DU KE SCOTT L. ENERGY, Oconee Nuclear Station VP / 7800 … · 2017. 6. 15. · DU KE SCOTT L. BATSON ENERGY, Vice President Oconee Nuclear Station Duke Energy ONO I VP / 7800 Rochester

DU KE SCOTT L. BATSONVice President

ENERGY, Oconee Nuclear Station

Duke EnergyONO I VP / 7800 Rochester HwySeneca, SC 29672

864-873-3274ONS-2013-035 864-873-4208 fax

[email protected]

December 19, 2013

Document Control DeskU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001

Subject: Duke Energy Carolinas, LLCOconee Nuclear Station, Units 1, 2, and 3Docket Numbers 50-269, 50-270, and 50-287,Renewed Operating Licenses DPR-38, DPR-47, and DPR-55Revision to Tornado/HELB Mitigation Strategies and Regulatory Commitments8T, 10T, 17T, and 25H

References:

1. NRC Letter from Henry B. Barron (Duke Power Company, LLC), "Tornado/HELBMitigation Strategies and Regulatory Commitments," dated November 30, 2006.

2. NRC letter from Scott L. Batson (Duke Energy Carolinas, LLC) "Revision toTornado Mitigation Strategy Regulatory Commitments 1 1T, 12T, 13T, and 16T,"dated July 1,2013.

3. NRC letter to Duke Energy Carolinas, LLC, "Notice of Violation and ConfirmatoryOrder Related to a Fire Protection Program License Condition (Oconee NuclearStation Units 1, 2, and 3)," dated July 1,2013.

This letter documents Duke Energy Carolinas, LLC (Duke Energy) notification to theNuclear Regulatory Commission (NRC) of a revision to the tornado and High Energy LineBreak (HELB) mitigation strategy commitments (Ref. 1). The Enclosure to this lettercontains two (2) tables showing the complete list of tornado and HELB commitments madeto the Staff and last revised on July 1, 2013 (Ref. 2).

The revised implementation schedule includes revisions to tornado commitments 8T and17T. Commitment 8T is the completion of the Protected Service Water (PSW) system thatwas changed from July 1, 2013, to February 4, 2016, to coincide with the date given in aNRC Notice of Violation and Confirmatory Order (Ref. 3). Commitment 17T improves theprotection of the Standby Shutdown Facility (SSF) double doors to comply with UFSARSSF tornado criteria. Due to the lead time required to design and construct the new SSFtornado missile shield door and the unanticipated diversion of resources to work onemergent work, this commitment was changed to January 31, 2015.

Additionally, Commitments 1OT and 25H, which require that the NRC Deputy Director,Division of Reactor Licensing be notified of significant changes in the scope and/orcompletion dates of the commitments, were changed to coincide with the longest leadcommitment item contained in the tables. These are ongoing commitments that will be in

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U. S. Nuclear Regulatory CommissionDecember 19, 2013Page 2

place until 2022. By phone, the basis for this change was discussed with the Staff onDecember 17, 2013.

Duke Energy remains committed to the completion of these projects and recognizes itscontribution to resolution of outstanding tornado, HELB, and fire protection regulatoryissues as well as its significant positive impact on the station's probabilistic riskassessment margin. As such, the project team's goal is to complete the PSW project assoon as reasonably achievable. In no case will safety or quality be compromised for thesake of schedule.

If you have any questions in regard to this letter, please contact Stephen C. Newman,Oconee Nuclear Station, Regulatory Affairs Group at (864) 873-4388.

Sincerely,

Scott BatsonVice President,Oconee Nuclear Station

Enclosure

U. S. Nuclear Regulatory CommissionDecember 19, 2013Page 3

cc (w/enclosure):

Mr. Victor McCree, Regional AdministratorU. S. Nuclear Regulatory Commission - Region IIMarquis One Tower245 Peachtree Center Ave., NE, Suite 1200Atlanta, GA 30303-1257

Mr. Richard Guzman, Senior Project Manager(By electronic mail only)U. S. Nuclear Regulatory CommissionOffice of Nuclear Reactor Regulation11555 Rockville PikeRockville, MD 20852

Mr. Eddy CroweNRC Senior Resident InspectorOconee Nuclear Site

Ms. Susan Jenkins, ManagerRadioactive & Infectious Waste ManagementDivision of Waste ManagementSouth Carolina Department of Health and Environmental Control2600 Bull St.Columbia, SC 29201

Enclosure

Revised Tornado and HELB Regulatory Commitments

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Enclosure - Revised Tornado and HELB Regulatory CommitmentsDecember 19, 2013 Page 1

CompleteNo. Tornado Commitments Due Date Cmlt

(YIN)

1T U3 Control Room North Wall Modification. - Y

2T SSF Diesel Fuel Vent Modification. - Y

3T SSF and CT-5 Trenches Intersection Modification SSF - YTrench at north end of SSF (TORMIS).

4T Borated Water Storage Tank Modifications. - Y

5T West Penetration Room (WPR) and Cask Decontamination - YTank Room (CDTR) Wall Modifications.

6T Fiber Reinforced Polymer (FRP) LAR for strengthening - Yselected masonry walls for tornado wind and AP.

7T Tornado Mitigation Strategy LAR. - Y

8T PSW/HPI modifications. 2-4-2016 N

9T Missile inventory program developed. Y

10T Verbally notify in advance the Deputy Director, Division of 2022 NReactor Licensing of the NRC, followed by a writtencommunication, of significant changes in the scope and/orcompletion dates of the commitments. The notification willinclude the reason for the changes and the modifiedcommitments and/or schedule.

11T Installation of MSIVs. Ul: 2020 N

12T U2: 2021

13T U3:2022

14T Fiber Reinforced Polymer (FRP) LAR for strengthening Yselected "brick" masonry walls for tornado wind and AP.

15T Analyze the double column set which support each unit's YMain Steam lines outside of the containment building, andprovide modifications, as necessary, to meet tornadocriteria

16T Physically protect the Atmospheric Dump Valve's (ADV's) UI: 2020 Nfunction per RG 1.76, Rev. 1. U2: 2021

U3: 2022

17T Improve protection of the Standby Shutdown Facility (SSF) 1-31-2015 Ndouble doors (large 8'x12' doors located on the south sideof the SSF structure) per UFSAR SSF tornado criteria.

18T Revise and clarify the tornado LB description as After issuance of Ndocumented in UFSAR Section 3.2.2; add the TORMIS the SER.methodology results to UFSAR Section 3.5.1.3, and correctinaccurate tornado design information for the AuxiliaryBuilding Cable and Electrical Equipment Rooms asdescribed in UFSAR Table 3-23.


No. Tornado Commitments

19T The SSF BASES for TS 3.10.1 will be clarified to addressdegradation of passive civil features as not applying tooperability under Technical Specifications LimitingCondition for Operation (TS LCO) 3.10.1, "StandbyShutdown Facility," but rather as UFSAR commitmentsoutside of the ONS TS.

20T1 Duke Energy will perform qualification testing and reportingin accordance with ICC AC1 25 [Reference 5 of Enclosure2] for the selected FRP System.

21T Duke Energy will perform and document a technicalevaluation of the FRP system (fibers and polymeric resin)in accordance with Duke Energy's Supply Chain DirectiveSCD230 [Reference 7 of Enclosure 2] to demonstrate that:

1. The item qualifies as a commercial grade item.

2. The supplier is capable of supplying a qualityproduct.

3. The quality of the item can be reasonably assured.

22T Duke Energy will utilize technical procedures to controltesting of concrete substrate and installation and inspectionof the FRP system in accordance with ICC AC125[Reference 5 of Enclosure 21, ACI 440.2R-02 [Reference 6of Enclosure 2], and ICC AC1 78 [Reference 8 of Enclosure2].

23T Duke Energy will perform long-term inspection of the FRPsystem as described in UFSAR Section 18.3.13 and EDM-410, and in accordance with ICC AC1 25 [Reference 5 ofEnclosure 2], ACI 440.2R-02 [Reference 6 of Enclosure 2],and ICC AC178 [Reference 8 of Enclosure 2], on a nominal5 year interval. This inspection frequency may be reducedto a nominal 10 year interval with appropriate justificationbased on the structure, environment, and previous long-term inspection results. Inspections of the installed FRPsystem will include:

* visual inspections of test walls and selected portions ofWPR walls for changes in color, debonding, peeling,blistering, cracking, crazing, deflections and otheranomalies; and,

* tension adhesion testing of cored samples taken fromtest walls using methods specified in ASTM D4541[Reference 9 of Enclosure 2] or ACI 530R-02[Reference 16 of Enclosure 2].

Y

24T 2 Duke Energy will perform qualification testing and reporting Yin accordance with ICC AC125 [Approved 10/2006,Effective 1/1/2007] for the selected FRP System.

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.


No. Tornado Commitments Due Date Complete(Y/N)

25T Duke Energy will perform and document a technical Yevaluation of the FRP system (fibers and polymeric resin)in accordance with Duke Energy's Supply Chain DirectiveSCD230 [Reference 7 of Enclosure 2] to demonstrate that:

* 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.

26T Duke Energy will utilize technical procedures to control Ytesting of concrete substrate and installation and inspectionof the FRP system in accordance with ICC ACl 25[Approved 10/2006, Effective 1/1/2007], ACI 440.2R-02[Effective 7/1/2002], and ICC AC1 78 [Approved 6/2003,Effective 7/1/2003, editorially revised 6/2008].


No. Tornado Commitments Due Date Complete(Y/N)

27T Duke Energy will implement a long-term inspection Yprogram of the FRP system that will be described inUFSAR Section 18.3.13 and EDM-410, meet therequirements of ICC AC1 25 [Approved 10/2006, Effective1/11/2007], ACI 440.2R-02 [Effective 7/1/2002], and ICCAC1 78 [Approved 6/2003, Effective 7/1/2003, editoriallyrevised 6/2008], on the following schedule: at each unit'soutage cycle for the first six years from 2012 through 2017,then, if justified based on no observed FRP degradation,transition to every-other outage cycle for the next fouryears from 2018 through 2021, then, if justified based oncontinued no observed FRP degradation, transition toevery third outage cycle thereafter from 2022 until end oflicense in July 2034. Inspections of the installed FRPsystem will include:

* visual inspections of test walls and portions(both random and controlled locations) ofWPR in-service walls for changes in color,debonding, peeling, blistering, cracking,crazing, deflections and other anomalies;

" tension adhesion testing of cored samplestaken from designated test walls usingmethods specified in ASTM D7234; and,

* visual inspections of mortar joints locatedalong the bottom edge of FRP-strengthened masonry walls.

For each inspection interval, the portions of FRP-strengthened masonry walls to be inspected will be chosenin accordance with a sampling plan developed fromguidance provided by a) Draft Regulatory Guide DG-1 070,"Sampling Plans Used for Dedicating Simple MetallicCommercial Grade Items for use in Nuclear Power Plants",and b) EPRI NP-7218 document "Guidelines for theUtilization of Sampling Plans for Commercial Grade ItemAcceptance" (NCIG-19), as implemented at ONS by SupplyChain Directive SCD-290 [(new) Reference 21 of Enclosure2].Note: This response replaces the five (5) year inspectioncommitment made in FRP LAR (No. 2009-05) dated June29, 2009, and will apply to the FRP application for bothblock and brick.

28T Duke Energy will install mechanical shear restraints along Ythe brick masonry wall perimeter (top and sides only) andblock masonry wall perimeter (top only) to remediatepotentially limiting conditions of construction.

29T Duke Energy will incorporate the FRP testing and Yinspection program into Oconee Nuclear Station's AgingManagement Program.


No. Tornado Commitments Due Date Complete(YIN)

30T As discussed with the Staff, Fyfe Company, LLC, the Ymanufacturer of the FRP products, will provide DukeEnergy with a Certificate of Compliance certifying that boththe FRP product and its installation meet all applicablerequirements.

No. HELB Commitments Due Date Complete(YIN)

1 H Implement an inspection program for the Aux Bldg MS and - YFW girth and accessible attachment welds.

2H Implement an inspection program for other Aux. Bldg high - Yenergy piping critical crack locations at welds.

3H Initial ASME Section Xl ISI interval UT of the Aux. Bldg MS - Yand FW girth welds and accessible attachment welds.

4H Initial ASME Section XI ISI interval UT of other Aux. Bldg - Yhigh energy piping critical crack locations at welds.

5H Implement an inspection program for accessible piping - Ybase metal downstream of the FW isolation valves locatedin the EPR.

6H Implement an inspection program for accessible piping - Ybase metal of other Aux. Bldg high energy piping criticalcrack locations not at welds.

7H Initial ASME Section Xl ISI interval UT inspection of piping - Ybase metal downstream of FW isolation valves located inthe EPR.

8H Initial ASME Section XI ISI interval UT inspection for Yaccessible piping base metal of other Aux. Bldg highenergy piping critical crack locations not at welds.

9H Implement an inspection program of accessible attachment - Ywelds at the terminal ends inside the FW guard pipe.

10H Initial visual inspections of accessible attachment welds at - Ythe terminal ends inside the FW guard pipe.

11H Inspect and repair the Unit 2 East Penetration Room Yelectrical penetration termination enclosures to their correctconfiguration. Missing and/or damaged covers, gaskets,and fasteners will be repaired or replaced.



CompleteNo. Tornado Commitments Due Date Cmlt

(Y/N)


14H Create an inspection plan to select a portion of Units 1, 2 - Yand 3 enclosures to open and inspect for signs of internaldebris and corrosion.

15H Revise station procedures and processes as needed to - Yensure penetration termination enclosures are maintainedin their correct configurations.

16H Complete the design and installation of flood outlet devices - Yfor the Unit 1 East Penetration Room.



19H Complete the design and installation of flood impoundment - Yand exterior door flood improvement features for the Unit 1East Penetration Room

20H Complete the design and installation of flood impoundment - Yand exterior door flood improvement features for the Unit 2East Penetration Room.

21 H Complete the design and installation of flood impoundment - Yand exterior door flood improvement features for the Unit 3East Penetration Room.

22H HELB LB and Mitigation Strategy LARs. Y

23H

24H

25H Verbally notify in advance the Deputy Director, Division of 2022 NReactor Licensing of the NRC, followed by a writtencommunication, of significant changes in the scope and/orcompletion dates of the commitments. The notification willinclude the reason for the changes and the modifiedcommitments and/or schedule.

26H The inlet isolation valves to the Letdown Coolers on the To be provided to NLetdown Line (1 HP-1 & 1 HP-2) will be upgraded to permit the Staff upontheir use following a postulated HELB on the Letdown Line issuance of theat Containment Penetration No. 6. With these valves SER.upgraded, either could then be closed if either of theinboard containment isolation valves (1 HP-3 & 1 HP-4) failsto close in order to mitigate the postulated HELB on theLetdown line.


CompleteNo. Tornado Commitments Due Date (YIN)

(YIN)

27H The ducting near the Control Complex is being upgraded To be provided to Nwith duct registers or cover plates to prevent the potential the Staff uponpropagation of the HELB generated environment in the issuance of theEast Penetration Room to the Control Complex. SER.

28H The valves (1 HP-103 & 1HP-107) on the individual suction - Ylines to the "A" & "B" High Pressure Injection (HPI) pumpsare being upgraded to allow the remote operation(operated outside the HPI pump room) of these valves.The remote operation of these valves allow the isolation ofpostulated HELBs on the discharge side of the HPI Pumpswithout compromising the availability of the other HPIPumps and the need for maintaining the Letdown StorageTank aligned to the HPI Pump suction piping. For a singleactive failure of either valve 1 HP-103 or 1 HP-107 to close,a redundant, remotely operated valve is provided on eachof the HPI Pumps "A" and "B" to assure HELB mitigation.

29H The position of several Plant Heating System isolation Yvalves is being changed from "OPEN" to "CLOSED." Thisposition change will eliminate the need to postulate PlantHeating System HELBs in the East Penetration Room andWest Penetration Room, because these piping lines willisolated during normal plant conditions of the station.

30H Turbine Building structural support column D-26 will be To be provided to Nmodified by adding a brace to the column. This brace is the Staff uponnecessary to prevent potential failure of the column, when issuance of thesubjected to a pipe whip load. This upgrade prevents the SER.loss of the routing to get temporary cabling to the LowPressure Injection and Low Pressure Service Water pumpmotors.

31 H The existing Condenser Circulating Water (CCW) To be provided to Ndischarge stop gates will be replaced and four (4) new stop the Staff upongates will be obtained. These stop gates will be used to issuance of theterminate all reverse flow through HELB damaged Low SER.Pressure Service Water and CCW piping. Thismodification is required, in order to recover from a TurbineBuilding flood event caused by a postulated HELB therein.

32H Evaluate the ability of the Standby Shutdown Facility to Yperform its safety functions with a compromised mainsteam pressure boundary due to potential breaks in themain steam system and other HELBs.

33H Weep holes will be installed in the bottom of the outside- Ycontainment junction box enclosures for the VikingElectrical Penetrations. Also, the electrical penetrationinspection procedure is being amended to inspect the weepholes for blockage


No. Tornado Commitments Due Date Complete(YIN)

34H The inlet isolation valves to the Letdown Coolers on the To be provided to NLetdown Line (2HP-1 & 2HP-2) will be upgraded to permit the Staff upontheir use following a postulated HELB on the Letdown Line issuance of theat Containment Penetration No. 6. With these valves SER.upgraded, either could then be closed if either of theinboard containment isolation valves (2HP-3 & 2HP-4) failsto close in order to mitigate the postulated HELB on theLetdown line.

35H The Unit 2 HVAC ducting near the Control Complex is To be provided to Nbeing upgraded with duct registers or cover plates to the Staff uponprevent the potential propagation of the HELB generated issuance of theenvironment in the East Penetration Room to the Control SER.Complex.

36H The valves (2HP-103 & 2HP-107) on the individual suction To be provided to Nlines to the "A" & "B" High Pressure Injection (HPI) pumps the Staff uponare being upgraded to allow the remote operation issuance of the(operated outside the HPI pump room) of these valves. SER.The remote operation of these valves allow the isolation ofpostulated HELBs on the discharge side of the HPI pumpswithout compromising the availability of the other HPIPumps and the need for maintain the Letdown StorageTank aligned to the HPI Pump suction piping. For a singleactive failure of either valves 2HP-1 03 or 2HP-1 07 to close,a redundant, remotely operated valves is provided on eachof the HPI Pumps "A" and "B" to assure HELB mitigation.

37H The position of several Unit 2 Plant Heating System Yisolation valves is being changed from "OPEN" to"CLOSED." This position change will eliminate the need topostulate Plant Heating System HELBs in the EastPenetration Room and West Penetration Room, becausethese piping lines will be isolated during normal plantconditions of the station.

38H Turbine Building structural support Column D-29 & D-31 To be provided to Nwill be modified by adding a brace to the column. This the Staff uponbrace is necessary to prevent potential failure of the issuance of thecolumn, when subjected to a pipe whip load. SER.

39H Weep holes will be installed in the bottom of the Unit 2 Youtside-containment junction box enclosures for the VikingElectrical Penetrations. Also, the electrical penetrationinspection procedure is being amended to inspect the weepholes for blockage.

40H The inlet isolation valves to the Letdown Coolers on the To be provided to NLetdown Line (3HP-1 and 3HP-2) will be upgraded to the Staff uponpermit their use following a postulated HELB on the issuance of theLetdown Line at Containment Penetration No. 6. With SER.these valves upgraded, either could then be closed if eitherof the inboard containment isolation valves (3HP-3 and3HP-4) fails to close in order to mitigate the postulatedHELB on the Letdown Line.


CompleteNo. Tornado Commitments Due Date (Y/N)

(YIN)

41 H The Unit 3 Auxiliary Building HVAC ducting near the Unit 3 To be provided to NControl Complex is being upgraded with duct registers or the Staff uponcover plates to prevent the potential propagation of the issuance of theHELB generated environment in the East Penetration SER.Room to the Unit 3 Control Complex.

42H The valves (3HP-103 and 3HP-107) on the individual Ysuction lines to the "A" and "B" High Pressure Injection(HPI) pumps are being upgraded to allow the remoteoperation (operated outside the HPI pump room) of thesevalves. The remote operation of these valves allow theisolation of postulated HELBs on the discharge side of theHPI Pumps without compromising the availability of theother HPI Pumps and the need for maintaining the LetdownStorage Tank aligned to the HPI Pump suction piping. Fora single active failure of either valve 3HP-103 or 3HP-107to close, a redundant, remotely operated valve is providedon each of the HPI Pumps "A" and "B" to assure HELBmitigation.

43H The position of the Unit 3 Plant Heating System isolation Yvalve 3AS-182 being changed from "OPEN" to "CLOSED."This position change will eliminate the need to postulatePlant Heating System HELBs in the East Penetration Roomand West Penetration Room, because these piping lineswill be isolated during Normal Plant Conditions of thestation.

44H Turbine Building structural support columns M-20 (Unit 1), To be provided to NM-35 (Unit 2), D-43 and D-45 (Unit 3), M-49 (Unit 3), and L- the Staff upon47 (Unit 3) will be modified by adding a brace or issuance of thereinforcement to each column. These modifications are SER.necessary to prevent potential failure of the column(s),when subjected to a pipe whip load.

45H Weep holes will be installed in the bottom of the Unit 3 Youtside-containment junction box enclosures for the VikingElectrical Penetrations. Also, the electrical penetrationinspection procedure is being amended to inspect the weepholes for blockage.

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DU KE SCOTT L. ENERGY, Oconee Nuclear Station VP / 7800 … · 2017. 6. 15. · DU KE SCOTT L. BATSON ENERGY, Vice President Oconee Nuclear Station Duke Energy ONO I VP / 7800 Rochester