HNP-14-108, Response to Request for Additional Information Re License Amendment Request to Revise Technical Specification Table 3.3-4 Loss of Offsite Power 6.9 Kv Emergency Undervoltage Primary Setpoints

Response to Request for Additional Information Re License Amendment Request to Revise Technical Specification Table 3.3-4 Loss of Offsite Power 6.9 Kv Emergency Undervoltage Primary Setpoints

ML14296A365
Person / Time
Site:	Harris
Issue date:	10/23/2014
From:	Waldrep B Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
HNP-14-108, TAC MF4294
Download: ML14296A365 (5)

Text

Benjamin C. Waldrep Vice President Harris Nuclear Plant 5413 Shearon Harris Road New Hill NC 27562-9300 919.362.2000 10 CFR 50.90 Serial: HNP-14-108 October 23, 2014 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400 / Renewed License No. NPF-63

Subject:

Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification Table 3.3-4 Loss of Offsite Power 6.9 kV Emergency Undervoltage Primary Setpoints (TAC No. MF4294)

Ladies and Gentlemen:

By letter dated June 19, 2014, Duke Energy Progress, Inc., requested an amendment to the Technical Specifications (TS) for Shearon Harris Nuclear Power Plant, Unit 1 (HNP). HNP proposes to revise TS 3.3.2, Engineered Safety Features Actuation System Instrumentation, Table 3.3-4, Engineered Safety Features Actuation System Instrumentation Trip Setpoints.

Specifically, the Functional Unit 9.a, Loss-of-Offsite Power 6.9 kV Emergency Bus Undervoltage

- Primary, instrument trip setpoint and associated allowable value are being revised to correct a non-conservative TS. The proposed change incorporates portions of Technical Specification Task Force Traveler TSTF-493-A, Option A, related to the Loss-of-Offsite Power instrumentation surveillance requirements.

The NRC staff reviewed the request and determined that additional information is needed to complete their review. A letter requesting additional information was sent on October 8, 2014, requesting a response by October 24, 2014. The HNP response to the request is enclosed.

This document contains no new Regulatory Commitments.

Please refer any questions regarding this submittal to John Caves at (919) 362-2406.

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Sincerely, Benjamin C. Waldrep

Enclosure:

Response to Request for Additional Information cc: Mr. J. D. Austin, NRC Sr. Resident Inspector, HNP (email)

Mr. W. L. Cox, III, Section Chief N.C. DENR (email)

Ms. M. Barillas, NRC Project Manager, HNP (email)

Mr. V. M. McCree, NRC Regional Administrator, Region II (EIE)

U.S. Nuclear Regulatory Commission Page 1 of 2 HNP-14-108 Enclosure Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400 / Renewed License No. NPF-63 Response to Request for Additional Information License Amendment Request to Revise Technical Specification Table 3.3-4 Loss of Offsite Power 6.9 kV Emergency Undervoltage Primary Setpoints By letter dated June 19, 2014, Duke Energy Progress, Inc., requested an amendment to the Technical Specifications (TS) for Shearon Harris Nuclear Power Plant, Unit 1 (HNP). HNP proposes to revise TS 3.3.2, Engineered Safety Features Actuation System Instrumentation, Table 3.3-4, Engineered Safety Features Actuation System Instrumentation Trip Setpoints.

Specifically, the Functional Unit 9.a, Loss-of-Offsite Power 6.9 kV Emergency Bus Undervoltage

- Primary, instrument trip setpoint and associated allowable value are being revised to correct a non-conservative TS. The proposed change incorporates portions of Technical Specification Task Force (TSTF) Traveler TSTF-493-A, Option A, related to the Loss-of-Offsite Power instrumentation surveillance requirements.

The NRC staff reviewed the request and determined that additional information is needed to complete their review. A letter requesting additional information was sent on October 8, 2014, requesting a response by October 24, 2014. The HNP response to the request follows.

STSB RAI 1:

HNP TS 3.3.2, Table 3.3-4 Functional Unit 6.e refers to Item 9. Item 9 is Loss of Offsite Power functional unit and it consists of two functions 9.a, 6.9 kV Emergency Bus Undervoltage -

Primary (Loss of Voltage), and 9.b, 6.9 kV Emergency Bus Undervoltage -Secondary (Degraded Voltage).

Explain why the TSTF-493 Notes 1, 2 were not applied to both functions 9.a and 9.b. (only 9a.

states See Notes 1, 2).

Response

HNP did not request any change to Item 9.b. in the subject license amendment request (LAR),

and a change to Item 9.b. is not required to resolve the identified non-conservative specification that resulted in the license amendment request. This LAR was not intended to implement TSTF-493 beyond the limited scope of resolving the non-conservative TS.

U.S. Nuclear Regulatory Commission Page 2 of 2 HNP-14-108 Enclosure STSB RAI 2:

TSTF-493 requires that if the specification does not include a Surveillance Requirements column or a Function table, then the Notes are added to the applicable Surveillance Requirements.

Explain why the TSTF-493 Notes were not applied to the channel calibration and trip actuating device operational test surveillance requirements in Table 4.3-2 for channel functional unit 9.a and 9.b.

Response

The proposed applications of the TSTF-493 Notes in this LAR are consistent with the application of TSTF-493 Notes in Table 2.2-1, Reactor Trip System Instrumentation Trip Setpoints, implemented in Amendment 139 as documented in Shearon Harris Nuclear Power Plant, Unit 1 - Issuance Of Amendment Re: Measurement Uncertainty Recapture Power Uprate dated May 30, 2012 (ADAMS Accession Number ML11356A096).

Page 66 of the Safety Evaluation states:

The NRC staff reviewed the two notes proposed by the licensee and found that they are consistent with the intent of the two notes in Option A of TSTF-493, Revision 4.

Therefore, the staff finds the addition of Notes 7 and 8 acceptable.

It would be inappropriate to have inconsistent application of the Notes in the two sections of TS.

As indicated above, no changes were requested to Item 9.b., so Notes were not proposed for the existing specifications.