units 1 and 2. The exemption would allow an alternative to the physical inventory requirements for movable incore detectors.

The regulations in 10 CFR 74.19 specify recordkeeping requirements applicable to special nuclear material (SNM). In addition, the regulatory requirement in 10 CFR 74.19(c) stipulates that the licensee must conduct a physical inventory of all SNM in its possession under license at intervals not to exceed 12 months. The NRC staff has reviewed the request and has determined that the following additional information is necessary to enable the NRC staff to make an independent assessment regarding its technical review.

RAIl1 Provide a completion date for modifications to the incore storage sleeves to make the incore detectors within the storage sleeves inaccessible.

RAI 2

Provide an implementation date for modifications to ensure the incore detectors meet the requirements of inaccessibility.

RAI 3

Provide administrative procedures and controls to be established so that verification of the storage pipes shall be performed during refueling outages and that records concerning the location and unique identity of incore detectors are accurate.

RAI 4

Confirm that the acronym "2E0C23" used in the exemption request means Unit 2, end of cycle 23 and the acronym "1EOC24" means Unit 1, end of cycle 24.

Page 1 of 3

RAI #1 Provide a completion date for modifications to the incore storage sleeves to make the incore detectors within the storage sleeves inaccessible.

McGuire Response:

The Unit 2 hardware modification making the incore *detectors within the storage sleeves inaccessible was completed September 12, 2015. The Unit 1 modification is planned to be completed before unit startup from 1EOC24 which is currently scheduled for April 18, 2016.

RAI #2 Provide an implementation date for modifications to ensure the incore detectors meet the requirements of inaccessibility.

McGuire Response:

The Unit 2 hardware modification was fully implemented as of September 12, 2015. The Unit I modification will be implemented during 1E0C24 and completed prior to unit startup which is currently scheduled for April 18, 2016.

RAI #3 Provide administrative procedures and controls to be established so that verification of the storage pipes shall be performed during refueling outages and that records concerning the location and unique identity of the incore detectors are accurate.

McGuire Response:

The modification includes cover plates to block access to the storage sleeves. The cover plates are anchored to the containment concrete wall with bolts and tamper proof wire cable running through the bolts. The wire cable will be secured by a padlock and Tamper Indicating Device (TID) with a unique identification number. The Radiation Protection (RP) Group will control keys for the locks. RP procedures HP/I/B/I1006/024 and HP/2/B/1 006/024, Outage Controls and Surveillances, will be revised to incorporate the administrative guidance in a new enclosure for the RP Group to verify the integrity of the TID and record the unique identification number of each TID.

The RP TID verification enclosure will be forwarded to the Reactor Engineering (RE) Group after completion of the verification. Reactor Engineering procedure PT/0/N4550/O03, Physical Inventory of Reportable Special Nuclear Material, will be revised to incorporate the new detector storage sleeve cover plates as an item that needs to be addressed in the inventory.

Reactor Engineering procedure PT/0/A/4150/032, Audit of Movable Incore Detector Records provides the guidance for documentation and record keeping for the incore detectors. This procedure ensures that records concerning the location and unique identity of the incore detectors are accurate.

Page 2 of 3

RAI #4 Confirm that the acronym "2EOC23" used in the exemption request means Unit 2, end of cycle 23 and the acronym "1EOC24 means Unit 1, end of cycle 24.

McGuire Response:

"2EOC23" means Unit 2, End-of-Cycle 23 "1EOC24" means Unit 1, End-of-Cycle 24 Page 3 of 3

ATTACHMENT 2 Regulatory Commitments

1. Regulatory Commitments Due Date 1 Complete the modifications that make access to the incore detector Before startup sleeves inaccessible. Unit 2 is complete. Complete Unit 1 modification from 1 EOC24 before unit startup from 1EOC24.

2 Revise the procedures that establish the controls so that verification of Before startup the storage pipes shall be performed during refueling outages and that from 1 EOC24 records concerning the location and unique identity of the incore

___detectors are accurate. ________

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