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MONTHYEARML12047A1772012-02-16016 February 2012 Request for Additional Information Regarding the License Amendment Requests for Upgrading the Licensing Basis for High Energy Line Break Mitigation Project stage: RAI ML12354A2722012-12-20020 December 2012 Request for Additional Information and Suspension of Review of License Amendment Request for Revised Licensing Basis for High-Energy Line Breaks Project stage: RAI 2012-12-20
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Category:Letter
MONTHYEARML23304A1422024-02-0101 February 2024 Issuance of Environmental Scoping Summary Report Associated with the U.S. Nuclear Regulatory Commission Staffs Review of the Oconee Nuclear Station, Units 1, 2, & 3, Subsequent License Renewal Application ML24005A2492024-01-24024 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting) IR 05000269/20243012024-01-11011 January 2024 Notification of Licensed Operator Initial Examination 05000269/2024301, 05000270/2024301, and 05000287/2024301 ML23331A7982023-12-14014 December 2023 Review of the Fall 2022 Steam Generator Tube Inspection Report (01R32) ML23262A9672023-12-13013 December 2023 Alternative to Use RR-22-0174, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems Section XI, Division 1 ML23317A3462023-11-14014 November 2023 Duke Fleet - Correction Letter to License Amendment Nos. 312 & 340 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-554, Revision 1 IR 05000269/20230032023-11-14014 November 2023 Integrated Inspection Report 05000269/2023003, 05000270/2023003, and 05000287/2023003; and IR 07200040/2023001; and Exercise of Enforcement Discretion ML23219A1402023-10-10010 October 2023 Audit Report Proposed Alternative to Use ASME Code Case N-752, Risk Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems XI, Division 1 ML23269A1102023-10-0606 October 2023 Letter to Steven Snider-Revised Schedule for the Environmental Review of the Oconee Nuclear Station, Unit 1, 2, and 3, Subsequent License Renewal Application ML23256A0882023-09-25025 September 2023 Issuance of Alternative to Steam Generator Welds ML23195A0782023-08-29029 August 2023 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-554, Revision 1 IR 05000269/20230112023-08-25025 August 2023 Comprehensive Engineering Team Inspection Report 05000269/2023011 and 05000270/2023011 and 05000287/2023011 IR 05000269/20230052023-08-25025 August 2023 Updated Inspection Plan for Oconee Nuclear Station Units 1, 2 and 3 (Report 05000269/2023005, 05000270/2023005, and 05000287/2023005) IR 05000269/20230022023-07-28028 July 2023 Integrated Inspection Report 05000269/2023002, 05000270/2023002 and 05000287/2023002 ML23208A0972023-07-27027 July 2023 Subsequent License Renewal List of Threatened and Endangered Species That May Occur in Your Proposed Project Location or May Be Affected IR 05000269/20230102023-07-19019 July 2023 Biennial Problem Identification and Resolution Inspection Report 05000269/2023010 and 05000270/2023010 and 05000287/2023010 and Notice of Violation ML23178A0682023-07-0303 July 2023 Audit Plan Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 & 3 Systems Section XI, Division 1 ML23132A2392023-06-0101 June 2023 Summary of the April 2023 Remote Environmental Audit Related to the Review of the Subsequent License Renewal Application ML23144A0192023-05-25025 May 2023 Review of the Spring 2022 Steam Generator Tube Inspection Report (O3R31) IR 05000269/20230012023-05-12012 May 2023 Integrated Inspection Report 05000269/2023001 and 05000270/2023001 and 05000287/2023001 ML23121A0552023-05-0303 May 2023 Acknowledgement of Withdrawal Request to Revise TS 5.5.2 Containment Leakage Rate Testing Program ML23118A0762023-05-0101 May 2023 Approval for Use of Specific Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI ML23117A0432023-04-20020 April 2023 Framatome, Inc., Part 21 Notification of Existence of a Defect ML23075A0732023-04-0505 April 2023 License Renewal Regulatory Audit Regarding the Environmental Review of the Subsequent License Renewal Application Supplement (EPID Number L-2021-SLE-0002) ML23045A1332023-03-15015 March 2023 Request for Scoping Comments Concerning the Supplemental Environmental Review of Oconee Nuclear Station, Units 1, 2, and 3, Subsequent License Renewal Application - Achp Letter ML23045A1402023-03-15015 March 2023 Request for Scoping Comments Concerning the Supplemental Environmental Review of Oconee Nuclear Station, Units 1, 2, and 3, Subsequent License Renewal Application - Shpo Letter ML23045A1432023-03-15015 March 2023 Request for Scoping Comments Concerning the Supplemental Environmental Review of Oconee Nuclear Station, Units 1, 2, and 3, Subsequent License Renewal Application - State Tribe Letter ML22332A4932023-03-10010 March 2023 William States Lee III 1 and 2 - Issuance of Amendments Regarding the Relocation of the Emergency Operations Facility ML23069A1102023-03-10010 March 2023 Notification of Inspection and Request for Information for NRC Problem Identification and Resolution Inspection ML23061A1772023-03-0303 March 2023 Notification of Oconee Nuclear Station Comprehensive Engineering Team Inspection - NRC Inspection Report 05000269/2023011, 05000270/2023011 and 05000287/2023011 IR 05000269/20220062023-03-0101 March 2023 Annual Assessment Letter for Oconee Nuclear Nuclear Station, Units 1, 2 and 3 (NRC Inspection Report 05000269/2022006, 05000270/2022006, and 05000287/2022006) ML23039A1632023-02-0808 February 2023 Requalification Program Inspection ML23037A0772023-02-0606 February 2023 402 Cyber Notification and RFI Letter Final IR 05000269/20220042023-02-0202 February 2023 Integrated Inspection Report 05000269 2022004 and 05000270/2022004 and 05000287/2022004 ML22363A3942023-01-12012 January 2023 Subsequent License Renewal Environmental Report Supplement - Proposed Review Schedule ML22356A0512022-12-14014 December 2022 Curtiss-Wright Nuclear Division, Letter Regarding Potential Efect in a Configuration of the 11/2 Inch Quick Disconnect Connector Cable Assemblies Supplied to Duke Energy (See Attached Spreadsheet) for a Total of 460 of Connectors Only Suppl ML22321A0492022-12-0808 December 2022 Issuance of Amendment Nos. 426, 428 and 427, Additional Mode Change Limitations Applicable to the Adoption of TSTF- 359, Revision 9, Increase Flexibility in Mode Restraints ML22329A1042022-11-29029 November 2022 Review of the Fall 2021 Steam Generator Tube Inspection Report ML22321A1582022-11-22022 November 2022 Summary of Conference Call Regarding the Fall 2022 Steam Generator Tube Inspections ML22096A0032022-11-18018 November 2022 McGuire Nuclear Station and Shearon Harris Nuclear Power Plant Authorization of RA-19-0352 Regarding Use of Alternative for RPV Head Closure Stud Examinations ML22256A2532022-11-14014 November 2022 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-541, Rev. 2 IR 05000269/20220032022-11-0707 November 2022 Integrated Inspection Station 05000269/2022003 and 05000270/2022003 and 05000287/2022003 ML22301A0112022-11-0303 November 2022 Request for Withholding Information from Public Disclosure Regarding the SLR Application - September 2, 2022 ML22298A0752022-10-27027 October 2022 Request for Withholding Information from Public Disclosure Regarding the Subsequent License Renewal Application Duke Energy Letter Dated July 25, 2022 ML22264A0322022-10-20020 October 2022 _Request for Withholding Information from Public Disclosure Regarding the Subsequent License Renewal Application - Duke Energy Letter Dated July 8, 2022 IR 05000269/20220112022-09-26026 September 2022 NRC Inspection Report 05000269/2022011 and 05000270/2022011 and 05000287/2022011 ML22258A0302022-09-15015 September 2022 Evacuation Time Estimate Reports ML22222A0072022-09-14014 September 2022 Request for Withholding Information from Public Disclosure Regarding the Subsequent License Renewal Application ML22231B1362022-09-0101 September 2022 Review of the Draft Environmental Assessment and Findings of No Significant Impact for Catawba Nuclear Station, H.B. Robinson Steam Electric Plant, and Oconee Nuclear Station Independent Spent Fuel Storage Installation Decommissioning Fundi ML22234A0062022-08-30030 August 2022 SLRA - Closed Public Meeting Summary - August 18, 2022 2024-02-01
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML23284A3322023-10-11011 October 2023 Request for Additional Information Alternative Request (RA-22-0174) (L-2022-LLR-0060) ML23178A0682023-07-0303 July 2023 Audit Plan Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 & 3 Systems Section XI, Division 1 ML23156A2452023-06-0505 June 2023 Audit Summary and RAI-RCI - Revised Enclosure ML23151A3482023-05-30030 May 2023 Duke Fleet - Request for Additional Information Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) ML23142A2732023-05-22022 May 2023 Duke Fleet - Request for Additional Information Proposed Alternative for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1) ML23095A0052023-04-0404 April 2023 002 Radiation Safety Baseline Inspection Information Request ML23086C0362023-03-27027 March 2023 Request for Additional Information Steam Generator Tube Inspection Report (03R31) ML23039A1632023-02-0808 February 2023 Requalification Program Inspection ML23038A1832023-02-0707 February 2023 Request for Additional Information Alternative Request (RA-22-0174) to Use ASME Code Case N-752 ML23037A0772023-02-0606 February 2023 402 Cyber Notification and RFI Letter Final ML22251A2902022-09-0808 September 2022 Request for Additional Information Additional Mode Change Limitations Applicable to the Adoption of Technical Specifications Tasks Force Traveler (TSTF) No. 359, Revision 9 ML22234A0052022-08-30030 August 2022 SLRA - Feedback for RAI B2.1.7-4a to Duke - August 16, 2022 ML22157A0042022-06-0606 June 2022 10 CFR 50.59 Inspection Initial Information Request ML22157A0012022-06-0101 June 2022 Email from NRC (Angela Wu) to Duke (Paul Guill) - Oconee SLRA - Additional NRC Comments on RAI 4.6.1-1a ML22154A2122022-06-0101 June 2022 SLRA - 2nd Round RAI B2.1.7-4b ML22124A1632022-05-0303 May 2022 (Public) Oconee SLRA - 2nd Round RAI B2.1.7-4a ML22124A1612022-05-0303 May 2022 Email from Angela Wu (NRC) to Steve Snider (Duke) - Oconee SLRA - 2nd Round RAI B2.1.7-4a ML22122A0182022-04-28028 April 2022 Attachment: Oconee SLRA - 2nd Round RAI B2.1.9-2a ML22122A0192022-04-28028 April 2022 Email from Angela Wu (NRC) to Steve Snider (Duke) - Oconee SLRA - 2nd Round RAI B2.1.9-2a ML22122A1312022-04-27027 April 2022 (Public) Oconee SLRA - 2nd Round RAIs - Trp 76 (Irradiation Structural) - FE 3.5.2.2.2.6 Redacted ML22115A1412022-04-25025 April 2022 NRR E-mail Capture - Duke Common EOF Relocation - Request for Addition Information ML22113A0092022-04-20020 April 2022 Attachment: Oconee SLRA - Final RAI 3.1.2-1 ML22112A0072022-04-20020 April 2022 Email from Marieliz Johnson (NRC) to Steve Snider (Duke) - Oconee SLRA - Request for Confirmation of Information 3.5.2.2.2.6-L ML22081A0062022-03-21021 March 2022 Attachment: Oconee SLRA - 2nd Round RAI B4.1-3 ML22081A0052022-03-21021 March 2022 Email from Angela Wu (NRC) to Steve Snider (Duke) - Oconee SLRA - 2nd Round RAI B4.1-3 ML22080A0772022-03-16016 March 2022 SLRA - RAI Set 4 (2nd Round Rais) ML22069A0012022-03-0808 March 2022 Attachment: Oconee SLRA - Final Requests for Confirmation of Information - Set 4 ML22063A4502022-03-0404 March 2022 Request for Additional Information Application to Revise TS 3.7.7, Low Pressure Service Water (LPSW) System, to Extend the Completion Time for One Required Inoperable LPSW Pump RA-22-0036, Responses to NRC Request for Additional Information Set 22022-02-14014 February 2022 Responses to NRC Request for Additional Information Set 2 ML22019A1042022-01-18018 January 2022 Attachment: Oconee SLRA - Final Requests for Additional Information - Set 3 ML22019A2442022-01-18018 January 2022 Notification of an NRC Fire Protection Team Inspection (FPTI) (NRC Inspection Report 05000269/2022010, 05000270/2022010, 05000287/2022010) and Request for Information (RFI) ML22019A1032022-01-18018 January 2022 Email from Angela Wu (NRC) to Steve Snider (Duke) - Oconee SLRA - Requests for Additional Information - Set 3 ML22012A0422022-01-11011 January 2022 SLRA - Final Requests for Additional Information - Set 2 ML22010A1132022-01-0505 January 2022 SLRA - RCIs - Set 3 ML21333A0392021-11-29029 November 2021 RP Inspection Document Request ML21330A0192021-11-23023 November 2021 Attachment: Oconee SLRA - Final Requests for Confirmation of Information - Set 2 ML21327A2782021-11-23023 November 2021 Email from Angela Wu (NRC) to Steve Snider (Duke) - Oconee SLRA - Final RAIs (Set 1 and 2nd Round RAI B2.1.27-1a) ML21327A2792021-11-23023 November 2021 SLRA - Final Requests for Additional Information - Set 1 ML21327A2802021-11-23023 November 2021 SLRA - Final 2nd Round RAI - RAI B2.1.27-1a ML21313A2342021-11-0404 November 2021 Attachment: Oconee SLRA - Final Requests for Confirmation of Information - Set 1 ML21274A0682021-10-0101 October 2021 Request for Additional Information Alternative Request (RA-20-0334) Regarding Use of an Alternative to the ASME Code Case N-853 Acceptance Criteria ML21273A0492021-09-30030 September 2021 Request for Additional Information Alternative Request (ON-RPI-OMN-28) to Use Code Case OMN-28 ML21271A5892021-09-28028 September 2021 SLRA - RAI B2.1.27-1 (Draft) ML21271A5902021-09-28028 September 2021 SLRA - RAI B2.1.27-1 (Final) ML21271A5882021-09-22022 September 2021 SLRA - Request for Additional Information B2.1.27-1 - Email from Angela Wu (NRC) to Steve Snider (Duke) ML21217A1912021-08-0505 August 2021 Request for Additional Information Alternative Request (RA-20-0334) Regarding Use of an Alternative to the ASME Code Case N-853 Acceptance Criteria ML21190A0172021-07-0808 July 2021 NRR E-mail Capture - Oconee Nuclear Station, Units 1, 2, and 3 - Request for Additional Information Alternative for ISI RPV Weld Examination from 10 to 20 Years (EPID-L-2021-LLR-0004) ML21075A0032021-03-12012 March 2021 Emergency Preparedness Exercise Inspection Request for Information for - Brunswick, Catawba, North Anna, Oconee, Vogtle 1 & 2 ML21049A2632021-02-0404 February 2021 NRR E-mail Capture - Request for Additional Information - Duke Energy Fleet License Amendment Request to Revise Emergency Plan ML20323A4072020-11-18018 November 2020 NRR E-mail Capture - Request for Additional Information - Brunswick License Exemption Request from 10CFR73 Annual Force on Force Exercise Requirements (EPIC L-2020-LLE-0180) 2023-07-03
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 20, 2012 Mr. Preston Gillespie Site Vice President Oconee Nuclear Station Duke Energy Carolinas, LLC 7800 Rochester Highway Seneca, SC 29672
SUBJECT:
OCONEE NUCLEAR STATION, UNITS 1,2, AND 3 - REQUEST FOR ADDITIONAL INFORMATION AND SUSPENSION OF REVIEW OF LICENSE AMENDMENT REQUEST FOR REVISED LICENSING BASIS FOR HIGH-ENERGY LINE BREAKS (TAC NOS. ME7743, ME7744, AND ME7745)
Dear Mr. Gillespie:
By letter dated December 16,2011, Duke Energy Carolinas, LLC (Duke or the licensee) submitted a revised license amendment request (LAR) to the Nuclear Regulatory Commission (NRC) for a change to the plant licensing basis for high-energy line breaks (HELBs) for Oconee Nuclear Station, Units 1, 2, and 3 (ONS 1/2/3). By letter dated July 31, 2012, Duke stated that the implementation of the new protected service water (PSW) system had developed some issues, and requested that the schedule for implementation of the PSW system be delayed by two years. The PSW system is credited in the HELB LAR (e.g., for mitigation of certain high energy line breaks). As the PSW system had been scheduled to be operational before the end of 2012, the NRC staff had proceeded with the HELB LAR with that understanding. Now that the PSW system has been delayed, the NRC staff finds that it is not possible to approve a revised licensing basis for HELBs without the detailed knowledge of the final configuration of the PSW system. Therefore, the NRC staff has suspended the review of the HELB amendment.
Attached is a request for additional information (RAI) on the HELB LAR that had been developed prior to the suspension of the review. When the NRC has issued a license amendment approving the final configuration of the PSW system, please submit the response to this RAI and the NRC staff will resume the review of the HELB LAR.
P. Gillespie -2 If you have any questions, please contact me at 301-415-2901 or via e-mail at John. Boska@nrc.gov.
Sincerely, J hn P. Boska, Senior Project Manager lant licenSing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, 50-287
Enclosure:
Request for Additional Information cc w/encl: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSING BASIS FOR HIGH-ENERGY LINE BREAKS DUKE ENERGY CAROLINAS, LLC OCONEE NUCLEAR STATION, UNITS 1,2, AND 3 DOCKET NOS. 50-269, 50-270, AND 50-287 In Enclosure 3 to a letter dated December 16, 2011, Agencywide Document Access and Management System Accession No. ML120030226, Duke Energy Carolinas, LLC (Duke or the licensee) submitted a compilation of documents comprising a license amendment request (LAR) along with responses to previous requests for additional information (RAls) to the Nuclear Regulatory Commission (NRC) for a revision to the plant's licensing basis for high-energy line breaks for Oconee Nuclear Station, Units 1,2, and 3 (ONS 1/2/3). The NRC staff is reviewing the submittal and has the following questions:
RAI HELB-1 EMCB In the response to RAI 79 in the letter dated December 16, 2011, Duke states:
Surveys of postulated break locations in both the Turbine Building and Auxiliary Building indicated that no interactions with the Turbine/Auxiliary Building wall would occur from postulated breaks located in the Auxiliary Building. These same surveys indicated several interactions that could occur with the Turbine/Auxiliary Building wall from postulated breaks located in the Turbine Bui/ding.
Please provide specific information on the wall interaction and supporting justification to the statement above to include responses to the following:
- How and where have these interactions been satisfactorily documented and addressed by the licensee?
- How do the impacted target (wall) dimensions compare to the pipe(s) diameter(s) that interact with the wall? In addition, please provide a summary of the wall construction and a discussion which shows that the wall has been evaluated and can withstand applicable pipe whip loads.
RAI HELB-2 EMCB In reference to the response to RAI 79, please provide the basis for using Appendix B of ANSI ANSI 58.2 to calculate the steady state thrust forces (pipe whip) and compare these loads to the original design basis.
Enclosure
-2 RAI HELB-3 EMCB In the response to RAI 80, Duke states:
Thermal fatigue stresses alone (i.e., secondary stresses) do not fail piping.
Therefore the original Giambusso/Schwencer break criteria based solely on SA is not appropriate, and the BTP [Branch Technical Position] MEB 3-1 break threshold is used. The current ONS Licensing basis for crack locations is a non-deterministic Giambusso criteria (worst effects). The ASME Code discussion recognizes that self-limiting (secondary) thermal stresses, even above yield, does not fail piping and therefore, for cracks, the 0.4 (Sh + SAl is an appropriate stress limit for crack postulation also taken from BTP MEB 3-1.
A. The statement that thermal fatigue stresses alone do not fail piping has been repeated several times in many of Duke's RAI responses. Please provide justification that validates this statement.
B. Please clarify how the Giambusso/Schwencer break criteria based solely on SA have been shown to be not appropriate.
C. The Duke response mentions "The ASME Code discussion ... " Please provide specific details on this "ASME Code discussion."
RAI HELB-4 EMCB In the response to RAI 80, Duke states:
"The revised outside containment ONS HELB Program does not use Leak-Before-Break methods to link crack and break locations. For rigorously analyzed piping systems, break and crack locations are based only on stress values, and then cracks and breaks are evaluated for their different effects, as required by Giambusso/Schwencer."
Please discuss how the above statement conforms with the requirement to postulate breaks at terminal ends regardless whether the piping system has been rigorously analyzed. (
Reference:
BTP MEB 3-1, Revision 2, 1987: Sections B.1.c.(1 )(a) (Class 1) and B.1.c.(2)(a) (Class 2 & 3).
RAI HELB-5 EMCB In the response to RAI 81, Duke states:
The collar/guard pipe is designed to withstand the pressure loads as a result of a break anywhere under these components. Since they surround a straight piece of 24" nominal diameter pipe, the dynamic and jet effects of a piping break under the collar/guard pipe up to and including the butt weld at the elbow will result in the same dynamic forces, the same pipe reactions and no greater consequences than those breaks initiating from under the guard pipe alone.
-3 Please provide verification that approved and final design & analysis calculations exist that support the above statement.
RAJ HELB-6 EMCB In the response to RAI 83, Duke states:
The ONS HELB criteria address the effects of breaks and cracks for piping down to 1.5 inches NPS.
BTP 3-3-9, Revision 3, March 2007, Appendix B, (Giambusso), Section 3.b. specifies criteria used to determine pipe break orientation at the specified break locations: "Circumferential breaks in piping runs exceeding 1 inch nominal pipe size."
Please verify that there exist no lines that are less than 1.5 inch NPS (Le. 1.25 inch NPS) that should have been considered from a HELB perspective but have been inadvertently excluded.
RAJ HELB-7 EMCB In the response to RAI 84, Duke states:
Duke Energy agrees that NUREGICR-2913 was initiated for the determination of jet impingement effects following a high energy line break. However, Duke Energy requests NRC approval to use the NUREG for determination of the effects from critical cracks.
Please provide information and bases for any precedent(s) that is (are) available for using NUREG/CR-2913 to define jet impingement effects from cracks.
If other plants have been approved to use this approach, provide justification for use of the same approach by Oconee. Establish similarities between any precedent plants including system operating parameters (pressure and temperature), & geometry (including variables such as nominal pipe size) to those lines affected at Oconee.
Address, as necessary, the validity of the application of NUREG/CR-2913 for lines outside the model application ranges stated in the Duke response to RAI 84: "The model ranges in application from 60 bars (870 psi) to 170 bars (2465 psig) pressure and 70 degrees Centigrade (158 degrees Fahrenheit) subcooled liquid to 0.75 (or greater) steam quality."
RAJ HELB-8 EMCB In the response to RAI 85, Duke Energy states:
The original 1973 HELB submittal (MDS OS-73.2) did not include the methodology to which HELB thrust forces and jet impingement loads were calculated. Thrust forces for systems normally in operation and for systems not normally in operation were listed in Tables 2.1-1 and 2.1-2 respectively in the MDS OS-73. 2 report. However the methodology used to determine these forces
- 4 is not included. In addition, the submittal did not include information relative to the jet lengths originating from a high energy line break or crack.
One of the reasons for submitting a new design basis for HELB was to provide sufficient documentation on the bases for break/crack postulation, determination of pipe whip and jet impingement loads, jet impingement lengths, and determination of mitigation strategies that were unclear in the 1973 submittal (MOS OS-73.2).
A. How many more breaks and cracks have been postulated under the "new" methodology and evaluation than were considered in the original evaluation and submittal from 1973?
B. How are the new analyses (submittal designated HELB LARs, Report ONDS-351 Rev 2) establishing a new licensing basis (e.g., show they are as conservative as the original analyses (Report designated MDS OS-73.2) or meet current NRC criteria) based upon the table data (steady state thrust force and steady state thrust coefficient) provided in the response to RAI 85?
C. Duke stated that the original methodology was not included in MDS OS-73.2. Please provide the basis for the following statement: "However, the overall methodology for determining steady state thrust forces appears to be the same."
D. Considering both of the tables included in the Duke response to RAI 85, provide justification for the steady state thrust coefficient that was "back calculated from the IVIDS OS-73.2 thrust force."
E. If other comparisons of steady state thrust forces were made beyond those examples provided in the response to RAI 85, why were they not included? If no other comparisons were made, provide justification as to why.
F. The response to RAI 85 also states:
The portions of ANSIIANS 58.2 regarding assumptions related to jet expansion modeling that may lead to un-conservative assessments ofjet impingement loads from postulated pipe breaks on SSCs located in the zone of influence were not used in the revised ONS HELB licensing basis.
Please clarify what specific assumptions or portions of ANSIIANS 58.2 that may lead to un conservative assessments of jet impingement loads were not used.
G. Address, as necessary, the validity of the application of NUREG/CR-2913 for lines outside the model application ranges stated in the Duke response to RAI 84: "The model ranges in application from 60 bars (870 psi) to 170 bars (2465 psig) pressure and 70 degrees Centigrade (158 degrees Fahrenheit) subcooled liquid to 0.75 (or greater) steam quality."
H. Provide justification that the jet impingement loads calculated in accordance with NUREG/CR-2913 and used to evaluate the structural components are at least as conservative as those used in the original analyses. Please include in the justification a
- 5 summary of jet impingement loads derived by application of NUREG/CR-2913 compared to loads at the same locations used in the original analyses.
RAI HELB-9 EMCB In the response to RAI 86, Duke states:
Per UFSAR Section 3.6. 1. 1 (2), "All penetrations are designed to withstand line rupture forces and moments generated by their own rupture as based on their respective design pressures and temperatures." This is interpreted to mean that each ONS containment penetration is designed for a postulated rupture of the piping running through that penetration. The postulated rupture could be either inside or outside containment. However, the postulated rupture would be adjacent to the anchor point of the penetration. Since the focus of the HELB LAR is for high energy line breaks outside containment, the location of the postulated terminal end breaks at the containment penetrations are outside of the concrete envelope of the reactor building. The locations were previously documented in the original HELB submittal (MDS OS-73.2) and these locations remain the same in the revised ONS HELB licensing basis. Jet impingement loads on each penetration would be bounded by individual line rupture loads given the distributed load characteristic associated with the jet expansion and the small area of the penetration(s).
A. Please verify that documentation exists that shows that the stated interpretation is correct.
B. In the October 23, 2009 Duke response to RAI 9 (b), Duke states that "any postulated break at the containment penetrations (at the terminal end) would result, by definition, in a loss of containment integrity." How is the loss of containment integrity addressed?
RAI HELB-10 EMCB In RAI 87, the following sketch is included:
Sketch RAHl7
- 6 The location of the break (shown outside the containment wall) is being considered as the break location conforming to requirements of Giambusso/Schwencer as described in the Duke response to RAI 87. However, the RAI 87 break location shown in the sketch has the potential to impact the liner plate which Duke acknowledges as an integral part of the Reactor Building containment.
How has the integrity of the liner plate in that location (and others with similar arrangements) been addressed for potential pipe breaks?
Does the licensee assert that a break could not occur at the location labeled "Break Location for RAI 87" in the sketch accompanying RAI 87?
ML12354A272 .. See memo dated 4/11/12 OFFICE DORLlLPL2-1/PM DORLlLPL2-1/LA DE/EMCB/BC" NAME JBoska SFigueroa MMurphy DATE 12119/12 12/19/12 4111112 OFFICE DORLlLPL2-1/BC DORLID DORLlLPL2-1/PM NAME RPascarelli MEvans JBoska DATE 12/19/12 12/20/12 12/20/12