ML070320656

Request for Additional Information Shearon Harris Nuclear Power Plant Unit 1 - Revision for Steam Generator Water Level Trip Setpoints

ML070320656
Person / Time
Site:	Harris
Issue date:	02/06/2007
From:	Chandu Patel NRC/NRR/ADRO/DORL/LPLII-2
To:	Duncan R Carolina Power & Light Co
Patel C, NRR/DORL/LPL2-2, 415-3025
References
TAC MD2723
Download: ML070320656 (5)

Text

February 6, 2007 Mr. Robert J. Duncan II, Vice President Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Code: Zone 1 New Hill, North Carolina 27562-0165

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION ON REVISION FOR STEAM GENERATOR WATER LEVEL TRIP SETPOINTS (TAC No. MD2723)

Dear Mr. Duncan:

By letter dated August 2, 2006, Carolina Power and Light Company, requested an amendment to the operating license for the Shearon Harris Nuclear Power Plant, Unit 1 to revise the allowable value for Steam Generator Water Level - Low, Coincident with Steam/Feedwater Flow Mismatch trip setpoint used in the Reactor Trip System instrumentation in the technical specifications.

The Nuclear Regulatory Commission staff has reviewed your submittal and determined that additional information is required in order to complete our review. Our request for additional information is enclosed. Please provide your response within 30 days from receipt of this letter to support our review schedule. Please contact me at 301-415-3025, if you have any questions.

Sincerely,

/RA/

Chandu P. Patel, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-400

Enclosure:

As stated

ML070320656 OFFICE LPL2-2/PM LPL2-2/LA EICB/BC LPL2-2/BC (A)

NAME CPatel RSola AHowe (by memo dated) MChernoff DATE 2/6/07 2/6/07 01/12/07 2/6/07 REQUEST FOR ADDITIONAL INFORMATION SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 STEAM GENERATOR WATER LEVEL TRIP SETPOINT TAC NO. MD2723 The license amendment request (LAR) proposes technical specification (TS) change to the allowable value for Steam Generator Water Level - Low Coincident with Steam/Feedwater Flow Mismatch trip setpoint used in the Reactor Trip System (RTS) instrumentation.

To support the Nuclear Regulatory Commission (NRC) staff assessment of the acceptability of the LAR in regard to setpoint changes, please provide the following:

1. Setpoint Calculation Methodology: Provide documentation (including sample calculations) of the methodology used for establishing the limiting setpoint (or NSP) and the limiting acceptable values for the As-Found and As-Left setpoints as measured in periodic surveillance testing. Indicate the related Analytical Limits and other limiting design values (and the sources of these values) for the setpoint.

2. Safety Limit (SL)-Related Determination: Provide a statement as to whether or not the setpoint is a limiting safety system setting for a variable on which an SL has been placed as discussed in 10 CFR 50.36(c)(1)(ii)(A). Such setpoints are described as SL-Related in the discussions that follow. In accordance with 10 CFR 50.36(c)(1)(ii)(A), the following guidance is provided for identifying a list of functions to be included in the subset of limiting safety system settings (LSSSs) specified for variables on which SLs have been placed as defined in Standard Technical Specifications (STS) Sections 2.1.1, Reactor Core SLs and 2.1.2, Reactor Coolant System Pressure SLs. This subset includes automatic protective devices in TSs for specified variables on which SLs have been placed that: (1) initiate a reactor trip; or (2) actuate safety systems. As such these variables provide protection against violating reactor core safety limits, or reactor coolant system pressure boundary safety limits.

Examples of instrument functions that might have LSSSs included in this subset in accordance with the plant-specific licensing basis, are pressurizer pressure reactor trip (pressurized water reactors), rod block monitor withdrawal blocks (boiling water reactors), feedwater and main turbine high water level trip (boiling water reactors), and end of cycle recirculation pump trip (boiling water reactors). For each setpoint, or related group of setpoints, that you determined not to be SL-Related, explain the basis for this determination.

3. For setpoints that are determined to be SL-Related: The NRC letter to the Nuclear Energy Institute (NEI), Setpoint Methods Task Force dated September 7, 2005 (Reference 1), describes Setpoint-Related TS (SRTS) that are acceptable to the NRC for instrument settings associated with SL-related setpoints. Specifically: Part A of the Enclosure to the letter provides limiting condition for operation notes to be added to the TS, and Part B includes a check list of the information to be provided in the TS Bases related to the proposed TS changes.

Enclosure

a. Describe whether and how you plan to implement the SRTS suggested in the September 7, 2005, letter. If you do not plan to adopt the suggested SRTS, then explain how you will ensure compliance with 10 CFR 50.36 by addressing items 3b and 3c, below.

b. As-Found Setpoint evaluation: Describe how surveillance test results and associated TS limits are used to establish operability of the safety system. Show that this evaluation is consistent with the assumptions and results of the setpoint calculation methodology. Discuss the plant corrective action processes (including plant procedures) for restoring channels to operable status when channels are determined to be inoperable or operable but degraded. If the criteria for determining operability of the instrument being tested are located in a document other than the TS (e.g. plant test procedure) explain how the requirements of 10 CFR 50.36 are met.

c. As-Left Setpoint control: Describe the controls employed to ensure that the instrument setpoint is, upon completion of surveillance testing, consistent with the assumptions of the associated analyses. If the controls are located in a document other than the TS (e.g. plant test procedure) explain how the requirements of 10 CFR 50.36 are met.

4. For setpoints that are not determined to be SL-related: Describe the measures to be taken to ensure that the associated instrument channel is capable of performing its specified safety functions in accordance with applicable design requirements and associated analyses. Include in your discussion information on the controls you employ to ensure that the as left trip setting after completion of periodic surveillance is consistent with your setpoint methodology. Also, discuss the plant corrective action processes (including plant procedures) for restoring channels to operable status when channels are determined to be inoperable or operable but degraded. If the controls are located in a document other than the TS (e.g., plant test procedure), describe how it is ensured that the controls will be implemented.

REFERENCES:

1. Letter from Patrick L. Hiland, NRC, to NEI, Setpoint Methods Task Force, "Technical Specification for Addressing Issues Related to Setpoint Allowable Values," dated September 7, 2005, available on the NRC public website in the Agencywide Documents Access and Management System (ADAMS) Accession No. ML052500004.

2. Letter from Bruce A. Boger, NRC, to Alexander Marion, NEI, "Instrumentation, Systems, and Automatic Society (ISA) S67.04 Methods for Determining Trip Setpoints and Allowable Values for Safety-Related Instrumentation," dated August 23, 2005, ADAMS Accession No. ML051660447.

3. Letter from James A. Lyons, NRC, to Alexander Marion, NEI, "Instrumentation, Systems, and Automation Society S67.04 Methods for Determining Trip Setpoints and Allowable Values for Safety-Related Instrumentation," dated March 31, 2005, ADAMS Accession No. ML050870008.