RA-22-0193, Subsequent License Renewal Application Response to ONS SLRA Second Round RAI B2.1.7-4b

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Subsequent License Renewal Application Response to ONS SLRA Second Round RAI B2.1.7-4b
ML22189A010
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 07/08/2022
From: Snider S
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML22189A008 List:
References
RA-22-0193
Download: ML22189A010 (14)
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Text

Steven M. Snider Vice President Oconee Nuclear Station Duke Energy ON01VP l 7800 Rochester Hwy Seneca, SC 29672 o: 864.873.3478 f: 864.873.5791 Steve.Snider @duke-energy.com, Attachment 1P of this letter contains proprietary information that is being withheld from public disclosure under 10 CFR 2.390. Upon separation from Enclosure 1 Attachments, this letter is decontrolled.

RA-22-0193 July 8, 2022 10 CFR 50.4 10 CFR Part 54 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Duke Energy Carolinas, LLC (Duke Energy)

Oconee Nuclear Station (ONS), Units 1, 2, and 3 Docket Numbers 50-269, 50-270, 50-287 Renewed License Numbers DPR-38, DPR-47, DPR-55 Subsequent License Renewal Application Response to ONS SLRA Second Round RAI B2.1.7-4b

References:

1.

Duke Energy Letter (RA-21-0132) dated June 7, 2021, Application for Subsequent Renewed Operating Licenses, (ADAMS Accession Number ML21158A193) 2.

NRC Letter dated July 22, 2021, Oconee Nuclear Station, Units 1, 2, and 3 - Determination of Acceptability and Sufficiency for Docketing, Proposed Review Schedule, and Opportunity for a Hearing Regarding Duke Energy Carolinas Application for Subsequent License Renewal (ADAMS Accession Number ML21194A245) 3.

NRC E-mail dated September 22, 2021, Oconee SLRA - Request for Additional Information B2.1.27-1 (ADAMS Accession Number ML21271A586) 4.

Duke Energy Letter (RA-21-0281) dated October 22, 2021, Subsequent License Renewal Application, Response to Request for Additional Information B2.1.27-1 (ADAMS Accession Number ML21295A035) 5.

NRC E-mail dated November 23, 2021, Oconee SLRA - Request for Additional Information - Set 1 and Second Round Request for Additional Information RAI B2.1.27-1a (ADAMS Accession Number ML21327A277) 6.

Duke Energy Letter (RA-21-0332) dated January 7, 2022, Subsequent License Renewal Application Responses to NRC Request for Additional Information Set 1 and Second Round Request for Additional Information B2.1.27-1a (ADAMS Accession Number ML22010A129) 7.

NRC E-mail dated January 11, 2022, Oconee SLRA - Request for Additional Information - Set 2 (ADAMS Accession Numbers ML22012A043 and ML22012A042) 8.

Duke Energy Letter (RA-22-0036) dated February 14, 2022, Subsequent License Renewal Application Responses to NRC Request for Additional Information Set 2 (ADAMS Accession Number ML22045A021) 9.

NRC E-mail dated January 18, 2022, Oconee SLRA - Request for Additional Information Set 3 (ADAMS Accession Numbers ML22019A103 and ML22019A104)

U.S. Nuclear Regulatory Commission July 8, 2022 Page 2

10. Duke Energy Letter (RA-22-0040) dated February 21, 2022, Subsequent License Renewal Application Responses to NRC Request for Additional Information Set 3 (ADAMS Accession Numbers ML22052A002)
11. NRC E-mail dated March 16, 2022, Oconee SLRA - Request for Additional Information Set 4 (ADAMS Accession Numbers ML22080A077)
12. NRC E-mail dated March 21, 2022, Oconee SLRA - 2nd Round RAI B4.1-3 (ADAMS Accession Numbers ML22081A005 and ML22081A006)
13. NRC E-mail dated March 29, 2022, Oconee SLRA - 2nd Round RAI 4.6.1-1a (ADAMS Accession Number ML22091A092)
14. Duke Energy Letter (RA-22-0111) dated March 31, 2022, Subsequent License Renewal Application Follow-up Request for Additional Information Set 2 and 3 Updates (ADAMS Accession Number ML22090A046)
15. Duke Energy Letter (RA-22-0129) dated April 20, 2022, Subsequent License Renewal Application Responses to Oconee SLRA - 2nd Round RAI B4.1-3 (ADAMS Accession Number ML22110A207)
16. NRC E-mail dated April 20, 2022, Oconee SLRA - Request for Additional Information 3.1.2-1 (ADAMS Accession Number ML22113A008 and ML22113A009)
17. Duke Energy Letter (RA-22-0124) dated April 22, 2022, Subsequent License Renewal Application Responses to NRC Request for Additional Information Set 4 (ADAMS Accession Numbers ML22112A016)
18. NRC E-mail dated April 28, 2022, Oconee SLRA - 2nd Round RAI B2.1.9-2a (ADAMS Accession Numbers ML22122A018 and ML22122A019)
19. Duke Energy Letter (RA-22-0137) dated May 20, 2022, Response to ONS SLRA Second Round RAI 4.6.1-1a (ADAMS Accession Number ML22140A016)
20. Duke Energy Letter (RA-22-0159) dated May 27, 2022, Response to ONS SLRA - Request for Additional Information 3.1.2-1 (ADAMS Accession Number ML22147A001)
21. NRC E-mail dated June 1, 2022, Oconee SLRA - 2nd Round RAI B2.1.7-4b (ADAMS Accession Number ML22154A214)
22. Duke Energy Letter (RA-22-0158) dated June 8, 2022, Response to ONS SLRA - 2nd Round Request for Additional Information B2.1.9-2a (ADAMS Accession Number ML22159A151)

By letter dated June 7, 2021 (Reference 1), Duke Energy Carolinas, LLC (Duke Energy) submitted an application for the subsequent license renewal of Renewed Facility Operating License Numbers DPR-38, DPR-47, and DPR-55 for the Oconee Nuclear Station (ONS), Units 1, 2, and 3 to the U.S. Nuclear Regulatory Commission (NRC). On July 22, 2021 (Reference 2), the NRC determined that ONS subsequent license renewal application (SLRA) was acceptable and sufficient for docketing. In emails from NRC to Steve Snider (Duke Energy) dated September 22, 2021, November 23, 2021, January 11, 2022, January 18, 2022, March 16, 2022, March 21, 2022, March 29, 2022, April 20, 2022, and April 28, 2022 (References 3, 5, 7, 9, 11, 12, 13, 16, and 18), the NRC transmitted specific requests for additional information (RAl) to support completion of the Safety Review. The responses were provided to the NRC on October 22, 2021, January 7, 2022, February 14, 2022, February 21, 2022, March 31, 2022, April 20, 2022, April 22, 2022, May 20, 2022, May 27, 2022, and June 8, 2022 (References 4, 6, 8, 10, 14, 15, 17, 19, 20, and 22).

In an email from Angela X. Wu (NRC) to Steve Snider (Duke Energy) dated June 1, 2022 (Reference 21), the NRC transmitted a second round for RAl B2.1.7-4b also to support completion of the Safety Review.

contains the responses for RAI B2.1.7-4b. Enclosure 1, Attachment 1P contains proprietary information. Enclosure 2 contains the affidavit for the proprietary information. As directed by

U.S. Nuclear Regulatory Commission July 8, 2022 Page 3 the NRC Project Manager, the revised due date for this response is July 8, 2022. This submittal contains no revisions to the commitment program in Table A6.0-1.

Since Enclosure 1 contains proprietary information, it is supported by an affidavit signed by the owner of the information (Enclosure 2). The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in 10 CFR 2.390(b)(4) and consistent with NRC Regulatory Issue Summary 2014-01, Regulatory Requirements for Withholding of Proprietary Information from Public Disclosure. Accordingly, it is respectfully requested that the proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390. A redacted, non-proprietary version is provided in Enclosure 1, Attachment 1.

Correspondence with respect to the copyright or proprietary aspects of the vendor information or affidavit should be addressed to the vendor representative identified in the affidavit.

Should you have any questions regarding this submittal, please contact Paul Guill at (704) 382-4753 or by email at paul.guill@duke-energy.com.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 8, 2022.

Sincerely, Steven M. Snider Site Vice President Oconee Nuclear Station

Enclosure:

1. Response to ONS SLRA Second Round RAI B2.1.7-4b Response To ONS SLRA Second Round RAI B2.1.7-4b - Non-Proprietary Version P Response To ONS SLRA Second Round RAI B2.1.7-4b - Proprietary Version
2. Framatome Affidavit

U.S. Nuclear Regulatory Commission July 8, 2022 Page 4 CC: W/O

Enclosures:

Laura A. Dudes Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 Angela X. Wu, Project manager (by electronic mail only)

U.S. Nuclear Regulatory Commission Mail Stop 11 G3 11555 Rockville Pike Rockville, Maryland 20852 Shawn A. Williams, Project Manager (by electronic mail only)

U.S. Nuclear Regulatory Commission Mail Stop 8 B1A 11555 Rockville Pike Rockville, Maryland 20852 Jared Nadel (by electronic mail only)

NRC Senior Resident Inspector Oconee Nuclear Station Anuradha Nair (by electronic mail only: naira@dhec.sc.gov)

Bureau Environmental Health Services Department of Health & Environmental Control 2600 Bull Street Columbia, South Carolina 29201

U.S. Nuclear Regulatory Commission July 8, 2022 Page 5 BCC: W/O

Enclosures:

T.P. Gillespie K. Henderson S.D. Capps T.M. Hamilton P.V. Fisk H.T. Grant S.A. Dalton M.C. Nolan L. Grzeck S.M. Snider R.K. Nader G.D. Robison T.M. LeRoy P.F. Guill R.V. Gambrell File: (Corporate)

Electronic Licensing Library (ELL)

ENCLOSURE 1 OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 SUBSEQUENT LICENSE RENEWAL APPLICATION RESPONSE TO ONS SLRA 2ND ROUND RAI B2.1.7-4b Attachment RAI Number 1

B2.1.7-4b - Non-proprietary Version 1P B2.1.7-4b - Proprietary Version

ENCLOSURE 1 OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 SUBSEQUENT LICENSE RENEWAL APPLICATION RESPONSE TO ONS SLRA 2ND ROUND RAI B2.1.7-4b ATTACHMENT 1

[NON-PROPRIETARY]

, Attachment 1 Response to ONS SLRA 2nd Round RAI B2.1.7-4b - Non-Proprietary Version

, Attachment 1 Response to ONS SLRA 2nd Round RAI B2.1.7-4b

[Non-Proprietary Version]

Note: Text that is within brackets is proprietary to Framatome, Inc.

Request for Additional Information (RAI) B2.1.7-4b:

Regulatory Basis:

Title 10 of the Code of Federal Regulations (CFR) Section 54.21(a)(3) requires an applicant to demonstrate that the effects of aging for each structure and component identified in 10 CFR 54.21(a)(1) will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. One of the findings that the U.S. Nuclear Regulatory Commission (NRC) staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under 10 CFR 54.21, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis.

Per 10 CFR 54.21(c), the applicant is required to evaluate time limited aging analyses (TLAA) and disposition them in accordance with (c)(1)(i), (c)(1)(ii), or (c)(1)(iii). SRP-SLR Section 4.6.1.1 states, in part: The ASME Code contains explicit requirements for fatigue parameter evaluations (fatigue analyses or fatigue waivers), which are TLAAs.

In order to complete its review and enable making a finding under 10 CFR 54.29(a), the staff requires additional information in regard to the matters described below.

Background:

In Section B2.1.7 of Oconee Nuclear Station (ONS) SLRA Appendix B, the applicant downgraded the EPRI MRP-227 based classification of the core barrel (CB) top cylinder-to-bottom cylinder circumferential seam welds, the CB top flange-to-top cylinder circumferential seams welds, and the CB bottom flange-to-bottom cylinder circumferential seam welds in Units 1 and 3 and the CB top cylinder and bottom cylinder axial seam welds in Units 1, 2 and 3 from being designated as Expansion category components of the program to No Additional Measures (NAM) category components of the program.

The applicants response to RAI B2.1.7-4 dated February 14, 2022 (ADAMS Accession No. ML22045A020) states that the CB cylinder axial seam welds and CB middle circumferential seam welds meet the dose and stress levels for susceptibility to both irradiation-assisted stress corrosion cracking (IASCC) and neutron irradiation embrittlement (IE). The response also identifies these welds as (( )) (ADAMS Accession No. ML20091K284). The RAI response further states that IASCC has been addressed for these welds, and it is justified and concluded these welds at all three Oconee Units are downgraded to No Additional Measures, however, no basis was provided for this statement.

The applicants response also states that the referenced CB weld types are ((

))

, Attachment 1 Response to ONS SLRA 2nd Round RAI B2.1.7-4b - Non-Proprietary Version In addition, the applicants response to RAI B2.1.7-4 states:

A cumulative usage factor (CUF) value for the Oconee Units 1, 2, and 3 core barrel was recently calculated. As a result of this calculation, fatigue is downgraded to No Additional Measures for the core barrel of all Oconee Units and IE has been addressed for the core barrel cylinder, and ((

)). Therefore, for Oconee Units 1 and 3, IE for the core barrel cylinder and top flange is considered No Additional Measures.

On May 17 and 18, 2022, the staff held a supplemental audit regarding the applicants basis for placing the referenced CB welds into the NAM category of the Reactor Vessel Internals Program and the applicants fatigue and SCC screening bases for the referenced CB welds. In preparation of the presentations and discussions made by the applicant to the staff during the supplemental audit of May 17 and 18, 2022, the applicant placed its supplemental fatigue analysis for the CB assemblies and welds onto the supplemental audit ePortal for the SLRA. The staff reviewed the adequacy of this fatigue screening document as part of its supplemental audit review activities.

In the supplemental fatigue analysis, the applicant calculated a bounding and limited cumulative usage factor (CUF) value of (( )) for the CB assemblies and welds; the calculation demonstrates the CUF value in the supplemental analysis is greater than the EPRI MRP

(( )) in MRP-189, Revision 3. But, as it has been explained in SLRA AMP B2.1.7 (on SLRA page B-66), the applicant determined that the EPRI MRPs

(( )) in MRP-189, Revision 3 was overly conservative and not applicable to the current licensing basis (CLB) for the ONS units. Consistent with this basis, on SLRA page B-66, the applicant indicates that it used an alternate fatigue screening criterion of 1.0 for the fatigue screening objectives of the reference CB assemblies and welds.

Issues:

As part of the discussion held with the applicant during the supplemental audit of May 17 and 18, 2022, the applicant indicated that the basis for use of an alternative fatigue screening value of 1.0 is given in the ASME Boiler and Pressure Vessel Code,Section III, Subsection NG (ASME III NG). However, based on its review of the CLB, the staff notes that the RVI core support structure components in the ONS units were not designed and evaluated to ASME III NG design rules because the ASME Section III version of record used for the plant design preceded the development of ASME III NG rules for PWR RVI core support structure components (which include CB assemblies and their welds). This is reflected on page B-66 of the SLRA and demonstrated by the fact that Sections 4.1 and 4.3 of the SLRA do not cite or include an ASME III NG design basis fatigue TLAA (CUF-based) for the RVI core support structure components in the units. Thus, other than the mention of this alternate fatigue screening criterion on page B-66 in the SLRA, the staff has no record of the applicants basis and justification of adopting an alternative AMSE III NG-based fatigue (CUF) screening criterion of 1.0 for the fatigue calculation that was performed for the CB assemblies and welds.

, Attachment 1 Response to ONS SLRA 2nd Round RAI B2.1.7-4b - Non-Proprietary Version Request:

Provide the basis for adopting an alternative AMSE III NG-based fatigue (CUF) screening criterion of 1.0 for the supplemental fatigue calculation that was performed for the CB assemblies and welds. As part of this basis, explain the use of this screening criterion of 1.0 when taken in light of the fact that ASME Section III NG design rules and criteria are not part of the CLB for the RVI core support structure components (including the CB assemblies) in the ONS units.

Response to RAI B2.1.7-4b:

Response to Request 1:

As described in the Oconee SLRA, Section B2.1.7, page B-66, preliminary screening for fatigue susceptibility was completed for SLR consistent with MRP-189, Revision 3. From this screening, the core barrel cylinder was found to be potentially susceptible to cracking by fatigue. As permitted by MRP-134, Revision 1, an engineering evaluation may be performed to refine the screening and categorization process results established in MRP-189, Revision 3. As such, an ASME Section III, Division I, 1998 Edition through 2001 Addenda, Subsection NB-3222, fatigue calculation of Oconee core barrel cylinder was performed. The guidance in NB-3222 is more detailed than in NG-3222, and therefore NB-3222 was used in the fatigue calculation. It should be noted that the fatigue calculation methodologies of NB-3222 and NG-3222, in particular NB-3222.4 and NG-3222.4, are essentially the same and yield the same results. The fatigue calculation demonstrated that the cumulative usage factor for the core barrel cylinder is less than 1.0. Based on this ASME Section III calculation, fatigue cracking is not an appliable aging effect for SLR, and fatigue as a degradation mechanism was downgraded to No Additional Measures for the Oconee Units 1, 2, and 3 core barrel cylinder for SLR.

The acceptance criterion of 1.0 is based on the ASME Section III code requirement specified in NB-3222.4, which states that the CUF shall not exceed 1.0. This is consistent with the equivalent criterion in ASME Section III, NG-3222.4. As discussed during the recent audit, Duke Energy did not utilize the MRP-175, Revision 1, CUFen screening criterion of (( ))d,e for the core barrel cylinder since it is based on the overly conservative assumption that design transients of all licensees will be doubled for 80 years of operation, which is not the case for Oconee as reported in the ONS SLRA, Section 4.3. In addition, the MRP-175 Revision 1 CUFen criterion includes a conservative factor of (( )) d,e adjustment for environmental effects, which need not be considered since the core support assembly is not a pressure retaining component; this is consistent with NUREG-2192.

As reported in the Oconee SLRA, Section B2.1.7, the Oconee reactor vessel internals were designed and constructed prior to the development of ASME Code requirements for core support structures. As such, fatigue cumulative usage factors were not calculated during original construction and are only available for a select number of replacement bolting items. The ASME Section III, Division I, fatigue evaluation of the Oconee core barrel cylinder reported above applied contemporary code design thinking to understand the potential for fatigue cracking. This evaluation provides the basis for determining that fatigue cracking of the core barrel cylinder need not be managed for the SPEO consistent with the requirements established in MRP-134, Revision 1, relative to engineering evaluation of potential damage mechanisms following initial screening and is permitted within the framework of MRP-227, Revision 1-A with the gap analysis, for SLR.

ENCLOSURE 2 OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 SUBSEQUENT LICENSE RENEWAL APPLICATION RESPONSE TO ONS SLRA 2ND ROUND RAI B2.1.7-4b FRAMATOME AFFIDAVIT

3

9.

The foregoing statements are true and correct to the best of my knowledge, information, and belief.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: July 6, 2022.

Digitally signed by ELLIOTT Gayle Date: 2022.07.06 15:32:55 -04'00' Gayle Elliott ELLIOTT Gayle

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