ML080580195

License Renewal Application - Revision 4 to License Renewal Commitments

ML080580195
Person / Time
Site:	Harris
Issue date:	02/19/2008
From:	Natale T J Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
HNP-08-022
Download: ML080580195 (13)

Text

Progress Energy FEB 1 9 2008 SERIAL: HNP-08-022 10 CFR 54 U. S. Nuclear Regulatory Commission ATTENTION:

Document Control Desk Washington, DC 20555

Subject:

, SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400 / LICENSE NO. NPF-63 LICENSE RENEWAL APPLICATION

-REVISION 4 TO LICENSE RENEWAL COMMITMENTS

References:

1. Letter from Cornelius J. Gannon to the U. S. Nuclear Regulatory Commission (Serial: HNP-06-136), "Application for Renewal of.Operating License," dated November 14, 2006 2. Letter from Thomas J. Natale to the U. S. Nuclear Regulatory Commission (Serial: HNP-08-001), "License Renewal Application

-Amendment 6 and Responses to Requests for Additional Information Related to Aging Management Reviews and Time-Limited Aging Analyses," dated January 17, 2008 Ladies and Gentlemen:

On November 14, 2006, Carolina Power & Light Company, doing business as Progress Energy Carolinas, Inc. (PEC), requested the renewal of the operating license for the Shearon Harris Nuclear Power Plant, Unit No. 1, also known as the Harris Nuclear Plant (HNP), to extend the term of its operating license an additional 20 years beyond the current expiration date.By letter dated January 17, 2008, PEC submitted a letter to the NRC that included Revision 3 to the License Renewal (LR) Commitments for HNP. Revision 3 added an additional provision to Commitment

1. 32 regarding the Reactor Coolant Pressure Boundary Fatigue Monitoring Program. Subsequently, it was determined that changes were inadvertently made to Commitments

1. 11 and #12 during preparation of Revision 3 of the LR Commitments.

Commitments

1. 11 and #12 should have remained unchanged from those in the previous revision of the LR Commitments.

Progress Energy Carolinas, Inc.Harris Nuclear Plant P. 0. Box 165 New Hill, NC 27562 4iA2- ,<

Document Control Desk HNP-08-022

/ Page 2 To provide the current text of Commitments

1. 11 and 12, a complete revision of the HNP LR Commitments, Revision 4, has been prepared and is enclosed.

Please refer any questions regarding this submittal to Mr. Roger Stewart, Supervisor

-License Renewal, at (843) 857-5375.I declare, under penalty of perjury, that the foregoing is true and correct (Executed on FEB 1 9 2008 ).Sincerely,.N Thomas J. Natale Manager -Support Services Harris Nuclear Plant TJN/mhf

Enclosure:

HNP License Renewal Commitments, Revision 4 c: Mr. P. B. O'Bryan (NRC Senior Resident Inspector, HNP)Ms. B. 0. Hall (Section Chief, N.C. DENR)Mr. M. L. Heath (NRC License Renewal Project Manager, HNP)Ms. M. G. Vaaler (NRC Project Manager, HNP)Mr. V. M. McCree (NRC Acting Regional Administrator, Region II)

HNP-08-022 Enclosure Page 1 of 11 In accordance with the guidance of NUREG-1801, Rev. 1, regarding aging management of reactor vessel internals components, FINP will: (1) participate in the industry programs for investigating and managing aging effects on reactor internals (such as Westinghouse Owner's Group and Electric Power Research Institute materials programs), (2) evaluate and implement the results of the industry programs as applicable to the reactor internals, and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, submit an inspection plan for reactor internals to the NRC for review and approval.As stated in the commitment Reactor Vessel Internals Aging Management Activities LRA Section A. 1.1 2 In accordance with the guidance of NUREG- 1801, Rev. 1, regarding A. 1.1 As stated in the Primary Water Stress aging management of nickel alloy and nickel-clad components commitment Corrosion Cracking of susceptible to primary water stress corrosion cracking, HNP will Nickel Alloys comply with applicable NRC Orders and will implement:

(1)applicable Bulletins and Generic Letters, and (2) staff-accepted LRA Section A. 1.t1 industry guidelines.

3 Program inspections are performed as augmented inspections in the A. 1.1.5 Prior to the period of Nickel-Alloy Penetration HNP Inservice Inspection (ISI) Program. The ISI Program extended operation Nozzles Welded to the administrative controls will be enhanced to specifically identify the Upper Reactor Vessel requirements of NRC Order EA-03-009.

Closure Heads of Pressurized Water Reactors Program LRA Section B.2.5 4 The Thermal Aging and Neutron Irradiation Embrittlement of Cast A. 1.1.6 Prior to the period of Thermal Aging and Austenitic Stainless Steel (CASS) Program is a new program to be extended operation Neutron Irradiation implemented.

Embrittlement of Cast Austenitic Stainless Steel (CASS) Program LRA Section B.2.6 HNP-08-022 Enclosure Page 2 of 11 The Program will be enhanced to provide a consolidated exclusion bases document (i.e., a FAC susceptibility analysis).

The exclusion bases document will include an evaluation of the Steam Generator Feedwater Nozzles to determine their susceptibility to FAC.A. 1.1./rrior to me perioa or extended operation i ne r iow-Acceleratea Corrosion (FAC)Program LRA Section B.2.7 6 A precautionary note will be added to plant bolting guidelines to A. 1.1.8 Prior to the period of Bolting Integrity prohibit the use of molybdenum disulfide lubricants, extended operation Program LRA Section B.2.8 7 The Program implementing procedure will be enhanced to include a A. 1.1.9 Prior to the period of Steam Generator Tube description of the instructions for implementing corrective actions if extended operation Integrity Program tube plugs or secondary-side components (e.g., tube supports) are found to be degraded.

LRA Section B.2.9 8 The Program will be enhanced to: 1) include measurements of actual A. .1.12 Prior to the period of Boraflex Monitoring boron areal density using in-situ techniques, 2) include neutron extended operation, Program attenuation testing ("blackness testing"), to determine gap formation in unless an approved Boraflex panels, and 3) include the use of the EPRI RACKLIFE analysis exists that LRA Section B.2.12 predictive code or its equivalent, eliminates credit for the Boraflex in the BWR fuel racks 9 The Program will be enhanced to: (1) include in the Program all cranes A.I 1..13 Prior to the period of Inspection of Overhead within the scope of License Renewal; (2) require the responsible extended operation Heavy Load and Light engineer to be notified of unsatisfactory crane inspection results; Load Handling Systems (3) specify an annual inspection frequency for the Fuel Cask Handling Program Crane, Fuel Handling Bridge Crane, and Fuel handling Building Auxiliary Crane, and every refuel cycle for the Polar Crane, Jib LRA Section B.2.13;Cranes, and Reactor Cavity Manipulator Crane, and (4) include a Response to Audit requirement to inspect for bent or damaged members, loose Question B.2.13-JW-01 bolts/components, broken welds, abnormal wear of rails, and corrosion (other than minor surface corrosion) of steel members and connections.

HNP-08-022 Enclosure Page 3 of 11 i ne program wiii oe ennancec to: (1) include inspection criteria as described in NUREG- 1801 for penetration seals, (2) provide specific procedural guidance for inspecting fire barrier walls, ceilings and floors, (3) include a visual inspection of the diesel-driven fire pump fuel oil supply piping for signs of leakage, and (4) include minimum qualification requirements for inspectors performing inspections required by this Program.vrior to me perioa or extended operation LRA Section B.2.14 11 The Program will be revised to: (1) incorporate a requirement to perform one or a combination of the following two activities: (a) Perform non-intrusive baseline pipe thickness measurements at various locations, prior to the expiration of current license and trended through the period of extended operation.

The plant-specific inspection intervals will be determined by engineering evaluation performed after each inspection of the fire protection piping to detect degradation prior to the loss of intended function, or (b) Perform flow testing meeting the general flow requirements (intent) of NFPA 25, (2) either replace the sprinkler heads prior to reaching their 50-year service life or revise site procedures to perform field service testing, by a recognized testing laboratory, of representative samples from one or more sample areas, and (3) for in-scope spray nozzles, either (a) add a requirement to perform flow testing to ensure proper spray pattern or (b) add a modification to prevent blockage from external sources.A. 1.1.15 Prior to the period of extended operation Fire Water System Program LRA Section B.2.15 Commitment (1)(b) and the option of using a combination of (1)(a)and (1)(b) were added in the response to Audit Question B.2.15-PB-01 Commitment (3) was added per Audit Question 3.3.1-70-MK-0 1

HNP-08-022 Enclosure Page 4 of 11 Program admmistrative controls will te ennanced to: (1) add requirements to enter an item into the corrective action program whenever an administrative value or control limit for parameters relevant to this program are exceeded or water is drained from a fuel oil tank in the scope of this program; (2) establish administrative values for fuel oil chemistry parameters relating to corrosion; (3) require Diesel Fuel Oil System chemistry controls to include semiannual monitoring and trending of water and sediment and particulates from an appropriate sample point for the day tanks and semiannual monitoring and trending of biological growth in the main storage tanks; (4) require Security Power System fuel oil chemistry controls to include semiannual monitoring and trending of biological growth in the fuel oil in the buried storage tank and periodic inspecting of the internal surfaces of the buried storage tank and the aboveground day tank or require UT or other NDE of the tanks if inspection proves inadequate or indeterminate; (5) require Site Fire Protection System fuel oil chemistry controls for the Diesel Driven Fire Pump fuel oil storage tank to include quarterly monitoring and trending of particulates and semiannual monitoring and trending of biological growth, to check and remove water quarterly, to periodically inspect the tank or require UT or other NDE of the tank if inspection proves inadequate or indeterminate; and to revise chemistry sampling procedures to address positive results for biological growth including as one option the use of biocides; and (6) verify the condition of the Diesel Fuel Oil Storage Tank Building Tank Liners by means of bottom thickness measurements under the One Time Inspection Program. Day tank sampling for water, sediment, and particulate contamination is considered to be confirmatory of components outside the main storage tanks, and its frequency may be adjusted based on site operating experience.

'rior to me perioa ot extended operation ruel ui. unemstry Program LRA Section B.2.16, Response to Audit Question B.2.16-MK-12 HNP-08-022 Enclosure Page 5 of 11 The Program will be enhanced to: (1) include a provision that tested and untested specimens from all capsules pulled from the reactor vessel must be kept in storage to permit future reconstitution use, and that the identity, traceability, and recovery of the capsule specimens shall be maintained throughout testing and storage, (2) include a provision that withdrawal of the next capsule (i.e., Capsule W) will occur during Refueling Outage 16, at which time the capsule fluence is projected to be equivalent to the 60-year maximum vessel fluence of 6.8x10 1 9 n/cm2 in accordance with ASTM E 185-82, (3) include a provision that analysis of Capsule W be used to evaluate neutron exposure for remaining Capsules Y and Z, as required by 10 CFR 50 Appendix H. The withdrawal schedule for one of the remaining capsules will be adjusted, based on the analysis of Capsule W, so that the capsule fluence will not exceed twice the 60-year maximum vessel fluence in accordance with ASTM E 185-82. The neutron exposure and withdrawal schedule for the last capsule will be optimized to provide meaningful metallurgical data. If the last capsule is projected to significantly exceed a meaningful fluence value, it will either be relocated to a lower flux position or withdrawn for possible testing or re-insertion.

Capsules Y and Z and archived test specimens available for reconstitution will be available for the monitoring of neutron exposure if additional license renewals are sought, and (4) include a provision that, if future plant operations exceed the limitations in Section 1.3 of Regulatory Guide 1.99, Revision 2, or the applicable bounds, e.g., cold leg operating temperature and neutron fluence, as applied to the surveillance capsules, the impact of these plant operation changes on the extent of reactor vessel embrittlement will be evaluated, and the NRC will be notified.Prior to tne period or extended operation Keactor vessel Surveillance Program LRA Section B.2.17, RAI-B.2.17 14 The One-Time Inspection Program is a new program to be A. 1. 1. 18 Prior to the period of One-Time Inspection implemented.

extended operation Program LRA Section B.2.18 1HNP-08-022 Enclosure Page 6 of 11 i J i ne 3eiectJve Leacfing o0 iviateriais rrogram is a new program Lo De implemented IAk.l l.1.1 tnior LU mIC Periou 01 extended operation electlive LcdcinLIg 01 Materials Program LRA Section B.2.19 16 The Buried Piping and Tanks Inspection Program is a new program to A. 1.1.20 Prior to the period of Buried.Piping and Tanks be implemented.

extended operation Inspection Program LRA Section B.2.20 17 The One-Time Inspection of ASME Code Class 1 Small-Bore Piping A. 1.1.21 Prior to the period of One-Time Inspection of Program is a new program to be implemented.

extended operation ASME Code Class 1 Small-Bore Piping Program LRA Section B.2.21 18 The program will be enhanced to: (1) include a specific list of systems A. 1.1.22 Prior to the period of External Surfaces managed by the program for License Renewal, (2) provide specific extended operation Monitoring Program guidance for insulated/jacketed pipe and piping components to identify signs of leakage and provide criteria for determining whether the LRA Section B.2.22 insulation/jacket should be removed to inspect for corrosion, (3)provide inspection criteria for components not readily accessible during plant operations or refueling outages, (4) provide specific guidance for visual inspections of elastomers for cracking, chafing, or changes in material properties due to wear, and (5) incorporate a checklist for evaluating inspection findings, with qualified dispositions.

19 The Program will be enhanced:

(1) to require an evaluation of historic A. 1.1.23 Prior to the period of Flux Thimble Tube plant-specific test data in order to ensure that conservative wear rates extended operation Inspection Program are used so that a loss of intended function will not occur, (2) to provide guidance for treatment of flux thimbles that could not be LRA Section B.2.23 inspected due to restriction, defect or other reason, and (3) to require test results and evaluations be formally documented as QA records.

HNP-08-022 Enclosure Page 7 of 11 I lie Inspection ot Internal iurtaces in Miscellaneous Piping and Ducting Components Program is a new program to be implemented.

Prior to tne period ot extended operation Inspection ot Internal Surfaces in Miscellaneous Piping and Ducting Components Program LRA Section B.2.24 21 The Program will be enhanced as follows: (1) a review and revision of A. 1.1.25 Prior to the period of Lubricating Oil Analysis work documents and analysis requirements will be performed to ensure extended operation Program that the used oil from appropriate component types in the scope of License Renewal is analyzed to determine particle count and moisture, LRA Section B.2.25 and if oil is not changed in accordance with the manufacturer's recommendation, then additional analyses for viscosity, neutralization number, and flash point will be performed.

This activity will ensure that used oil is visually checked for water; and (2) the program administrative controls will be enhanced to include a requirement to perform ferrography or elemental analysis to identify wear particles or products of corrosion when particle count exceeds an established level or when considered appropriate.

22 The Program implementing procedure will be enhanced to: (1) include A. 1.1.26 Prior to the period of ASME Section XI, additional recordable conditions, (2) include moisture barrier and extended operation Subsection IWE applicable aging effects, (3) include pressure retaining bolting and Program aging effects, and (4) include a discussion of augmented examinations.

LRA Section B.2.26 23 The Program will be enhanced to describe in the implementing A. 1.1.29 Prior to the period of 10 CFR Part 50, procedures the evaluation and corrective actions to be taken when extended operation Appendix J Program leakage rates do not meet their specified acceptance criteria.LRA Section B.2.29 24 Program administrative controls will be enhanced to identify the A. 1.1.30 Prior to the period of Masonry Wall Program structures that have masonry walls in the scope of License Renewal. extended operation LRA Section B.2.30 HNP-08-022 Enclosure Page 8 of 11 2D The Program implementing procedures will be enhanced to: (1) identify the License Renewal structures and systems that credit the program for aging management, (2) require notification of the responsible engineer when below-grade concrete is exposed so an inspection may be performed prior to backfilling, (3) require periodic groundwater chemistry monitoring including consideration for potential seasonal variations., (4) define the term "structures of a system" in the system walkdown procedure and specify the condition monitoring parameters that apply to "structures of a system," (5) include the corporate structures monitoring procedure as a reference in the plant implementing procedures and specify that forms from the corporate procedure be used for inspections, (6) identify additional civil/structural commodities and associated inspection attributes required for License Renewal, and (7) require inspection of inaccessible surfaces of reinforced concrete pipe when exposed by removal of backfill.A. 1.1.31 Prior to the period of extended operation mructures Monitoring Program LRA Section B.2.31 26 The Program will be enhanced to: (1) require an evaluation of any A. 1. 1.32 Prior to the period of RG 1.127, Inspection of concrete deficiencies in accordance with the acceptance criteria extended operation Water-Control Structures provided in the corporate inspection procedure, (2) require initiation of Associated with Nuclear a Nuclear Condition Report (NCR) for degraded plant conditions and Power Plants Program require, as a minimum, the initiation of an NCR for any condition that constitutes an "unacceptable" condition based on the acceptance LRA Section B.2.32 criteria specified, and (3) require documentation of a visual inspection of the miscellaneous steel at the Main Dam and Spillway.27 The Electrical Cables and Connections Not Subject to 10 CFR 50.49 A. 1.1.33 Prior to the period of Electrical Cables and Environmental Qualification Requirements Program is a new program extended operation Connections Not Subject to be implemented.

to 10 CFR 50.49 Environmental Qualification Requirements Program LRA Section B.2.33 HNP-08-022 Enclosure Page 9 of 11 The Electrical Cables and Connections Not Subject to 10 CFR 50.4c Environmental Qualification Requirements Used in Instrumentation Circuits Program is a new program to be implemented.

'rior to the perioc ot extended operation Electrical uables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Program LRA Section B.2.34 29 The Inaccessible Medium Voltage Cables Not Subject to 10 CFR A. 1.1.35 Prior to the period of Inaccessible Medium 50.49 Environmental Qualification Requirements Program is a new extended operation Voltage Cables Not program to be implemented.

Subject to 10 CFR 50.49 Environmental Qualification Requirements Program LRA Section B.2.35 30 The Metal Enclosed Bus Program is a new program to be A. 1.1.36 Prior to the period of Metal Enclosed Bus implemented.

extended operation Program LRA Section B.2.36 31 The Electrical Cable Connections Not Subject to 10 CFR 50.49 A. 1.1.37 Prior to the period of Electrical Cable Environmental Qualification Requirements Program is a new program extended operation Connections Not Subject to be implemented.

to 10 CFR 50.49 Environmental Qualification Requirements Program LRA Section B.2.37 HNP-08-022 Enclosure Page 10 of 1I 1 ne F'rogram will e ennancea to: (i) expani me program scope to include an evaluation of selected RCPB components beyond the reactor pressure vessel (including auxiliary system components such as the pressurizer lower head, pressurizer surge line, and CVCS piping and heat exchanger), and to include the NUREG/CR-6260 locations analyzed for environmental effects, (2) provide preventive actions to include, prior to a monitored location exceeding a cumulative usage factor limit of 1.0, evaluation of operational changes to reduce the number or severity of future transients, (3) include a provision to utilize online fatigue analysis software for the periodic updating (not to exceed once every 18 months) of cumulative usage, (4) describe the acceptance criteria for maintaining fatigue usage below the design limit, and (5) address corrective actions, to be implemented through the Corrective Action Program, for components that have exceeded alarm limits, with options to include a revised fatigue analysis or repair or replacement of the component and for piping systems that have exceeded their cyclic alarm limit to require a review of the pertinent design calculations to determine if any additional locations should be designated as nostulated high enermy line breaks.rrior to me periou o0 extended operation Reactor Coolant Pressure Boundary (RCPB)Fatigue Monitoring Program LRA Section B.3.1, Response to Audit Questions B.3.1 -RH-0 1, B.3.1-RH-05, and 4.7.4-1 (Follow-up) 33 The Low Temperature Overpressure (LTOP) setpoint analysis will be A. 1.2.1.4 After capsule fast TLAA -Low recalculated following removal of one of the remaining surveillance neutron exposure temperature Over-capsules from the reactor vessel, comparable to the Pressure Limits end of the period of extended operation LRA Section 4.2.5 34 The Oil-Filled Cable Testing Program is a new program to be A. 1.1.40 Prior to the period of Oil-Filled Cable Testing implemented.

extended operation Program LRA Section B.2.38, Response to Audit Question LRA-3.6.2-1-RM-02 Pi HNP-08-022 Enclosure Page 11 of 11 When the EPRI MRP methodology described in MRP-140, "Materials Reliability Program: Leak-Before-Break Evaluation for PWR Alloy 82/182 Welds," has been reviewed and approved by the NRC, 1HNP will review its plant-specific calculation for conformance to the endorsed approach.AS stateo in tne commitment I LAA -LeaK-betore-Break evaluation for Alloy 82/182 Welds LRA Section 4.3.4, Response to Audit Question LRA 4.3.4-1