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Category:Letter type:MNS
MONTHYEARMNS-18-044, Independent Spent Fuel Storage Installation (Isfsi), Submittal of 10 CFR 72.48 Summary Report from September 15, 2016 to July 26, 2018, No Changes, Tests, or Experiments2018-07-26026 July 2018 Independent Spent Fuel Storage Installation (Isfsi), Submittal of 10 CFR 72.48 Summary Report from September 15, 2016 to July 26, 2018, No Changes, Tests, or Experiments MNS-18-036, Redacted Response to the Request for Additional Information Regarding the License Amendment Request to Revise the Licensing Bases for Protection from Tornado Generated Missiles2018-07-0303 July 2018 Redacted Response to the Request for Additional Information Regarding the License Amendment Request to Revise the Licensing Bases for Protection from Tornado Generated Missiles MNS-18-042, Independent Spent Fuel Storage Installation (ISFSI)2018-06-28028 June 2018 Independent Spent Fuel Storage Installation (ISFSI) MNS-18-040, Submittal of Information Related to Pressurizer Surge and Spray Nozzle Thermal Sleeves Attachment Welds for License Renewal2018-06-26026 June 2018 Submittal of Information Related to Pressurizer Surge and Spray Nozzle Thermal Sleeves Attachment Welds for License Renewal MNS-18-039, Independent Spent Fuel Storage Installation (ISFSI)2018-06-19019 June 2018 Independent Spent Fuel Storage Installation (ISFSI) MNS-18-001, Application to Revise Technical Specifications to Adopt TSTF-234-A Revision 1, Add Action for More than One Dpri Inoperable2018-05-31031 May 2018 Application to Revise Technical Specifications to Adopt TSTF-234-A Revision 1, Add Action for More than One Dpri Inoperable MNS-18-030, 2017 Annual Radiological Environmental Operating Report2018-05-15015 May 2018 2017 Annual Radiological Environmental Operating Report MNS-18-029, Resolution of Commitments Related to Review Request for the Aging Management Program and Inspection Plan for the McGuire Nuclear Station Units 1 and 2 Reactor Vessel Internals to Implement MRP-227-A2018-05-0909 May 2018 Resolution of Commitments Related to Review Request for the Aging Management Program and Inspection Plan for the McGuire Nuclear Station Units 1 and 2 Reactor Vessel Internals to Implement MRP-227-A MNS-18-029, McGuire Nuclear Station, Units 1 and 2 - Resolution of Commitments Related to Review Request for the Aging Management Program and Inspection Plan for the McGuire Nuclear Station Units 1 and 2 Reactor Vessel Internals to Implement MRP-227-2018-05-0909 May 2018 McGuire Nuclear Station, Units 1 and 2 - Resolution of Commitments Related to Review Request for the Aging Management Program and Inspection Plan for the McGuire Nuclear Station Units 1 and 2 Reactor Vessel Internals to Implement MRP-227-A MNS-18-028, Annual Radioactive Effluent Release Report2018-04-25025 April 2018 Annual Radioactive Effluent Release Report MNS-18-017, Non-Voluntary License Amendment Request (LAR) to Correct Non-Conservative Technical Specification 3.4.11 - PORVs2018-02-26026 February 2018 Non-Voluntary License Amendment Request (LAR) to Correct Non-Conservative Technical Specification 3.4.11 - PORVs MNS-18-018, McGuire, Units 1 & 2, Submittal of Emergency Plan Implementing Procedure Changes2018-02-22022 February 2018 McGuire, Units 1 & 2, Submittal of Emergency Plan Implementing Procedure Changes MNS-18-009, McGuire Nuclear Station, Units 1 and 2, Submittal of Emergency Plan, Revision 18-12018-01-31031 January 2018 McGuire Nuclear Station, Units 1 and 2, Submittal of Emergency Plan, Revision 18-1 MNS-18-003, End of Cycle 25 In-service and Steam Generator In-service Inspection Summary Reports2018-01-11011 January 2018 End of Cycle 25 In-service and Steam Generator In-service Inspection Summary Reports MNS-17-050, Review Request for the Aging Management Program and Inspection Plan for the Reactor Vessel Internals to Implement MRP-227-A2017-12-13013 December 2017 Review Request for the Aging Management Program and Inspection Plan for the Reactor Vessel Internals to Implement MRP-227-A MNS-17-048, Response to Request for Additional Information License Amendment Request Permanent Extension of Type a and Type C Leak Rate Test Frequencies2017-12-12012 December 2017 Response to Request for Additional Information License Amendment Request Permanent Extension of Type a and Type C Leak Rate Test Frequencies MNS-17-026, Submittal of License Amendment Request Proposing to Revise the Bases for Protection from Tornado-Generated Missiles2017-12-0808 December 2017 Submittal of License Amendment Request Proposing to Revise the Bases for Protection from Tornado-Generated Missiles MNS-17-042, McGuire Nuclear Station, Unit 1, Submittal of Cycle 26, Revision 0, Core Operating Limits Report2017-10-0909 October 2017 McGuire Nuclear Station, Unit 1, Submittal of Cycle 26, Revision 0, Core Operating Limits Report MNS-17-040, (Mns), Units 1 and 2 - Supplement to the High Frequency Supplement to Seismic Hazard Screening Report, Response NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force ..2017-09-27027 September 2017 (Mns), Units 1 and 2 - Supplement to the High Frequency Supplement to Seismic Hazard Screening Report, Response NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force .. MNS-17-038, Startup Ascension Summary Report Measurement Uncertainty Recapture Power Uprate2017-09-25025 September 2017 Startup Ascension Summary Report Measurement Uncertainty Recapture Power Uprate MNS-17-039, McGuire Nuclear Station, Units 1 and 2, Submittal of Emergency Plan, Revision 17-12017-09-19019 September 2017 McGuire Nuclear Station, Units 1 and 2, Submittal of Emergency Plan, Revision 17-1 MNS-17-031, License Amendment Request for Temporary Changes to Technical Specifications to Address an 'A' Train Nuclear Service Water System (Nsws) Non-Conforming Condition2017-09-14014 September 2017 License Amendment Request for Temporary Changes to Technical Specifications to Address an 'A' Train Nuclear Service Water System (Nsws) Non-Conforming Condition MNS-17-037, Submittal of Summary Report of Evaluations Performed Pursuant to 10 CFR 50.59 Changes, Tests, and Experiments During the Period from January 1, 2016 to March 31, 20172017-08-10010 August 2017 Submittal of Summary Report of Evaluations Performed Pursuant to 10 CFR 50.59 Changes, Tests, and Experiments During the Period from January 1, 2016 to March 31, 2017 MNS-17-033, Snubber Program Plan for the Fourth Ten-Year Lnservice Testing (IST) Interval2017-08-0202 August 2017 Snubber Program Plan for the Fourth Ten-Year Lnservice Testing (IST) Interval MNS-17-034, 16C4435-RPT-002, Rev. 1, 50.54(f) NTTF 2.1 Seismic High Frequency Confirmation for McGuire Nuclear Station.2017-07-24024 July 2017 16C4435-RPT-002, Rev. 1, 50.54(f) NTTF 2.1 Seismic High Frequency Confirmation for McGuire Nuclear Station. MNS-17-030, Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 3, Flooding Focused Evaluation Summary Submittal2017-06-28028 June 2017 Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 3, Flooding Focused Evaluation Summary Submittal MNS-17-023, Response to Request for Additional Information to License Amendment Request Permanent Extension of Type a and Type C Leak Rate Test Frequencies2017-05-25025 May 2017 Response to Request for Additional Information to License Amendment Request Permanent Extension of Type a and Type C Leak Rate Test Frequencies MNS-17-016, Nuclear Regulatory Commission (NRC) Annual Commitment Change Report2017-05-18018 May 2017 Nuclear Regulatory Commission (NRC) Annual Commitment Change Report MNS-17-020, Transmittal of McGuire, Units 1 and 2, 2016 Annual Radiological Environmental Operating Report2017-05-0505 May 2017 Transmittal of McGuire, Units 1 and 2, 2016 Annual Radiological Environmental Operating Report MNS-17-019, McGuire Nuclear Station, Units 1 and 2 - Submittal of Annual Radioactive Effluent Release Report2017-04-28028 April 2017 McGuire Nuclear Station, Units 1 and 2 - Submittal of Annual Radioactive Effluent Release Report MNS-17-008, Letter of Intent to Submit Plant-Specific Reactor Vessel Internals Inspection Plans2017-02-23023 February 2017 Letter of Intent to Submit Plant-Specific Reactor Vessel Internals Inspection Plans MNS-16-092, License Amendment Request to Revise Technical Specifications Section 5.5.2, Containment Leakage Rate Testing Program for Permanent Extension of Type a and Type C Leak Rate Test Frequencies2016-12-19019 December 2016 License Amendment Request to Revise Technical Specifications Section 5.5.2, Containment Leakage Rate Testing Program for Permanent Extension of Type a and Type C Leak Rate Test Frequencies MNS-16-091, License Amendment Request for Technical Specification 3.6.14, Divider Barrier Integrity.2016-12-0808 December 2016 License Amendment Request for Technical Specification 3.6.14, Divider Barrier Integrity. MNS-16-086, Emergency Plan, Revision 16-42016-12-0707 December 2016 Emergency Plan, Revision 16-4 MNS-16-078, Written Notification Joslyn Clark Overload Heater Element Part No. 24552016-10-19019 October 2016 Written Notification Joslyn Clark Overload Heater Element Part No. 2455 MNS-16-077, Responding to Request for Additional Information Related to License Amendment Request to Implement a Risk-informed Performance-Based Fire Protection Program2016-09-29029 September 2016 Responding to Request for Additional Information Related to License Amendment Request to Implement a Risk-informed Performance-Based Fire Protection Program MNS-16-070, Response to Request for Additional Information to Relief Request 16-MN-0032016-08-18018 August 2016 Response to Request for Additional Information to Relief Request 16-MN-003 MNS-16-060, Spent Fuel Pool Evaluation Supplemental Report, Response to NRC Request for Information Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident2016-08-18018 August 2016 Spent Fuel Pool Evaluation Supplemental Report, Response to NRC Request for Information Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident MNS-16-062, Relief Request 16-MN-003 Alternative to Defect Removal Prior to Performing Temporary Repair Activities on Three-Inch-Diameter Nuclear Service Water System Piping2016-08-10010 August 2016 Relief Request 16-MN-003 Alternative to Defect Removal Prior to Performing Temporary Repair Activities on Three-Inch-Diameter Nuclear Service Water System Piping MNS-16-046, License Amendment Request for Technical Specification 3.6.14, Divider Barrier Integrity2016-06-30030 June 2016 License Amendment Request for Technical Specification 3.6.14, Divider Barrier Integrity MNS-16-056, License Amendment Request, One-Time Extension of Appendix J Type a Integrated Leakage Rate Test Interval, Response to Request for Additional Information2016-06-30030 June 2016 License Amendment Request, One-Time Extension of Appendix J Type a Integrated Leakage Rate Test Interval, Response to Request for Additional Information MNS-16-053, Relief Request 16-MN-002, Alternative to Defect Removal Prior to Performing Repair Activities on Nuclear Service Water System Piping2016-06-23023 June 2016 Relief Request 16-MN-002, Alternative to Defect Removal Prior to Performing Repair Activities on Nuclear Service Water System Piping MNS-16-052, Supplement to License Amendment Request for the Removal of Superseded Technical Specification Requirements, Dated May 5, 2016, TAC Nos. MF7682 and MF76832016-06-16016 June 2016 Supplement to License Amendment Request for the Removal of Superseded Technical Specification Requirements, Dated May 5, 2016, TAC Nos. MF7682 and MF7683 MNS-16-042, Withdrawal of Relief Request Serial No. 15-MN-0022016-05-17017 May 2016 Withdrawal of Relief Request Serial No. 15-MN-002 MNS-16-020, License Amendment Request Removal of Superseded Technical Specification Requirements2016-05-0505 May 2016 License Amendment Request Removal of Superseded Technical Specification Requirements MNS-16-041, Supplement to Final Notification of Full Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events and with Order EA-12-051..2016-05-0505 May 2016 Supplement to Final Notification of Full Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events and with Order EA-12-051.. MNS-16-036, Relief Request 16-MN-001, Limited Weld Examinations2016-04-28028 April 2016 Relief Request 16-MN-001, Limited Weld Examinations MNS-16-039, Submittal Revising Attachment s of License Amendment Request to Implement a Risk-Informed Performance-Based Fire Protection Program2016-04-26026 April 2016 Submittal Revising Attachment s of License Amendment Request to Implement a Risk-Informed Performance-Based Fire Protection Program MNS-16-026, Transmittal of Updated Final Safety Analysis Report, Revision 192016-04-0505 April 2016 Transmittal of Updated Final Safety Analysis Report, Revision 19 MNS-15-068, License Amendment Request to Technical Specification (TS) 3.6.13, Ice Condenser Doors.2016-03-24024 March 2016 License Amendment Request to Technical Specification (TS) 3.6.13, Ice Condenser Doors. 2018-07-03
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Steven D. Capps Vice President McGuire Nuclear Station ENERGY, Duke Energy MG01VP 112700 Hagers Ferry Road Huntersville, NC 27078 o: 980.875.4805 f: 980.875.4809 Steven.Capps@duke-energy.com 10 CFR 50.54(f)January 30, 2014 Serial: MNS-14-009 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Duke Energy LLC (Duke Energy)McGuire Nuclear Station (MNS), Units 1 and 2 Docket Nos. 50-369 and 50-370 Renewed License Nos. NPF-9 and NPF-17
Subject:
Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding Update -Review of Available Physical Margin (APM) Assessments
References:
- 1. NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident; dated March 12, 2012, (ADAMS Accession No. ML12053A340).
- 2. NEI 12-07, Guidelines for Performing Verification Walkdown of Plant Flood Protection Features, Revision 0-A, dated May 2012, (ADAMS Accession No. ML12144A401)
- 3. NRC Letter to Nuclear Energy Institute (NEI), Endorsement of Nuclear Energy Institute (NEI) 12-07, Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features, dated May 31, 2012, (ADAMS Accession No. ML1 2144A1 42).4. Flooding Walkdown Information Requested by NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident; dated November 26, 2012, (ADAMS Accession No. ML12361A006)
- 5. NRC letter, Request for Additional Information associated with Near-Term Task Force Recommendation 2.3, Flooding Walkdowns; dated December 23, 2013, (ADAMS Accession No. ML13325A891)
United States Nuclear Regulatory Commission January 30, 2014 Page 2 Ladies and Gentlemen:
On March 12, 2012, the Nuclear Regulatory Commission (NRC) staff issued Reference 1 requesting information pursuant to Title 10 of the Code of Federal Regulations 50.54(f).Enclosure 4 of that letter contains requested information associated with Near-Term Task Force Recommendation (NTTF) 2.3 for flooding.
NEI 12-07 (Reference
- 2) was endorsed by NRC letter dated May 31, 2012 (Reference 3). By Reference 4, MNS submitted the 180-day response to Reference 1 requiring the flooding walkdown report addressing the items in Appendix D of NEI 12-07.Following the NRC staffs initial review of the walkdown reports, regulatory site audits were conducted by the NRC staff at a sampling of plants. Based on the walkdown report reviews and site audits, additional information was determined to be necessary to allow the NRC staff to complete its assessments.
By letter dated December 23, 2013 (Reference 5), the NRC requested additional information regarding the determination and documentation of APM during flooding walkdowns.
The NRC staff requested that a response be provided no later than January 31, 2013. The Duke Energy response for MNS is enclosed.This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments.
Should you have any questions regarding this submittal, please contact George Murphy at (980) 875-5715.I declare under penalty of perjury that the foregoing is true and correct. Executed on January 30, 2014.Sincerely, Steven D Capps
Enclosure:
MNS Response to the NRC Request for Additional Information (RAI) Regarding Available Physical Margin (APM) during Flooding Walkdowns United States Nuclear Regulatory Comnmission January 30, 2014 Page 3 xc: V. M. McCree, Regional Administrator U.S. Nuclear Regulatory Commission
-Region II Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 Eric J. Leeds, Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North, Mailstop 13-H16M 11555 Rockville Pike Rockville, MD 20852-2738 J. C. Paige, Project Manager (CNS & MNS)U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 8 G9A Rockville, MD 20852-2738 J. Zeiler NRC Senior Resident Inspector McGuire Nuclear Station Justin Folkwein American Nuclear Insurers 95 Glastonbury Blvd., Suite 300 Glastonbury, CT 06033-4453 Enclosure McGuire Nuclear Station Response to the NRC Request for Additional Information (RAI)Regarding Available Physical Margin (APM) during Flooding Walkdowns Determination and documentation of available physical margin (APM)
Background:
The NRC staff observed that several licensees did not consistently determine and/or document available physical margin (APM) in a manner that met the expected interpretation of NEI 12-07 during audits associated with review of the NTTF Recommendation 2.3 report submittals.
APM is defined in Section 3.13 of NEI 12-07 and the process for obtaining and evaluating APM values is described in Section 5.8 of NEI 12-07. Consistent with NEI 12-07, a numerical value for APM should be determined and documented for every applicable flood protection feature (e.g., wall, penetration, berm, door, etc.). This would normally be a numerical value reflecting the difference between the licensing basis flood height at the location of the feature and the point at which the function of the flood protection feature is compromised (e.g., the top of a barrier or the height of the first unsealed penetration in a barrier) such that the resulting flood can affect a structures, systems, and components important to safety. Next, in accordance with Section 5.8 of NEI 12-07, if the APM appears to be small and the consequences of flooding appear to be significant, the licensee should enter the condition into the CAP and appropriate action be taken. While NEI 12-07 does not require that a specific numerical threshold value for"small" APM be defined for each site, doing so establishes a consistent basis for determining what instances need to be entered into the CAP. If a numerical APM value cannot be determined for any flood protection feature, the licensee should perform an assessment of the ability of the barrier to withstand the licensing basis flood plus the contribution of the additional water corresponding to the pre-established small-margin threshold value. If the barrier can withstand this flood, the APM for the feature is "not small" and further evaluation in accordance with Section 5.8 of NEI 12-07 is not required.
It is further noted that conclusions regarding"large" values of APM should be based on engineering evaluations or existing design documents.
Licensees should ensure that the process for APM determination and evaluation used during their flooding walkdowns is consistent with the guidance in NEI 12-07. The intent of this Request for Additional Information (RAI) is not to repeat the flooding walkdowns or perform an extensive revision of the walkdown record forms and other paperwork.
Instead the purpose is to verify or modify the process used to determine APM such that every site is aware of the margin at each of its flood protection features and take appropriate interim actions when the APM is small and the consequences are significant.
Instances where numerical values for APM were not determined, or where the basis for the APM was found to be questionable, should be rectified by either the documentation of a specific value or an explanation of why a non-numerical value is appropriate.
NRC RAI 1: Confirmation that the process for evaluating APM was reviewed;Response to RAI 1: Duke Energy has completed a review of the flooding design basis walkdown process used at McGuire to evaluate APMs.
NRC RAI 2: Confirmation that the APM process is now or was always consistent with the guidance in NEI 12-07 and discussed in this RAI;Response to RAI 2: The original walkdown effort followed the guidance provided in NEI 12-07, however, no definition for small margin was included at the time of the walkdown.
Engineers at McGuire have since defined small APM for the design basis flooding events. Although the original walkdown effort followed the guidance provided in NEI 12-07, a specific APM had not been assigned to the seals associated with flood protection features or to flood protection features that are below grade.Additional actions have been taken to make the APM process consistent with the information provided in this RAI and in NEI 12-07.
NRC RAI 3: If changes are necessary, a general description of any process changes to establish this consistency; Response to RAI 3: As stated above, the determination and documentation of the APM as performed during the original walkdown effort did not include a definition for a small margin and did not specifically assign an APM value to the seals associated with flood protection features or to flood protection features that were classified as below grade flood protection features.
The addition of the small margin definition and assignment of an APM value for all applicable flood protection features have now been addressed in accordance with the guidance provided in this RAI. Following completion of the actions described above there were no conditions identified that would require entry into the CAP process for further evaluation.
NRC RAI 4: As a result of the audits and subsequent interactions with industry during public meetings, NRC staff recognized that evaluation of APM for seals (e.g., flood doors, penetrations, flood gates, etc.) was challenging for some licensees.
Generally, licensees were expected to use either Approach A or Approach B (described below) to determine the APM for seals: a) If seal pressure ratings were known, the seal ratings were used to determine APM (similar to example 2 in Section 3.13 of NEI 12-07). A numerical value for APM was documented.
No further action was performed if the APM value was greater than the pre-established small-margin threshold value. If the APM value was small, an assessment of "significant consequences" was performed and the guidance in NEI 12-07 Section 5.8 was followed.b) If the seal pressure rating was not known, the APM for seals in a flood barrier is assumed to be greater than the pre-established small-margin threshold value if the following conditions were met: (1) the APM for the barrier in which the seal is located is greater than the small-margin threshold value and there is evidence that the seals were designed/procured, installed, and controlled as flooding seals in accordance with the flooding licensing basis. Note that in order to determine that the seal has been controlled as a flooding seal, it was only necessary to determine that the seal configuration has been governed by the plant's design control process since installation.
In this case, the APM for the seal could have been documented as "not small".As part of the RAI response, state if either Approach A or Approach B was used as part of the initial walkdowns or as part of actions taken in response to this RAI. No additional actions are necessary if either Approach A or B was used.If neither Approach A or B was used to determine the APM values for seals (either as part of the walkdowns or as part of actions taken in response to this RAI), then perform the following two actions:* Enter the condition into the CAP (note: it is acceptable to utilize a single CAP entry to capture this issue for multiple seals). CAP disposition of "undetermined" APM values for seals should consider the guidance provided in NEI 12-07, Section 5.8. The CAP disposition should confirm all seals can perform their intended safety function against floods up to the current licensing basis flood height. Disposition may occur as part of the Integrated Assessment.
If an Integrated Assessment is not performed, determine whether there are significant consequences associated with exceeding the capacity of the seals and take interim action(s), if necessary, via the CAP processes.
These actions do not need to be complete prior to the RAI response." Report the APM as "undetermined" and provide the CAP reference in the RAI response.Response to RAI 4: As part of the actions taken in response to this RAI, seal pressure ratings were used to determine APM in accordance with approach a) above. A numerical value for APM was documented in the applicable flood protection feature design document.
Since the APM was greater than the "small" margin threshold value no further action is required.