ML12340A073

McGuire Nuclear Station, Units 1 and 2, Response to Request for Additional Information Regarding License Amendment Related to Revising Technical Specification 3.7.7, Nuclear Service Water System (TAC ME8118 and ME8119)

ML12340A073
Person / Time
Site:	McGuire, Mcguire
Issue date:	11/13/2012
From:	Capps S D Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML12340A073 (14)

Text

Duke.~Energy,STEVEN D CAPPSVice PresidentMcGuire Nuclear StationDuke EnergyMG01 VP I 12700 Hagers Ferry Rd.Huntersville, NC 28078980-875-4805980-875-4809 faxSteven. Capps@duke-energy. cornNovember 13, 201210 CFR 50.90U.S. Nuclear Regulatory CommissionWashington, D.C. 20555-0001ATTENTION: Document Control DeskSUBJECT:Duke Energy Carolinas, LLC (Duke Energy)McGuire Nuclear Station, Units 1 and 2Docket Nos. 50-369 and 50-370Response to Request for Additional Information Regarding License AmendmentRelated to Revising Technical Specification 3.7.7, "Nuclear Service WaterSystem" (TAC Nos. ME8118 and ME8119)By letter dated February 22, 2012 Duke Energy requested a license amendment to revise theMcGuire Nuclear Station (MNS) Technical Specifications (TS) for Limiting Condition forOperation (LCO) 3.7.7, "Nuclear Service Water System" (NSWS). The License AmendmentRequest (LAR) will allow the use of the NSWS Pump discharge crossover valves andassociated piping to cross tie Unit 1 and 2 NSWS Trains to mitigate a Loss of Service Water(LOSW) event at MNS Units 1 or 2.By letter dated September 24, 2012 Nuclear Regulatory Commission (NRC) staff requestedadditional information needed to complete their review of the proposed LAR. The encloseddocument provides Duke Energy's responses and contains no regulatory commitments.Pursuant to 10 CFR 50.91, a copy of this LAR is being sent to the designated officials of theState of North Carolina.If there are any questions or if additional information is needed, please contact Mr. R. E. Abbottat (980) 875-4685.Sino relySteven .Cap(Enclosureýtoý_ji(wdw. duke-energy corn U.S. Nuclear Regulatory CommissionNovember 13, 2012Page 2xc: with enclosure:V. M. McCreeRegional Administrator, Region IIU.S. Nuclear Regulatory CommissionMarquis One Tower245 Peachtree Center Ave., NE Suite 1200Atlanta, .GA 30303-1257J. ZeilerNRC Senior Resident InspectorMcGuire Nuclear StationJ. H. Thompson (addressee only)NRC Senior Project Manager (McGuire)U.S. Nuclear Regulatory CommissionMail Stop 0-8 G9AWashington, DC 20555-0001W. L. Cox III, Section ChiefNorth Carolina Department of Environment and Natural ResourcesDivision of Environmental HealthRadiation Protection Section1645 Mail Service CenterRaleigh, NC 27699-1645 U.S. Nuclear Regulatory CommissionNovember 13, 2012Page 3Steven D. Capps affirms that he is the person who subscribed his name to the foregoingstatement, and that all the matters and facts set forth herein are true and correct to the best ofhis knowledge.Steven D. Capps,\ resident, McGuire Nuclear StationSubscribed and sworn to me:r)OL/Mb '/ ]ý, 701DatDate6fmuiýrNotary Public(9My commission expires: bateI-'/

ENCLOSUREResponses to Request for Additional InformationSubject: License Amendment Request to Revise Technical Specification 3.7.7, "NuclearService Water System" dated February 22, 2012.NRC Request for Additional Information:1. The licensee stated in the LAR that one train of the shared Service Water (SW) system inthe operable Unit would be used to supply the SW system of the affected Unitexperiencing a Loss of Service Water (LOSW) event. The licensee also stated thatabnormal procedures will limit the flow rate from the shared SW train during a LOSWevent to the surplus capacity existing after adequate cooling capacity is retained tosupport the availability of the train's dedicated Unit Emergency Diesel Generator (EDG)and long-term operation of the shared NSWS pump. The LAR does not describe howmuch flow is needed from one SW train to support the operation of the shared Unit EDGand NSWS pump throughout the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time as indicated in Condition A ofTS 3.7.7. The LAR also does not describe how the procedures will monitor the shared SWtrain flow into the affected Unit.The NRC staff requests for the licensee to provide additional information on:a. How much SW flow is needed to supply the EDG and NSWS pump in the sharing unitand how much surplus capacity of the remaining SW flow will be available for the unitexperiencing the LOSW event?Response:Net positive suction head (NPSH) calculations show each Nuclear Service WaterSystem (NSWS) pump is capable of delivering at least 14,000 gallons per minute (gpm).The minimum required flow to the EDG and NSWS pump is 750 gpm. An additional flowrequirement is backwash supply, which requires 400 gpm minimum, for total nuclearservice water (NSW) flow required for the sharing unit of 1,150 gpm. The currentanalysis assumes that 2000 gpm is maintained on the sharing unit leaving a minimum of12,000 gpm surplus capacity available for the unit experiencing the LOSW event.1

b. How the unit experiencing the LOSW event will utilize the shared SW to mitigate theLOSW event over the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time period?Response:Cooling water will be supplied to critical components needed to support LOSW unitshutdown. Cooling water may also be supplied to the Reactor Building to supportReactor Coolant Pump operation and Reactor Building Ventilation.c. How the operators will utilize abnormal procedures to monitor the SW flow from thesharing unit to the affected Unit over the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time period? In addition, explainwhether these abnormal procedures will be developed specifically for this alignment.(SBPB 1)Response:Operators will control the evolution by maintaining the shared NSW Pump total flow rateless than 14,000 gpm and aligning valves as necessary to ensure flow is onlymaintained to critical components on the sharing train. Specific abnormal procedure(AP) guidance will be developed for supplying cooling water from one unit to the other.Operators on the sharing unit will monitor NSW flow throughout the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time periodusing flow instruments currently installed in the Control Room.NRC Request for Additional Information:2. The licensee is requesting to revise TS 3.7.7, "Limiting Condition of Operations", Condition Aby adding a Note, "A NSWS train may be shared with another unit to mitigate a LOSWevent." The licensee stated that the placement of the Note in TS 3.7.7 Condition A restrictsthe exception to the activities allowed in TS 3.0.2 LCO Bases and to a LOSW event. Thelicensee also stated in the LAR that the location of the Note also limits the shared alignmentto 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> consistent with the Completion Time (CT) established for an inoperable NSWSsystem I train per unit.However, the staff considers the proposed Note as written in the TS markup pages couldpossibly allow subsequent entries into Condition A of TS 3.7.7 after the initial 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> timeperiod has elapsed. Multiple entries into Condition A of TS 3.7.7 could negatively impact theinventory needed to support the SW system for the sharing unit.The NRC staff requests that the licensee reassess and provide justification that the proposedNote for Condition A prevents multiple entries into TS 3.7.7 for the sharing unit after the initial72 hours of a LOSW event. (SBPB 2)Response:McGuire's Technical Specifications were converted to NUREG-1431, "StandardTechnical Specifications -Westinghouse Plants" (STS), Revision 1, dated April 1995 andapproved by the NRC September 30, 1998 (TAC # M98964 and M98965). Consistentwith the NUREG, the proposed note for Condition A conforms to the use and applicationof TS 1.3 Completion Times (CT). With respect to the use of Notes, McGuire's TS 1.3states, in part, "If this method of modifying how the Completion Time is tracked was2 applicable only to a specific Condition, the Note would appear in that Condition ratherthan at the top of the ACTIONS Table." Accordingly, proposed LAR located the Note inCondition A to limit the use of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> CT to a LOSW Event.The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time (CT) is the amount of time allowed for completing aRequired Action and is referenced to the time of the inoperable condition. TS 1.3 requirethat Action Conditions remain in effect and the Required Action continue to apply untilthe condition no longer exists or the unit is not within the LCO Applicability. Therefore, ifthe LOSW event is not mitigated at or before 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the shared train must be restoredto OPERABLE or the unit must enter Condition B and brought to Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> andMode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. As stated in the proposed LAR, "Condition A allows operation withone OPERABLE NSWS Train for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before action to restore the inoperabletrain to operable must be complete or unit shutdown is required." The LAR proposedRequired Action (A2), "Restore the NSWS Pump Discharge Crossover Valves to theclosed position" and the associated bases stated, in part, "Required Action A.2 ensuresthe Pump Discharge Crossover Valves are restored to the normal alignment within 72hours; thus, restoring compliance to GDC-5 and Condition A." Based on McGuire TSsand Duke Energy's understanding of NUREG-1431, the placement of the Note wasappropriate.With respect to multiple TS entries, McGuire's TS 3.0.2 and associated Bases requirethat intentional use of TS ACTIONS must be done in a manner that does notcompromise safety. Multiple entries into Condition A of TS 3.7.7 that could negativelyimpact the inventory needed to support the SW system would not be allowed if it wouldcompromise safety.NRC Request for Additional Information:3. The licensee stated in the LAR that the NSWS pump discharge header crossover manualvalves are normally closed and that the valves can be aligned to use one of two availableNSWS trains to the unit experiencing a LOSW event. The LAR does not describe how long itwill take for operators to utilize this alignment after a LOSW event occurs and what otheractions will be needed throughout the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period.The staff requests that the licensee describe the crosstie alignment process, as far as how longit will take for operators to manually align the crossover valves after a LOSW occurs and if othermanual actions are needed during the LOSW event. The staff also requests information ontraining and testing completed that substantiates those operator actions can be completedwithin the times necessary to mitigate a LOSW event. (SBPB 3),Response:Time critical operator actions to cross-tie NSWS between units are already validatedusing periodic test PT/O/A/4600/113 (Operator Time Critical Task Verification) andPT/I &2/AI4600/030 (Cycling Time Critical Manually Operated Valves). Operators areallowed 60 minutes from initial LOSW until the cross-tie alignment is complete andcooling water is flowing to the affected unit. Local operator actions to open the NSWSpump discharge header crossover manual valves are included in this time requirementand are required to be performed in less than 25 minutes. Previous validations have3 shown that these times can be met and are documented in these periodic tests (PTs).Additionally, all non-licensed operators are required to locate the manual cross-tie valvesin the plant as part of training and qualification (T&Q) Guide MO-8004. (Response toRAI #13 provides related insight).NRC Request for Additional Information:4. Describe the required operator actions that support implementation of the proposed LAR.(AHPB 1)Response:Operators will align valves from the Control Room as necessary to supply cooling water fromthe desired train on the sharing unit to the desired train on the affected unit. Operators willensure the shared train maintains required loads. Additionally, operators will be dispatched tolocally operate the specific NSWS pump discharge header crossover manual valves tocomplete the alignment.NRC Request for Additional Information:5. Are there any additions to, deletions of, or changes to current operator actions required tosupport this LAR? If yes, continue. If no, provide the answers to Questions 1 and 2 only.(AHPB 2)Response:APs will be revised to include all operator actions required to cross-tie NSWS trains betweenunits.NRC Request for Additional Information:6. What are the changes, deletions, or additions to procedures associated with this LAR?(AHPB 3)Response:APs will be revised to include operator actions required to cross-tie NSWS trains betweenunits. No other changes are anticipated.4 NRC Request for Additional Information:7. Are there any changes to the time available for the affected actions or the time required tocomplete the action(s)? If yes, what are the available times and the observed completiontimes (seconds, minutes, hours) associated with performing the action(s) before and after theLAR? (AHPB 4)Response:No, controls of time critical actions are controlled by Nuclear System Directives (NSD 514).The time available or required to perform actions to cross connect units is not affected. (RAI#3 and #11 responses provide related insight).NRC Request for Additional Information:8. What cues and/or alarms will be provided for required operator action(s) identified in Question1, above? (AHPB 5)Response:Operators are trained to implement APs based on "symptoms" listed at the beginning of theAP. Control Room indications of SW flow, SW pressure, and SW pump status are includedin the AP's list of symptoms and would be used by the operator to diagnose a LOSWcondition. Implementation of this LAR does not require any additional alarms or cues to beadded to the AP.NRC Request for Additional Information:9. Will there be any control room or remote shutdown panel modifications associated with thisrequest? If so, what changes will take place, and when? (AHPB 6)Response:No control room or remote shutdown panel modifications will be needed for this LAR.NRC Request for Additional Information:10. Will the required actions be performed by one operator or more than one? Will it require thecoordination of an operator at each unit? (AHPB 7)Response:Cross connecting SW between units will require one Control Room operator on each unit tomake the necessary valve and pump alignments. Additionally, it will take at least oneoperator in the plant to locally open required crossover manual valves. The AP will bewritten such that all operator actions are coordinated appropriately.5 NRC Reauest for Additional Information:11. Will the task analysis that is the basis for the Emergency Operating Procedures (EOPs),control room equipment, training, and qualification require revision? If not, how will theoperators' needs be determined? (AHPB 8)Response:No revision to the operator task analysis will be required. The task analysis supportingprevious AP guidance to cross connect NSWS during a LOSW event will be used to restorethe AP guidance. This task analysis is not expected to change. (Response to RAI #18provides additional insight).NRC Request for Additional Information:12. How will personnel know when to initiate the action(s)? (AHPB 9)Response:Actions to cross-tie SW between units will be controlled by AP. The actions to cross-tie SWbetween units will be initiated once Control Room personnel are (1) unsuccessful at startinga SW pump on the affected unit and (2) unsuccessful at establishing adequate cooling waterflow from a backup cooling water source (i.e. Containment Ventilation Cooling WaterSystem).NRC Request for Additional Information:13. How will personnel know that the action(s) was performed correctly? (AHPB 10)Response:After the SW cross-tie alignment has been made AP will have a Control Room operatoraction on the LOSW unit to verify temperature indications are within a normal range forcritical components receiving cooling water from the sharing unit. Alarms and alarmresponses will ensure the shared train is operated within normal parameters.NRC Request for Additional Information:14. How will personnel know when the action(s) should be terminated? (AHPB 11)Response:AP will contain guidance to terminate the alignment after the affected unit restores a SWpump to service.6 INRC Request for Additional Information:15. Have likely human errors and their potential consequences been identified? If yes, describeerrors analyzed. If no, why not? (AHPB 12)Response:Yes. When an AP is revised, it goes through the verification and validation process perOperations Management Procedure (OMP) 4-7 (Verification Process for Abnormal andEmergency Procedures) and OMP 4-8 (Validation of the Emergency Response CapabilitySystem). This process ensures procedures are technically correct and written such thatoperators understand the actions required. If an operator error does occur during thealignment, the AP will contain actions for control room operators to monitor plant conditionson both units to ensure proper system response.NRC Request for Additional Information:16. Will the proposed action(s) require additional staffing or qualification? (AHPB 13)Response:No additional staffing or qualification will be required.NRC Request for Additional Information:17. Can the action(s) be performed within the analyzed time constraints?a. With minimum control room staffing?Response:Yes. Actions can be performed with minimum Control Room staffing.b. With normal control room staffing?Response:Yes. Actions can be performed with normal Control Room staffing.c. Under environmental conditions expected, e.g. emergency lighting, noise, heat, outdoorelements?Response:Yes. The NSWS pump discharge header crossover manual valves are located in acommon area of the Auxiliary Building that is routinely accessed during all modes of7 operation. The operator will be able to manipulate the valves during all expectedenvironmental conditions.d. Using required equipment, such as self-contained breathing apparatus, PCs, hand-carriedmeters, or tools? (AHPB 14)Response:Yes. A step ladder is the only tool required to locally operate the NSWS pump dischargeheader crossover manual valves. The ladder will be pre-staged in the area, and the APwill tell the operator where to obtain it.NRC Request for Additional Information:18. Was a review of operating experience (OE) done to support the LAR? If yes, what insightswere derived? If OE not reviewed. Why not? (AHPB 15)Response:The proposed LAR was predominately influenced by NRC issued violations related toMcGuire's intended use of the NSWS Pump Discharge Crossover Valves and related causeevaluations. The March 4, 2011, "Final Response to Task Interface Agreement -McGuireNuclear Station Service Water System Unit Crossties Relative to Sharing/Donating inAbnormal Procedures (TIA 2009-011)" developed by the Office of Nuclear ReactorRegulation was the single largest contributor used as the basis for the proposed LAR.Additionally, license amendments issued in response to NRC Generic Letter 91-13,"Request for Information Related to the Resolution of Generic Issue 130, Essential ServiceWater System Failures at Multi-Unit Sites" including Byron and Braidwood Stations (TAC #M85240, M85239, M85237 & M85238) and Comanche Peak (TAC # M80210 & M84709)were reviewed; however, applicable insights from these approved amendments was oflimited use. The proposed LAR was primarily derived from the following experiences:Generic Letter (GL) 91-13, Essential Service Water System Failures at Multi-Unit Sites,encouraged multi-unit sites to develop administrative-type improvements, includingTechnical Specification amendments and emergency procedure upgrade, to enhance theavailability of NSWS Trains for the purpose of mitigating a LOSW event on the opposite unit.The improvements suggested in GL 91-13 were warranted in view of the safety benefit to bederived.Insight: McGuire recognized the benefit of cross tying NSWS between units in the eventone unit experienced a LOSW event; however, the site's initial response was notadequate. Specifically, the original GL 91-13 evaluation failed to recognize thesignificance of procedurally specifying the use of the portions of the NSWS not designedto meet Appendix A to 10 CFR 50, General Design Criteria 5 (Sharing of structures,systems, and components). Several subsequent NRC violations emphasized the needfor prior NRC approval before NSWS could be shared between units to mitigate a LOSWevent as intended by GL 91-13.June 27, 1986; McGuire received a violation of 10 CFR 50.59 requirements for cross-connecting NSWS Trains between the units (NRC Inspection Report 50-369 / 85-38 and 50-8 Y370 / 85-39). It was determined the cross tie was prohibited by the unit's TechnicalSpecifications. The NSWS Pump Discharge Cross-Over Valves were not identified asshared components within the TSs and therefore should not have been used to sharesystem flows.Insight: The NSWS Pump Discharge Cross-Over Valves cannot be used without priorNRC approval. Following the approval of the proposed LAR, McGuire will be able tosupport development of a procedure under 10 CFR 50.59.April 24, 2008; McGuire received a violation for failure to adequately establish and maintainprocedures required by TS 5.4.1 (NRC Integrated Inspection Report 05000369 / 2008002and 05000370 / 2008002). Specifically, McGuire failed to adequately establish and maintainAP for LOSW (APIIIA/5500/20 & AP/2/A/5500/20), in that the procedure required operationof the NSWS outside the bounds of the approved licensing basis. The AP directed operatorsto cross-connect an operable NSWS train from one unit to the NSWS on the other unitwithout a safety analysis showing that such sharing would not significantly impair theNSWS's ability to perform its intended safety function for its original assigned unit.Insight: The safety implications associated with sharing the NSWS between units usingthe NSWS Pump Discharge Cross-Over Valves must be described in the UFSAR inaccordance with Regulatory Guide 1.70. Following the approval of the proposed LAR,McGuire plans to describe applicable aspects of sharing NSWS between units in theUFSAR.March 4, 2011; The NRC Office of Nuclear Reactor Regulation answered questions relatedto sharing NSWS between units via NSWS Pump Discharge Crossover Valves (FinalResponse to Task Interface Agreement -"McGuire Nuclear Station Service Water SystemUnit Crossties Relative to Sharing/Donating in Abnormal Procedures (TIA 2009-011))".Insight: The TIA confirmed a LAR was needed to share a NSWS train during a LOSWevent, sharing a NSWS train was not allowed by TS 3.0.2, and the current UFSARdescription and procedure guidance were not supported by an adequate 50.59evaluation.Following issuance of the TIA, McGuire received two additional violations on May 6, 2011(NRC Integrated Inspection Report 05000369 / 2011002 and 05000370 / 2011002). Aviolation of 10 CFR 50.71 (e) was identified for failure to update the UFSAR to reflect the siteresponse to Generic Letter (GL) 91-13, Essential Service Water System Failures at Multi-Unit Sites, which described capabilities in existing procedures for cross-connecting NSWbetween units. Also, a violation of 10 CFR 50.59 was identified for changes to the UFSARand AP-20, without prior NRC approval. The changes allowed one train of NSW to bealigned to the opposite unit to mitigate a LOSW event by opening NSWS Pump DischargeCrossover Valves.Insight: McGuire restored compliance by eliminating the AP allowing a NSWS train to beshared during a LOSW event and removed the description from the UFSAR. It is DukeEnergy's intent to restore procedure guidance and revise the UFSAR following NRCapproval of the proposed amendment.9 NRC Request for Additional Information:19. Was a Human Reliability Analysis (HRA) done to support this LAR? If yes, what insightswere derived? If HRA not performed, why not? (AHPB 16)Response:A specific human reliability analysis was not performed because the LAR is not a risk-informed submittal. The proposed changes would allow recovery actions for alignment ofthe NSWS pump discharge crossover header to be placed in plant procedures.Proceduralized actions are considered more reliable and thus the proposed changes areexpected to improve plant safety.NRC Request for Additional Information:20. Were additions, deletions, or changes made to the training program? If yes, describe. If no,justify why not. (AHPB 17)Response:No. Operators are already trained on the time critical nature of this evolution as required bynuclear station directive NSD 514 (Control of Time Critical Tasks). Operators will be trainedthat the use of the NSWS crossover is restored using AP guidance.NRC Request for Additional Information:21. Was any verification and validation of operator actions performed, or is any planned? (AHPB18)Response:When an AP is revised, it goes through the verification and validation process per OMP 4-7(Verification Process For Abnormal and Emergency Procedures) and 4-8 (Validation Of TheEmergency Response Capability System). This process ensures procedures are technicallycorrect and written such that operators understand the actions required.Time critical operator actions to cross-tie NSWS between units are already periodicallyvalidated in PT/O/AI4600/113 (Operator Time Critical Task Verification) andPT/1 &2/A/4600/030 (Cycling Time Critical Manually Operated Valves).NRC Request for Additional Information:22. Is any follow-up or long-term monitoring of this change planned? (AHPB 19)Response:10

.W. .%Yes. Time critical operator actions to cross-tie NSWS between units will be periodicallyvalidated in PT/OIA14600/113 (Operator Time Critical Task Verification) andPT/1&2/A/4600/030 (Cycling Time Critical Manually Operated Valves). Additionally, theNSWS cross-tie piping will continue to be periodically flushed to ensure it is free of debrisper PT/OIAI43501063 (Flushing of NSWS System Discharge Crossover Piping).NRC Request for Additional Information:23. Who has the responsibility to establish the crosstie that is needed? (AHPB 20)Response:The Operations group has the responsibility to make the necessary cross-tie alignmentduring a LOSW event.NRC Request for Additional Information:24. You rely on the Frequency Control Program to define the frequency with which surveillanceis done. Please describe the program. (AHPB 21)Response:The Duke Energy Surveillance Frequency Control Program (SFCP) provides a process forthe evaluation, implementation, and management of TS risk-informed surveillancerequirement (SR) frequency changes. The SFCP is administered by Nuclear StationDirective (NSD) 419, Revision 0.The SFCP process provides for a risk analysis, commitment review, deterministic evaluation(test history, maintenance history, manufacturer's recommendations, codes and standardsadherence, and operating experience), documentation, and performance monitoring ofchanges. This process is referred to as a STRIDE (Surveillance Test, Risk-Informed,Documented, Evaluation). The Duke Energy SFCP was benchmarked against the industry.A multi-disciplinary Independent Decision Making Panel (IDP) is utilized to initially evaluatedeterminations of proposed surveillance frequencies changes. Final review and approval ofa STRIDE is performed by the Plant Operations Review Committee (PORC).The Duke Energy SFCP was developed in accordance with Technical Specification TaskForce (TSTF) 425, Revision 3 "Relocate Surveillance Frequencies to Licensee Control-RITSTF Initiative 5b" and Nuclear Energy Institute (NEI) 04-10, Risk-Informed Method forControl of Surveillance Frequencies, Revision 1. McGuire submitted a license amendment inaccordance with the TSTF and the NRC model safety evaluation and it was approved byNRC on March 29, 2011. Also per the TSTF, a new program was added to theAdministrative Controls section of the Technical Specifications, TS 5.5.17, which describesthe process at a high level.11