HNP-14-119, Response to Request for Additional Information 2 Regarding License Amendment Request to Revise Technical Specification Table 3.3-4 Loss of Offsite Power 6.9 Kv Emergency Undervoltage Primary Setpoints
| ML14317A449 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/13/2014 |
| From: | Waldrep B Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| HNP-14-119 | |
| Download: ML14317A449 (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-14-119 November 13, 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 #2 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 24, 2014, requesting a response by November 14, 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.
U.S. Nuclear Regulatory Commission HNP-14-119 I declare under penalty of perjury that the foregoing is true and correct.
Executed on [
NOV 1
- 3 _2014
].
Sincerely, Be~in~-~:£
Enclosure:
Response to Request for Additional Information #2 cc:
Mr. J. D. Austin, NRC Sr. Resident Inspector, HNP (email)
Mr. W. L. Cox, Ill, Section Chief N.C. DENR (email)
Ms. M. Barillas, NRC Project Manager, HNP (email)
Mr. V. M. McCree, NRC Regional Administrator, Region II (EIE)
Page2
U.S. Nuclear Regulatory Commission Page 2 HNP-14-119 I declare under penalty of perjury that the foregoing is true and correct.
Executed on [ ].
Sincerely, Benjamin C. Waldrep
Enclosure:
Response to Request for Additional Information #2 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-14-119 Enclosure Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400/Renewed License No. NPF-63 Response to Request for Additional Information #2 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 24, 2014, requesting a response by November 14, 2014. The HNP response to the request follows.
EICB RAI 1:
The calculation submitted indicates how the Total Loop Uncertainties, Field Setpoint, Allowable Value, As-Found Tolerance, and As-Left Tolerance have been calculated for the Undervoltage Relays and the Time Delay Relays. The staff noticed the tolerances (e.g.,
Reference Accuracy, Drift, Measurement and Test Equipment Error) used in calculating these parameters are either based on vendor provided data or from field test data. Provide additional details regarding the magnitude and confidence level of the uncertainties that are based on the vendor-provided data and the evaluation of the field data. Specifically, for each uncertainty tolerance, describe and explain the standard deviation and confidence levels used.
Response
Reference Accuracy The relay reference accuracy of 2% is a vendor provided parameter. The basis is discussed in the referenced calculation, section 4.2.2, which was docketed with the license amendment request. Harris Nuclear Plant staff did not review the raw data used by the vendor to establish that value, so additional information related to standard deviation and confidence level from the statistical analysis supporting the reference accuracy is not available. Following the implementation of the requested Technical Specification change, Surveillance Test MST-E0075, EMERGENCY BUS 1A-SA AND 1B-SB UNDERVOLTAGE (LOSS OF VOLTAGE) CHANNEL CALIBRATION, will confirm the as-found relay setpoint is within the as-found tolerance. If the
U.S. Nuclear Regulatory Commission Page 2 of 2 HNP-14-119 Enclosure as-found setpoint is outside of the as-found tolerance, a condition report will be initiated in the corrective action program and appropriate corrective actions would be taken.
Drift The basis for the use of 2% drift is discussed in the referenced calculation, Appendix P, which was docketed with the license amendment request. The value was selected based upon review of the data as opposed to a statistical analysis, so the standard deviation and confidence level were not calculated. Following the implementation of the requested Technical Specification change, Surveillance Test MST-E0075, EMERGENCY BUS 1A-SA AND 1B-SB UNDERVOLTAGE (LOSS OF VOLTAGE) CHANNEL CALIBRATION, will confirm the as-found relay setpoint is within the as-found tolerance. If the as-found setpoint is outside of the as-found tolerance, a condition report will be initiated in the corrective action program and appropriate corrective actions would be taken.
Test Equipment Error The test equipment errors are vendor provided parameters. Harris Nuclear Plant staff did not review the raw data used by the vendor to establish that value, so additional information related to standard deviation and confidence level from the statistical analysis supporting the test equipment errors is not available. The validity of the value is confirmed by the Measuring and Test Equipment Program, which implements the requirements of the 10 CFR 50, Appendix B, Quality Assurance Program. In the event that test equipment as-found calibration is outside specified tolerance, plant procedures require that a condition report be initiated in the corrective action program and appropriate corrective actions be taken.