ML14364A028

Oconee, Units 1, 2 and 3, Revision to Tornado/Helb Mitigation Strategies and Regulatory Commitment 17T

ML14364A028
Person / Time
Site:	Oconee
Issue date:	12/19/2014
From:	Batson S Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ONS-2014-164
Download: ML14364A028 (7)

Text

Scott L. BatsonDUKE Vice President Oconee Nuclear StationENERGY Duke EnergyONO1VP I 7800 Rochester HwySeneca, SC 29672ONS-2014-164 o: 864.873.3274864.873.

4208Scott.Batson@duke-energy.com December 19, 2014Document Control DeskU.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Duke Energy Carolina, LLC (Duke Energy)Oconee Nuclear Station, Units 1, 2 and 3Docket Numbers 50-269, 50-270, 50-287Renewed License Numbers DPR-38, DPR-47, and DPR-55

Subject:

Revision to Tornado/HELB Mitigation Strategies and Regulatory Commitment 17T

References:

1. Duke Energy Letter, "Tornado/HELB Mitigation Strategies and Regulatory Commitments,"

dated November 30, 2006 ADAMS Accession No. ML070290328.

2. Duke Energy Letter, "License Amendment Request to Revise Portions of the Updated FinalSafety Analysis Report Related to the Tornado Licensing Basis; License Amendment Request No. 2006-009,"

dated June 26, 2008, ADAMS Accession No. ML081840371.

3. Duke Energy Letter, "Tornado and High Energy Line Break (HELB) Mitigation LicenseAmendment Requests (LARs)- Responses to Request for Additional Information,"

datedDecember 16, 2011, ADAMS Accession No. ML1 20030226.

4. Duke Energy Letter, "Revision to Tornado/HELB Mitigation Strategies and Regulatory Commitments 8T, lOT, 17T, and 25H," dated December 19, 2013.Duke Energy's initial commitments related to tornado mitigation strategies are documented in aNovember 30, 2006 submittal (Ref. 1). These commitments were most recently updated in a DukeEnergy submittal dated December 19, 2013 (Ref. 4). This letter is Duke Energy's notification of aneeded revision to Tornado Commitment 17T of the Reference 4 letter.This letter revises Tornado Commitment 17T, which is a modification to improve the protection fora set of double doors on the SSF. The commitment was to complete the modification byJanuary 31, 2015. A design was conceived, and specific design criteria was developed;

however, upon moving toward implementation the design was determined to be neither feasiblenor constructible.

Insufficient time remains to develop and implement a new design prior to thecommitted due date.A commitment change is necessary to allow time for the development of a new design strategy toprovide the necessary door protection.

The 17T commitment has been revised with a due date ofSeptember 30, 2015 to provide an implementation completion date for the new modification.

Therevision is indicated on Enclosure 1 of this letter, which is a complete list of tornado commitments.

In accordance with Tornado Commitment 1OT, Duke Energy has verbally notified Louise Lund,NRC Deputy Director, Division of Reactor Licensing of this commitment change via telephone onDecember 19, 2014. A olIwww.duke-energy.com

, &--

ONS-2014-164 Page 2Revision to Tornado Commitment 17TDecember 19, 2014Duke Energy remains resolved to complete the tornado mitigation commitments and values therisk benefit it will provide for the station.If you have any questions in regard to this letter, please contact Stephen C. Newman, OconeeNuclear Station, Regulatory Affairs Group at (864) 873-4388.

Sincerely, Scott BatsonVice President, Oconee Nuclear StationEnclosure

1. Revised Tornado Commitments ONS-2014-164 Page 3Revision to Tornado Commitment 17TDecember 19, 2014cc (w/enclosure):

Mr. Victor McCree, Regional Administrator U.S. Nuclear Regulatory Commission

-Region IIMarquis One Tower245 Peachtree Center Ave., NE Suite 1200Atlanta, Georgia 30303-1257 Mr. James R. Hall, Project Manager (ONS)(by electronic mail only)U.S. Nuclear Regulatory Commission 11555 Rockville PikeMail Stop O-8B1Rockville, MD 20852Mr. Eddy CroweNRC Senior Resident Inspector Oconee Nuclear StationMs. Susan Jenkins, ManagerRadioactive

& Infectious Waste Management Division of Waste Management South Carolina Department of Health and Environmental Control2600 Bull St.Columbia, SC 29201 Enclosure 1Revised Tornado Commitments www.duke-energy.com Enclosure 1 -Revised Tornado and HELB Regulatory Commitments December 19, 2014Page 1Cornplete No. Tornado Commitments Due Date(YIN)1T U3 Control Room North Wall Modification.

-Y2T SSF Diesel Fuel Vent Modification.

-Y3T SSF and CT-5 Trenches Intersection Modification SSF Trench at north -end of SSF (TORMIS).

4T Borated Water Storage Tank Modifications.

-Y5T West Penetration Room (WPR) and Cask Decontamination Tank Room -y(CDTR) Wall Modifications.

6T Fiber Reinforced Polymer (FRP) LAR for strengthening selected masonry -ywalls for tornado wind and AP.7T Tornado Mitigation Strategy LAR. -Y8T PSW/HPI modifications.

2-4-2016 N9T Missile inventory program developed.

YVerbally notify in advance the Deputy Director, Division of ReactorLicensing of the NRC, followed by a written communication, of significant 1OT changes in the scope and/or completion dates of the commitments.

The 2022 Nnotification will include the reason for the changes and the modifiedcommitments and/or schedule.

11T Installation of MSIVs. Ul: 202012T U2: 2021 N13T U3:202214T Fiber Reinforced Polymer (FRP) LAR for strengthening selected "brick" ymasonry walls for tornado wind and AP.Analyze the double column set which support each unit's Main Steam15T lines outside of the containment

building, and provide modifications, as -Ynecessary, to meet tornado criteriaPhysically protect the Atmospheric Dump Valve's (ADV's) function per Ul: 202016T RG 1.76, Rev. 1. U2: 2021 NU3: 2022Improve protection of the Standby Shutdown Facility (SSF) double doors(large 8'xl 2' doors located on the south side of the SSF structure) per17T UFSAR SSF tornado criteria.

By 9-30-2015, this commitment will be 9-30-2015 Nupdated to provide the completion date for implementing themodification.

Revise and clarify the tornado LB description as documented in UFSAR AfterSection 3.2.2; add the TORMIS methodology results to UFSAR Section issuance18T 3.5.1.3, and correct inaccurate tornado design information for the Auxiliary of the NBuilding Cable and Electrical Equipment Rooms as described in UFSAR SERTable 3-23. 1The SSF BASES for TS 3.10.1 will be clarified to address degradation of Afterpassive civil features as not applying to operability under Technical issuance19T Specifications Limiting Condition for Operation (TS LCO) 3.10.1, "Standby ofitheNShutdown Facility,"

but rather as UFSAR commitments outside of the SER.ONS TS.

Enclosure 1 -Revised Tornado and HELB Regulatory Commitments December 19, 2014Page 2No. Tornado Commitments Due Date Complete(YIN)Duke Energy will perform qualification testing and reporting in accordance 20T1 with ICC AC1 25 [Reference 5 of Enclosure 2] for the selected FRP -YSystem.Duke Energy will perform and document a technical evaluation of the FRPsystem (fibers and polymeric resin) in accordance with Duke Energy'sSupply Chain Directive SCD230 [Reference 7 of Enclosure 2] to21T demonstrate that: y1. The item qualifies as a commercial grade item.2. The supplier is capable of supplying a quality product.3. The quality of the item can be reasonably assured.Duke Energy will utilize technical procedures to control testing of concrete22T substrate and installation and inspection of the FRP system in accordance ywith ICC AC1 25 [Reference 5 of Enclosure 2], ACI 440.2R-02

[Reference 6 of Enclosure 2], and ICC AC1 78 [Reference 8 of Enclosure 2].Duke Energy will perform long-term inspection of the FRP system asdescribed in UFSAR Section 18.3.13 and EDM-410, and in accordance with ICC AC125 [Reference 5 of Enclosure 2], ACI 440.2R-02

[Reference 6 of Enclosure 2], and ICC AC1 78 [Reference 8 of Enclosure 2], on anominal 5 year interval.

This inspection frequency may be reduced to anominal 10 year interval with appropriate justification based on thestructure, environment, and previous long-term inspection results.23T Inspections of the installed FRP system will include:* visual inspections of test walls and selected portions of WPR walls forchanges in color, debonding,

peeling, blistering,

cracking, crazing,deflections and other anomalies; and,* tension adhesion testing of cored samples taken from test walls usingmethods specified in ASTM D4541 [Reference 9 of Enclosure 2] orACI 530R-02 [Reference 16 of Enclosure 2].Duke Energy will perform qualification testing and reporting in accordance 24T with ICC AC125 [Approved 10/2006, Effective 1/1/2007]

for the selected YFRP System.Duke Energy will perform and document a technical evaluation of the FRPsystem (fibers and polymeric resin) in accordance with Duke Energy'sSupply Chain Directive SCD230 [Reference 7 of Enclosure 2] to25T demonstrate that: y" The item qualifies as a commercial grade item." The supplier is capable of supplying a quality product.* The quality of the item can be reasonably assured.Duke Energy will utilize technical procedures to control testing of concretesubstrate and installation and inspection of the FRP system in accordance 26T with ICC AC125 [Approved 10/2006, Effective 1/1/2007],

ACI 440.2R-02 Y[Effective 7/1/2002],

and ICC AC1 78 [Approved 6/2003, Effective 7/1/2003, editorially revised 6/2008].1 Tornado commitments 20-23 originate from the FRP LAR dated 6-1-2006 (NRC SER dated 2-21-2008).

2 Tornado commitments 20-26 are addressed in the NRC's FRP SER for brick masonry dated 6-27-2011.

Enclosure 1 -Revised Tornado and HELB Regulatory Commitments December 19, 2014 Page 3No. Tornado Commitments Due Date C(YIN)Duke Energy will implement a long-term inspection program of the FRPsystem that will be described in UFSAR Section 18.3.13 and EDM-410,meet the requirements of ICC AC125 [Approved 10/2006, Effective 1/1/2007],

ACI 440.2R-02

[Effective 7/1/2002],

and ICC AC178 [Approved 6/2003, Effective 7/1/2003, editorially revised 6/2008],

on the following schedule:

at each unit's outage cycle for the first six years from 2012through 2017, then, if justified based on no observed FRP degradation, transition to every-other outage cycle for the next four years from 2018through 2021, then, if justified based on continued no observed FRPdegradation, transition to every third outage cycle thereafter from 2022until end of license in July 2034. Inspections of the installed FRP systemwill include:* visual inspections of test walls and portions (both randomand controlled locations) of WPR in-service walls forchanges in color, debonding,

peeling, blistering,

cracking, 27T

• crazing, deflections and other anomalies; 2 tension adhesion testing of cored samples taken fromdesignated test walls using methods specified in ASTMD7234; and,* visual inspections of mortar joints located along thebottom edge of FRP-strengthened masonry walls.For each inspection

interval, the portions of FRP-strengthened masonrywalls to be inspected will be chosen in accordance with a sampling plandeveloped from guidance provided by a) Draft Regulatory Guide DG-1070, "Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for use in Nuclear Power Plants",

and b) EPRI NP-7218document "Guidelines for the Utilization of Sampling Plans for Commercial Grade Item Acceptance" (NCIG-19),

as implemented at ONS by SupplyChain Directive SCD-290 [(new) Reference 21 of Enclosure 2].Note: This response replaces the five (5) year inspection commitment made in FRP LAR (No. 2009-05) dated June 29, 2009, and will apply tothe FRP application for both block and brick.Duke Energy will install mechanical shear restraints along the brick28T masonry wall perimeter (top and sides only) and block masonry wall yperimeter (top only) to remediate potentially limiting conditions ofconstruction.

Duke Energy will incorporate the FRP testing and inspection program into29T Oconee Nuclear Station's Aging Management Program.As discussed with the Staff, Fyfe Company, LLC, the manufacturer of the30T FRP products, will provide Duke Energy with a Certificate of Compliance ycertifying that both the FRP product and its installation meet all applicable requirements.