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MONTHYEARML12073A3542012-03-0909 March 2012 30-Day Report Pursuant to 10 CFR 50.46, Changes to or Errors in an Evaluation Model Project stage: Request ML12300A2012012-10-26026 October 2012 NRC Request for Additional Information on Errors Reported Per 10 CFR 50.46, ME9119 Project stage: RAI ML12348A0552012-12-0707 December 2012 Response to RAI Regarding 10 CFR 50.46 Notification of Change in Peak Cladding Temperature for Large Break Loss of Coolant Accident Analysis Project stage: Request ML13060A4172013-03-0101 March 2013 NRC Request for Additional Information on Errors Reported Per 10 CFR 50.46 (TACs ME9119, ME9120, ME9121) Project stage: RAI ML13102A0332013-04-0404 April 2013 Response to NRC RAI Regarding 10 CFR 50.46 Notification of Change in Peak Cladding Temperature for Large Break Loss of Coolant Accident Analysis Project stage: Request ML13237A0022013-08-23023 August 2013 NRR E-mail Capture - Oconee Nuclear Station, Units 1, 2, and 3, NRC Request for Additional Information on Errors Reported Per 10 CFR 50.46 (TACs ME9119, ME9120, ME9121) Project stage: RAI ML13309A4462013-09-12012 September 2013 E-mail from R.Guzman to T.Byrne Request for Additional Information on Errors Reported Per 10 CFR 50.46 (TACs ME9119, ME9120, ME9121) Project stage: RAI RA-13-1002, Response to Supplemental NRC RAI Regarding 10 CFR 50.46 Notification of Change in Peak Cladding Temperature for Large Break Loss of Coolant Accident2013-10-10010 October 2013 Response to Supplemental NRC RAI Regarding 10 CFR 50.46 Notification of Change in Peak Cladding Temperature for Large Break Loss of Coolant Accident Project stage: Request ML13338A3452013-12-0505 December 2013 Closure Evaluation for Report Concerning Significant Emergency Core Cooling System Evaluation Model Errors/Changes Project stage: Other 2013-12-05
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Category:Letter type:RA
MONTHYEARRA-23-0325, Submittal of Procedures CSD-EP-HNP-0101-01, 02, CSD-EP-ONS-0101-01, CSD-EP-RNP-0101-01, and EP-RNP-EPLAN-ANNEX2024-01-0808 January 2024 Submittal of Procedures CSD-EP-HNP-0101-01, 02, CSD-EP-ONS-0101-01, CSD-EP-RNP-0101-01, and EP-RNP-EPLAN-ANNEX RA-23-0320, Notification of Deviation from MRP-227, Revision 1-A Baffle-to-Former Bolt Inspection Frequency2023-12-14014 December 2023 Notification of Deviation from MRP-227, Revision 1-A Baffle-to-Former Bolt Inspection Frequency RA-23-0318, Supplement to Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-0404 December 2023 Supplement to Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation RA-23-0182, Duke Energy Carolinas, LLC - License Amendment Request to Revise Technical Specification 5.5.2, Containment Leakage Rate Testing Program for a One-Time Extension of the Units 1, 2 and 3 Type a Leak Rate Test Frequency2023-11-16016 November 2023 Duke Energy Carolinas, LLC - License Amendment Request to Revise Technical Specification 5.5.2, Containment Leakage Rate Testing Program for a One-Time Extension of the Units 1, 2 and 3 Type a Leak Rate Test Frequency RA-23-0284, RA-23-0284 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-16016 November 2023 RA-23-0284 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation RA-23-0304, Transmittal of Core Operating Limits Report (COLR) for Oconee Unit 2 Cycle 32 (Revision 0)2023-11-14014 November 2023 Transmittal of Core Operating Limits Report (COLR) for Oconee Unit 2 Cycle 32 (Revision 0) RA-23-0281, Procedure EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 5, Summary of Changes2023-11-0101 November 2023 Procedure EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 5, Summary of Changes RA-23-0275, Subsequent License Renewal Application, Appendix E, Responses to Requests for Additional Information (Rai), and Request for Confirmation of Information (RCI)2023-10-12012 October 2023 Subsequent License Renewal Application, Appendix E, Responses to Requests for Additional Information (Rai), and Request for Confirmation of Information (RCI) RA-23-0268, Transmittal of Sixth 10-Year Inservice Testing Interval Program Plan2023-09-29029 September 2023 Transmittal of Sixth 10-Year Inservice Testing Interval Program Plan RA-23-0234, Update to the Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations for Oconee Nuclear Station (ONS)2023-09-28028 September 2023 Update to the Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations for Oconee Nuclear Station (ONS) RA-23-0225, Procedure AD-EP-ALL-0109, Offsite Protective Action Recommendations, Revision 9, and the Joint Information Center (JIC) Relocation, Summary of Changes2023-09-20020 September 2023 Procedure AD-EP-ALL-0109, Offsite Protective Action Recommendations, Revision 9, and the Joint Information Center (JIC) Relocation, Summary of Changes RA-23-0228, Registration for Use of General License Spent Fuel Cask Number 1752023-09-14014 September 2023 Registration for Use of General License Spent Fuel Cask Number 175 RA-23-0223, Registration for Use of General License Spent Fuel Cask Numbers 173 and 1742023-08-23023 August 2023 Registration for Use of General License Spent Fuel Cask Numbers 173 and 174 RA-23-0222, On-Shift Staffing Analysis (Ossa), Revision 12023-08-23023 August 2023 On-Shift Staffing Analysis (Ossa), Revision 1 RA-23-0211, Reply to a Notice of Violation (NOV) 05000270/2023010-022023-08-17017 August 2023 Reply to a Notice of Violation (NOV) 05000270/2023010-02 RA-23-0154, Duke Energy - Response to Request for Additional Information Regarding Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1)2023-07-20020 July 2023 Duke Energy - Response to Request for Additional Information Regarding Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) RA-23-0136, Duke Energy Response to Request for Additional Information Regarding Proposed Alternative for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1)2023-07-20020 July 2023 Duke Energy Response to Request for Additional Information Regarding Proposed Alternative for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1) RA-23-0186, Transmittal of Core Operating Limits Report (COLR) for Oconee Unit 2 Cycle 31 (Revision 3)2023-07-18018 July 2023 Transmittal of Core Operating Limits Report (COLR) for Oconee Unit 2 Cycle 31 (Revision 3) RA-23-0184, Registration for Use of General License Spent Fuel Cask Numbers 171 and 1722023-07-10010 July 2023 Registration for Use of General License Spent Fuel Cask Numbers 171 and 172 RA-23-0142, Mcguire, Units 1 and 2, Oconee, Units 1, 2, and 3, H. B. Robinson, Unit 2, Response to Request for Additional Information Regarding the License Amendment Request to Revise Restrictive Technical Specification Surveillance Require2023-07-0707 July 2023 Mcguire, Units 1 and 2, Oconee, Units 1, 2, and 3, H. B. Robinson, Unit 2, Response to Request for Additional Information Regarding the License Amendment Request to Revise Restrictive Technical Specification Surveillance Require RA-23-0146, Subsequent License Renewal Application, Appendix E, Responses to Requests for Additional Information (Rai), and Request for Confirmation of Information (RCI)2023-06-20020 June 2023 Subsequent License Renewal Application, Appendix E, Responses to Requests for Additional Information (Rai), and Request for Confirmation of Information (RCI) RA-23-0135, Submittal of 30 Day Report Per 10 CFR 26.719(c), Unsatisfactory Performance of Health and Human Services Certified Laboratory2023-06-0707 June 2023 Submittal of 30 Day Report Per 10 CFR 26.719(c), Unsatisfactory Performance of Health and Human Services Certified Laboratory RA-23-0041, Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations2023-05-30030 May 2023 Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations RA-23-0128, Refuel 32 (O1R32) Steam Generator Tube Inspection Report2023-05-18018 May 2023 Refuel 32 (O1R32) Steam Generator Tube Inspection Report RA-23-0018, Relief Request (RA-23-0018) to Utilize Code Case N-853 PWR Class 1 Primary Piping Alloy 600 Full Penetration Branch Connection Weld Metal Buildup for Material Susceptible to Primary Water Stress Corrosion Cracking Section XI, Division 12023-05-0404 May 2023 Relief Request (RA-23-0018) to Utilize Code Case N-853 PWR Class 1 Primary Piping Alloy 600 Full Penetration Branch Connection Weld Metal Buildup for Material Susceptible to Primary Water Stress Corrosion Cracking Section XI, Division 1 RA-23-0111, Withdrawal of License Amendment Request to Revise Technical Specification 5.5.2, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies2023-04-27027 April 2023 Withdrawal of License Amendment Request to Revise Technical Specification 5.5.2, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies RA-23-0104, Response to Request for Additional Information (RAI) Regarding Oconee Unit 3, Refuel 31 (O3R31) Steam Generator Tube Inspection Report2023-04-26026 April 2023 Response to Request for Additional Information (RAI) Regarding Oconee Unit 3, Refuel 31 (O3R31) Steam Generator Tube Inspection Report RA-23-0047, Duke Energy Annual Radiological Environmental Operating Report - 20222023-04-26026 April 2023 Duke Energy Annual Radiological Environmental Operating Report - 2022 RA-23-0044, Aduke Energy Annual Report of Changes Pursuant to 10 CFR 50.462023-04-26026 April 2023 Aduke Energy Annual Report of Changes Pursuant to 10 CFR 50.46 RA-23-0099, Subsequent License Renewal Application Second Annual Amendment to the License Renewal Application2023-04-25025 April 2023 Subsequent License Renewal Application Second Annual Amendment to the License Renewal Application RA-23-0046, Annual Radioactive Effluent Release Report - 20222023-04-24024 April 2023 Annual Radioactive Effluent Release Report - 2022 RA-22-0292, License Amendment Request to Revise Technical Specification 5.5.2, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies2023-04-0404 April 2023 License Amendment Request to Revise Technical Specification 5.5.2, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies RA-23-0036, Biennial Decommissioning Financial Assurance Reports2023-03-30030 March 2023 Biennial Decommissioning Financial Assurance Reports RA-23-0040, Onsite Property Insurance Coverage2023-03-30030 March 2023 Onsite Property Insurance Coverage RA-23-0039, 10 CFR 140.21 Licensee Guarantees of Payment of Deferred Premiums2023-03-30030 March 2023 10 CFR 140.21 Licensee Guarantees of Payment of Deferred Premiums RA-23-0037, Duke Energy - Decommissioning Funding Plan for Independent Spent Fuel Storage Installations (Isfsis)2023-03-30030 March 2023 Duke Energy - Decommissioning Funding Plan for Independent Spent Fuel Storage Installations (Isfsis) RA-23-0051, Response to Request for Additional Information (RAI) Regarding Proposed Alternative to Use American Society of Mechanical Engineers Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities2023-03-0909 March 2023 Response to Request for Additional Information (RAI) Regarding Proposed Alternative to Use American Society of Mechanical Engineers Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities RA-23-0052, Refuel 32 (O1R32) Inservice Inspection (ISI) Report, Fifth 10-Year ISI Interval2023-02-22022 February 2023 Refuel 32 (O1R32) Inservice Inspection (ISI) Report, Fifth 10-Year ISI Interval RA-22-0257, Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1)2023-02-17017 February 2023 Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) RA-22-0091, Application to Revise Technical Specifications to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements2023-02-16016 February 2023 Application to Revise Technical Specifications to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements RA-23-0001, Request to Use a Provision of a Later Edition and Addenda of the ASME Boiler and Pressure Vessel Code, Section XI2023-02-0202 February 2023 Request to Use a Provision of a Later Edition and Addenda of the ASME Boiler and Pressure Vessel Code, Section XI RA-22-0118, License Amendment Request to Revise Restrictive Technical Specification Surveillance Requirement Frequencies2023-02-0101 February 2023 License Amendment Request to Revise Restrictive Technical Specification Surveillance Requirement Frequencies RA-22-0256, Proposed Alternative for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1)2023-01-23023 January 2023 Proposed Alternative for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1) RA-22-0335, Submittal of 30-Day Report Per 10CFR26.719(c)(1) - Unsatisfactory Performance of a Health & Human Services Certified Lab2022-12-0505 December 2022 Submittal of 30-Day Report Per 10CFR26.719(c)(1) - Unsatisfactory Performance of a Health & Human Services Certified Lab RA-22-0334, Refuel 31 (O3R31) Steam Generator Tube Inspection Report2022-11-21021 November 2022 Refuel 31 (O3R31) Steam Generator Tube Inspection Report RA-22-0329, Transmittal of Core Operating Limits Report (COLR) for Oconee Unit 1 Cycle 33 (Revision 0 and Revision 1)2022-11-11011 November 2022 Transmittal of Core Operating Limits Report (COLR) for Oconee Unit 1 Cycle 33 (Revision 0 and Revision 1) RA-22-0285, Subsequent License Renewal - Appendix E Environmental Report Supplement 22022-11-0707 November 2022 Subsequent License Renewal - Appendix E Environmental Report Supplement 2 RA-22-0313, Emergency Action Level (EAL) Technical Basis Document, Revision 4, EAL Wallchart, Revision 3 and Alternate TSC and OSC Renovations2022-10-27027 October 2022 Emergency Action Level (EAL) Technical Basis Document, Revision 4, EAL Wallchart, Revision 3 and Alternate TSC and OSC Renovations RA-22-0270, Response to Request for Additional Information Regarding License Amendment Request to Address Technical Specifications Mode Change Limitations2022-10-0707 October 2022 Response to Request for Additional Information Regarding License Amendment Request to Address Technical Specifications Mode Change Limitations RA-22-0192, Subsequent License Renewal Application Response to ONS SLRA Second Round RAI B2.1.7-4a2022-09-0202 September 2022 Subsequent License Renewal Application Response to ONS SLRA Second Round RAI B2.1.7-4a 2024-01-08
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Text
Joseph Frisco,Jr.
DUKENuear Desin Engneering ENERGY Duke EnW Corpoiadon ECO7/526 South Church SOWeet Charlole, NC 28202 Mailing Adcfrew P.O. Box 1006 Chae/ote, NC 28201-1006 October 10, 2013 10 CFR 50.46 RA-1 3-1002 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Duke Energy Carolinas, LLC (Duke Energy)
Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, 50-270, and 50-287 Renewed Op. License Nos. DPR-38, DPR-47, and DPR-55
Subject:
Response to Supplemental NRC RAI regarding 10 CFR 50.46 Notification of Change in Peak Cladding Temperature for Large Break Loss of Coolant Accident
References:
- 1) Letter, D. C. Culp (Duke Energy) to USNRC,
Subject:
Oconee Nuclear Station Day Report Pursuant to 10 CFR 50.46, Changes to or Errors in an Evaluation Model, March 9, 2012. [ADAMS Accession No. ML12073A354]
- 2) Email correspondence, John Boska (USNRC) to Kent R. Alter (Duke Energy),
Subject:
Oconee Units 1, 2, and 3, NRC Request for Additional Information on Errors Reported per 10 CFR 50.46, ME9119, October 26, 2012. [ADAMS Accession No. ML12300A201]
- 3) Letter, Pedro Salas, Director, Regulatory Affairs (AREVA NP Inc.) to USNRC,
Subject:
Generic RAI Response to a 30-day 10 CFR 50.46 Report of Significant PCT Change, December 6, 2012. [ADAMS Accession No. ML12342A381]
- 4) Letter, Garry D. Miller (Duke Energy) to USNRC,
Subject:
Response to NRC RAI regarding 10 CFR 50.46 Notification of Change in Peak Cladding Temperature for Large Break Loss of Coolant Accident Analysis, December 7, 2012. [ADAMS Accession No. ML12348A055]
- 5) Letter, Pedro Salas, Director, Regulatory Affairs (AREVA NP Inc.) to USNRC,
Subject:
Generic RAI Response to a 30-day 50.46 Report of Significant PCT Change, March 28, 2013. [ADAMS Accession No. ML13091A075]
wwduke-we~mnely
US Nuclear Regulatory Commission October 10, 2013 Page 2
- 6) Email correspondence, V. Sreenivas (USNRC) to Kent R. Alter (Duke Energy),
Subject:
Oconee Units 1, 2, and 3, NRC Request for Additional Information on Errors Reported per 10 CFR 50.46, (TACs ME9119, ME9120, ME9121), August 23, 2013. [ADAMS Accession No. ML13237A002]
- 7) Email correspondence, Richard Guzman (USNRC) to Tom R. Byrne (Duke Energy),
Subject:
Oconee Units 1, 2, and 3, NRC Request for Additional Information on Errors Reported per 10 CFR 50.46 (TACs ME9119, ME9120, ME9121), September 12, 2013.
On March 9, 2012, (Reference 1) Duke Energy submitted a 30-day report pursuant to 10 CFR 50.46(a)(3)(ii) regarding the impact on Peak Cladding Temperature (PCT) from two errors in the Emergency Core Cooling System (ECCS) evaluation model used to assess a postulated Large Break Loss of Coolant Accident (LBLOCA) for Oconee Nuclear Station. This information is specific to the application of the AREVA ECCS evaluation model for B&W plants, as applied to Oconee Nuclear Station.
The NRC transmitted, via email (Reference 2), Requests for Additional Information (RAls) regarding the Reference 1 letter, concerning the 30-day report pursuant to 10 CFR 50.46(a)(3)(ii). References 3, 4, and 5 provided the response to the RAls of Reference 2.
Subsequently, the NRC transmitted, via email (References 6 and 7) Requests for Additional Information (RAls) regarding the Reference 1 and 4 letters. The purpose of this letter is to provide a response to the RAIs.
There are no regulatory commitments contained in this letter.
Please address any comments or questions regarding this matter to Thomas R.
Byrne at (980) 373-3249 (Tom.Byme@duke-energy.com).
Sincerely, Joseph Frisco, Jr.
Vice President Nuclear Design Engineering
US Nuclear Regulatory Commission October 10, 2013 Page 3 Enclosure xc (with enclosure):
V. M. McCree, Region II Administrator U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 R. V. Guzman, Acting Project Manager (ONS)
U. S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 C2 Rockville, MD 20852-2738 NRC Senior Resident Inspector Oconee Nuclear Station
DUKE ENERGY CAROLINAS, LLC OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 ENCLOSURE RESPONSE TO SUPPLEMENTAL NRC RAI REGARDING 10 CFR 50.46 NOTIFICATION OF CHANGE IN PEAK CLADDING TEMPERATURE FOR LARGE BREAK LOSS OF COOLANT ACCIDENT ANALYSIS 2 total pages to follow
Response to NRC Request for Additional Information:
NRC RAI Question 1 On October 26, 2012, the staff issued a Request for Additional Information (RAI) to the licensee (ADAMS Accession Number ML12300A201) regarding the 30-day report which stated the following:
10 CFR 50.46(a)(3)(ii) states:" ... If the change or error is significant, the applicant or licensee shall provide this report within 30 days and include with the report a proposed schedule for providing a reanalysis or taking other action as may be needed to show compliance with 50.46 requirements... "
The PCT for LBLOCA for Oconee has changed by an absolute value of 160OF since the analysis was performed. Simply reporting the changes and errors in the methodology does not satisfy the intent of the regulation.
Justify not providing a schedule for reanalysis or taking other action to show compliance with Section 50.46.
The licensee responded to the RAI on December 7, 2012 (ADAMS Accession Number ML12348A055).
The RAI response does not include a proposed schedule for providing a reanalysis. In the response, the licensee states that the PCT error evaluations are supported by explicit analyses using the B&W plant ECCS evaluation model. Since a schedule for reanalysis was not provided, justify how generic analysis for the B&W plant ECCS evaluation model constitutes "taking other action" to show compliance with Section 50.46. In particular, while the submitted RAI response addresses the acceptance criteria contained in 10 CFR 50.46(b),
the response does not address the requirement, at 10 CFR 50.46(a)(1 Xi), to calculate "ECCS cooling performance..." "in accordance with an acceptable evaluation model."
In light of the presently reported, significant, estimated effects of errors and changes, explain how the present ECCS cooling performance has been calculated in accordance with an acceptable evaluation model, such that any other action, as provided in 10 CFR 50.46(a)(3), has been taken to show compliance with 10 CFR 50.46 requirements, including those contained in 10 CFR 50.46(a)(1). Alternatively, submit a schedule for providing a reanalysis or taking other action as may be necessary to show compliance with 10 CFR 50.46 requirements.
Duke Energy Carolinas Response to NRC RAI Question I The evaluation that supports the 2012 10 CFR 50.46 LOCA Report for B&W Plants denotes other actions taken to show compliance with 10 CFR 50.46 requirements. The evaluation demonstrated the requirements of 10 CFR 50, Appendix K for a conservative model were fully met based on a reported estimated net zero change in peak clad temperature (PCT). The evaluation concluded the actual net PCT would decrease, therefore, the existing model results remain conservative and acceptable. As the reported net PCT did not change, local oxidation and whole core hydrogen generation from the original model are unaffected and remain in compliance. In addition, the coolable core geometry and long-term cooling impacts remain unchanged and fully meet 10 CFR 50.46(b) requirements. ECCS cooling performance was calculated with the errors corrected and this result comes from an acceptable evaluation model that complies with 10 CFR 50.46(a)(1)(i) and 50.46(a)(1)(ii). The analytical technique used approximates realistically the behavior of the reactor system during a loss-of-coolant accident. As such, there is a high level of probability that the criteria will not be exceeded.
In lieu of submitting a proposed schedule for providing a reanalysis, the actions already taken as described above are considered sufficient to satisfy the intent of 10 CFR 50.46(a)(3)(ii), specifically "or taking other action as may be needed to show compliance with § 50.46 requirements".