ML16166A402

Summary of November 18, 2015, and December 15, 2015, Meetings with Duke Energy Carolinas, LLC to Discuss a Proposed Relief Request in Accordance with 10 CFR 50.55a(z) for the Oconee Nuclear Station, Units 1, 2, and 3 (CAC Nos. MF7029, MF703

ML16166A402
Person / Time
Site:	Oconee
Issue date:	06/27/2016
From:	Hall J Plant Licensing Branch II
To:	Duke Energy Carolinas
Hall J, NRR/DORL/LPL2-1
References
CAC MF7029, CAC MF7030, CAC MF7031
Download: ML16166A402 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 27, 2016 LICENSEE: Duke Energy Carolinas, LLC FACILITY: Oconee Nuclear Station, Units 1, 2, and 3

SUMMARY

OF NOVEMBER 18, 2015, AND DECEMBER 15, 2015, MEETINGS WITH DUKE ENERGY CAROLINAS, LLC TO DISCUSS PROPOSED REQUEST FOR ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(z)

FOR THE OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 (CAC NOS. MF7029, MF7030, AND MF7031)

On November 18, 2015, and December 15, 2015, Category 1 public meetings were held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Duke Energy Carolinas, LLC (Duke Energy or the licensee). The purpose of these meetings was to discuss a proposed request for alternative in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(z) for the Oconee Nuclear Station, Units 1, 2, and 3 (Oconee). The meeting notices and agendas, dated November 5, 2015, and December 3, 2015, are available in the Agencywide Documents Access and Management System (ADAMS) at Package Accession No. ML16166A405. A list of attendees for each meeting is enclosed. The licensee's slide presentations in support of the respective meetings can be found in the ADAMS package noted.

During the November 18, 2015, meeting, the licensee discussed its proposed request for alternative to the codes and standards requirements in 10 CFR 50.55a(h)(2), "Protection systems," which states, in part, that:

... For nuclear power plants with construction permits issued before January 1, 1971 [which includes Oconee], protection systems must be consistent with their licensing basis ...

The requirement in 10 CFR 50.55a(z), "Alternatives to codes and standards requirements,"

states the following:

Alternatives to the requirements of paragraphs (b) through (h) of this section or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation ... The applicant or licensee must demonstrate that:

(1) Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety; or (2) Hardship without a compensating increase in quality and safety. Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The licensee stated that it intends to submit this request for alternative to address, in part, the NRC staff's letter dated June 27, 2014, 1 which documents the results of a component design-basis inspection (CDBI) at Oconee (Inspection Report 05000269/2014007; 1 ADAMS Accession No. ML14178A535

05000270/2014007; 05000287/2014007). In that inspection report, the CDBI team identified an unresolved item (URI) involving cable configurations in certain underground cable raceways that may not comply with the Oconee licensing basis, design basis, and NRC regulations and requirements. Based on this URI, the NRC Region II staff issued Task Interface Agreement (TIA) 2014-05 by memorandum dated October 16, 2014, 2 seeking technical support to determine whether or not the cable configuration in the noted underground raceways meets the existing Oconee licensing basis and design basis.

During the meeting, the licensee stated that the request would propose an alternative approach to the requirement that the Oconee licensing basis meet the Institute of Electrical and Electronics Engineers (IEEE) Standard 279-1971. The licensee further stated that this submittal would demonstrate that the proposed alternatives provide an acceptable level of quality and safety and that NRC approval would revise and clarify the Oconee licensing basis and allow for resolution of the nonconforming condition outlined in the URI.

The licensee stated that the proposed alternatives would be applied in the following areas:

• Keowee Underground Power Path (Trench 3)

• PSW Ductbank Manholes 1 through 5

• PSW Ductbank Manhole 6 (MH-6) and PSW Cable Spreading Area

• Keowee Mechanical Equipment Gallery The specific proposed alternatives are outlined on pages 29 through 37 of the licensee's slide presentation. The licensee stated that the forthcoming submittal would demonstrate an acceptable level of quality and safety for the proposed alternatives based on several factors, including:

• modifications per accepted standards

• environmental factors

• aging management program

• risk significance

• cable crush and fault test results During the meeting, the licensee discussed the factors listed above. Further details are provided in the licensee's presentation slides.

During the December 15, 2015, meeting, the NRC staff and the licensee discussed questions that the NRC staff raised regarding the cable crush and fault testing. The questions can be found in the ADAMS package noted above. The licensee stated that the test results would be used to support the acceptability of the proposed alternative and validate previous engineering evaluations regarding postulated fault propagation. The licensee also stated that the test parameters and setup were established to bound plant conditions. A general overview and a review of the results of the cable testing can be found in the licensee's presentation slides for this meeting.

No regulatory decisions were made during these meetings.

2 ADAMS Accession No. ML14290A136

One member of the public was in attendance for the December 15, 2015, meeting by teleconference. The member of the public had no questions or comments for the NRC staff. No public meeting feedback forms were received.

Duke Energy formally submitted the request for alternative by letter dated February 15, 2016. 3 The submittal included responses to the NRC staff's questions transmitted by e-mail on December 8, 2015. The NRC staff notified the licensee that the request was accepted for review in an e-mail dated March 23, 2016. 4 The results of the NRC staff's review of the request for alternative will be documented in a safety evaluation and transmitted to the licensee upon completion.

Please direct any inquiries regarding this matter to me at 301-415-4032 or by e-mail to randy.hall@nrc.gov.

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/\jtt,{J Vmes R. Hall, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287

Enclosures:

1. List of Attendees at November 18, 2015, meeting

2. List of Attendees at December 15, 2015, meeting cc w/enclosures: Distribution via Listserv 3 ADAMS Accession No. ML16062A052 4 ADAMS Accession No. ML16083A370

LIST OF ATTENDEES NOVEMBER 18, 2015, PRE-SUBMITTAL MEETING WITH DUKE ENERGY CAROLINAS, LLC OCONEE NUCLEAR STATION, UNITS 1. 2, AND 3 NRC DUKE ENERGY MEMBERS OF PUBLIC Anne Boland Scott Batson John Lubinski Ed Burchfield Marissa Bailey Chris Nolan Anthony Gody Ray Price Jacob Zimmerman Chris Wasik Michael Markley Todd Grant Sunil Weerakkody Steve Kimbrough Roy Mathew Arthur Zaremba Gurcharan Matharu* Steve Newman*

Shavon Edmonds Terry Patterson*

Jeffrey Whited Mike Leisure*

Randy Hall Jordan Vaughn*

Michael Montecalvo Rick Ennis Margaret Chernoff Lynnea Wilkins Thomas Koshy Frank Ehrhardt*

Jannette Worosilo*

Theodore Fanelli*

• Participated by teleconference Enclosure 1

LIST OF ATTENDEES DECEMBER 15, 2015, PRE-SUBMITTAL MEETING WITH DUKE ENERGY CAROLINAS, LLC OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 NRC DUKE ENERGY MEMBERS OF PUBLIC Anne Boland Ed Burchfield Marvin Lewis*

Anthony Gody Chris Nolan MaryJane Ross-Lee Chris Wasik Jacob Zimmerman Todd Grant Michael Markley Arthur Zaremba Sunil Weerakkody Vance Bowman See-Meng Wong Bert Spear Nicholas Melly Ryan Greco Jeffrey Mitman Scott Batson*

Jeffrey Whited Terry Patterson*

Randy Hall Kerry Dutton*

Michael Montecalvo Ray Price*

Harold Barrett Jonathan Bartley*

Lynnea Wilkins

• Participated by teleconference Enclosure 2

PKG ML16166A405 Summary: ML16166A402 11/18/15 Mtg.: Notice: ML15309A270 Slides: ML15321A178 12/1 51 15 Mt~.: Notice: ML15337A526 Q uestions: M L15343 A1 14 S lides: ML15348A203 OFFICE DORL/LPL2-1 /PM DORL/LPL2-1/LA DORL/LPL2-1 /BC DORL/LPL2-1 /PM MMarkley (RMartin NAME JWhited LRonewicz JRHall for)

DATE 06/23/16 06/27/16 06/24/16 06/27/16