ML15281A246
| ML15281A246 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/06/2015 |
| From: | Martha Barillas Plant Licensing Branch II |
| To: | Caves J Duke Energy Corp |
| References | |
| TAC MF6196 | |
| Download: ML15281A246 (7) | |
Text
NRR-PMDAPEm Resource From: Barillas, Martha Sent: Tuesday, October 06, 2015 1:53 PM To: Caves, John Cc: Barillas, Martha
Subject:
Harris EALs LAR draft RAI (MF6196)
Attachments: Harris R6 EAL Draft RAIs.docx
- John, By letter dated April 30, 2015, Duke Energy Progress, Inc. (Duke Energy), requested approval of a proposed change to the Emergency Action Levels (EALs) used at the Shearon Harris Nuclear Plant (HNP), Unit 1 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML15126A083
[package]). Duke Energy proposed to revise their current HNP EAL scheme to one based on Revision 6 to Nuclear Energy Institute (NEI) document NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors (ADAMS Accession Number ML12326A805).
The draft requests for additional information (RAIs) attached are needed to support NRC staffs continued review of the proposed EAL scheme change.
If a clarification call is needed to discuss the attached draft RAI, it is requested you respond by October 8, 2015, with a proposed date.
We request the RAI response within 30 days of receipt of this email. If you do not believe you can meet this date, please provide an acceptable alternate date.
If circumstances result in the need to revise the response date, please contact me at (301) 415-2760 or via e-mail Martha.Barillas@nrc.gov.
Martha Barillas Project Manager Shearon Harris & H. B. Robinson NRR/DORL/Licensing Branch II-2 US Nuclear Regulatory Commission 301-415-2760 1
Hearing Identifier: NRR_PMDA Email Number: 2440 Mail Envelope Properties (312f4f0ae95a493ab5e11ee5f2ed82ba)
Subject:
Harris EALs LAR draft RAI (MF6196)
Sent Date: 10/6/2015 1:52:30 PM Received Date: 10/6/2015 1:52:31 PM From: Barillas, Martha Created By: Martha.Barillas@nrc.gov Recipients:
"Barillas, Martha" <Martha.Barillas@nrc.gov>
Tracking Status: None "Caves, John" <John.Caves@duke-energy.com>
Tracking Status: None Post Office: HQPWMSMRS03.nrc.gov Files Size Date & Time MESSAGE 1400 10/6/2015 1:52:31 PM Harris R6 EAL Draft RAIs.docx 40966 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
REQUESTS FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST EMERGENCY ACTION LEVEL SCHEME CHANGE SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400 By letter dated April 30, 2015, Duke Energy Progress, Inc. (Duke Energy), is requesting approval of a proposed change to the Emergency Action Levels (EALs) used at the Shearon Harris Nuclear Plant (HNP), Unit 1 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML15126A083 [package]). Duke Energy proposes to revise their current HNP EAL scheme to one based upon Revision 6 to Nuclear Energy Institute (NEI) document NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors (ADAMS Accession Number ML12326A805).
The requests for additional information (RAIs) listed below, in regards to Enclosure 3, Emergency Action Level Basis Document, are needed to support NRC staffs continued technical review of the proposed EAL scheme change.
RAI-HNP-1 Section 2.5, Technical Basis Information, includes a Plant-Specific (HNP) basis section, in addition to a Generic (NEI 99-01) basis section. One of the enhancements provided in Revision 6 to NEI 99-01 is a separation of the developers notes from the bases information.
This change was made to facilitate the use of bases information for the two distinct purposes, development and classification. Considering that the EAL Technical Basis is provided to support proper emergency classification decision making, please explain why a Generic (NEI 99-01) basis section is provided rather than incorporated into Plant-Specific (HNP) basis section.
Specific examples include the following:
- Escalation should refer to HNP EAL numbering vice generic NEI 99-01 EAL numbering to facilitate timely assessments by the Emergency Coordinator.
- The Plant-Specific (HNP) basis section information should be specific to each EAL provided by the licensee. The following are two examples of apparent inconsistencies:
o For the proposed RA1.3, the NEI 99-01 basis discussion includes reference to gaseous radioactivity while the proposed RA1.3 only applies to liquid effluent samples.
o For the proposed RA1.4, the last paragraph of the NEI 99-01 basis discussion includes reference to effluent radiation monitors while the EAL only applies to field survey results.
DRAFT
RAI-HNP-2 Section 4.3, Instrumentation Used for EALs, to NEI 99-01, Revision 6, states in part: Scheme developers should ensure that specific values used as EAL setpoints are within the calibrated range of the referenced instrumentation. Please confirm that all setpoints and indications used in the HNP EAL scheme are within the calibrated range(s) of the stated instrumentation and that the resolution of the instrumentation is appropriate for the setpoint/indication.
RAI-HNP-3 Appendix B, Definitions, to NEI 99-01, Revision 6, provides definitions for key terms necessary for overall understanding of the NEI 99-01 emergency classification scheme.
- a. For Section 5.1, Definitions, please justify the omission of the following definitions, or revise accordingly to include:
- Site Area Emergency,
- Unusual Event,
- Emergency Action Level,
- Emergency Classification Level,
- Fission Product Barrier Threshold, and
- Initiating Condition.
- b. For Section 5.1, Definitions, the proposed Alert and General Emergency definitions read events are in progress vice the proposed events are in process. Provide justification for this difference.
RAI-HNP-4 For EALs RA1.1, RS1.1 and RG1.1, there was a substantial change from the previous to the proposed Table R-1 values. The provided calculations did not contain information that could be used by the staff to verify the basis for this change. Please provide justification that supports the changes in the Table R-1 values from the previous values to the current values.
RAI-HNP-5 For EAL RU2.1, site-specific refueling pathway level indication is not provided per NEI 99-01, Revision 6. Please provide additional information as to why omitting specific level instrumentation for the EAL would not affect timely and accurate assessment, or revise the EAL to provide applicable site specific level indications, including the applicable mode availability for this level instrumentation.
RAI-HNP-6 EAL RA 2.1 states, Unusual Event, rather than an Alert as indicated in NEI 99-01, Revision 6, for this EAL. Provide justification for this difference.
DRAFT
RAI-HNP-7 Concerning EAL RA2.2, the logic was changed from NEI 99-01, Revision 6, which uses an increase in radiation monitor readings to determine that irradiated fuel has been damaged to a proposed logic that requires the operator to know that damage has occurred to irradiated fuel and there is an increase in radiation monitor indications. Please provide further justification for this deviation or revise accordingly based on NEI 99-01, Revision 6 (EAL AA2).
RAI-HNP-8 Table R-3/H-2, Safe Operation & Shutdown Rooms/Areas, under RA3.2 and HA5.1, indicates that Containment Building access is required in Mode 3. Please explain why Containment Building access is required for Mode 3 operations and include what equipment is required to be operated and the specific area of the containment that requires access.
RAI-HNP-9 Concerning EALs CS1.3 and CG1.2, address the following:
- a. HNP did not include the qualifier from NEI 99-01, Revision 6 (CS1/CG1), of sufficient magnitude to indicate core uncover, to the unplanned increase in any sump/tank level in the EAL wording. As proposed, EALs CS1.3 and CG1.2 could result in unnecessary Site Area Emergency and General Emergency declarations. Please provide further justification, or revise EAL CS1.3 and CG1.2 accordingly consistent with NEI 99-01, Revision 6.
The indication of visual observation of UNISOLABLE RCS leakage does not provide an indication of core uncovery. As proposed, EALs CS1.3 and CG1.2 could result in unnecessary Site Area Emergency and General Emergency declarations. Please provide further justification, or revise accordingly consistent with NEI 99-01, Revision 6.
RAI-HNP-10 For EALs CU2.1, SU1.1 and SA1.1, no list/table was provided with the proposed EALs that shows off-site and on-site AC power sources that can supply the required power within 15 minutes. This list/table should only include power supplies that can supply the required power within 15 minutes. This could impact the timeliness and accuracy of assessment. Please provide justification as to why list/table of AC power supplies was not provided, or revise accordingly.
RAI-HNP-11 For EAL CU3.1, the proposed EAL contains the condition, due to the loss of decay heat removal capability, which is not consistent with NEI 99-01, Revision 6. This deviation could result in potential misclassification for an event other than a loss of decay heat removal capability that leads to an unplanned RCS temperature to rise. Please provide justification for this deviation, or revise accordingly consistent with NEI 99-01, Revision 6.
DRAFT
RAI-HNP-12 For EAL CA3.1, the proposed EAL contains the condition, due to the loss of RCS cooling, which is not consistent with NEI 99-01, Revision 6. This deviation could result in potential misclassification for an event other than a loss of RCS cooling that leads to an unplanned RCS pressure increase. Please provide justification for this deviation, or revise accordingly consistent with NEI 99-01, Revision 6.
RAI-HNP-13 Concerning EALs CU5.1 and SU7.1, address the following:
- a. The DEMNET System is provided as a communication method communication method to the offsite response organizations (OROs). Please provide evidence that the DEMNET communication method could function as a means of timely notification to OROs for a spectrum of potential event responses, or revise accordingly.
- b. Tables C-4 and S-3, Communication Methods, include the site paging system. The staff could not determine how the site paging system could be used as a communication method for routine communications in support of plant operations as provided in NEI 99-01, Revision 6. Please explain how operational communications could be completed if the only means of communication was the site paging system, or revise accordingly.
RAI-HNP-14 For EAL CA6.1 and SA9.1, the HNP Basis discussion for seismic events refers to a discussion under EAL HU2.1. Please provide justification for not including the discussion as this could impact the timeliness of event assessment, or revise accordingly to include the discussion on seismic events in the EAL CA6.1 and SA9.1 HNP Basis.
RAI-HNP-15 For IC HU4.1 and HU4.2, the proposed EALs appear to cover a wider range of areas than that provided by NEI 99-01, Revision 6. Please provide justification that all areas identified for this EAL contain equipment needed for safe operation, safe shutdown and safe cool-down, and demonstrate accurate and timely assessment is achieved.
RAI-HNP-16 The Basis-Related Requirements from Appendix R discussion provided in the NEI 99-01 HU4 Basis, was not included in the HNP EAL HU4.1. This discussion clarifies which rooms or areas should be included in the respective EALs. As such, this discussion supports timely and accurate assessments either during training activities or actual event conditions. Please provide further justification for exclusion of this Appendix R basis information, or revise accordingly.
DRAFT
RAI-HNP-17 For IC HA5.1, the Containment Building is included as one of the rooms/areas in Table R-3/H-2, Safe Operation & Shutdown Rooms/Areas, for Mode 3. Please explain why Containment Building access is required when Mode 3 is entered, and if required, please verify that the access to the entire Containment Building is accessible during Mode 3 operations.
RAI-HNP-18 No clear start time is provided for EALs HA6.1 and HS6.1. Please provide a site-specific condition that clearly indicates when the transfer of control from the control room to the alternate control panel begins, or provide justification as to why this detail is not required.
RAI-HNP-19 For ICs SU6.1, SU6.2, SA6.1 and SS6.1, the HNP basis includes a detailed discussion of post-trip response indications, which includes a prompt drop in reactor power (as sensed by nuclear instrumentation) and lowering of power into the source range. These indications are consistent with those included in the HNP EOPs. However, it is not clear as to how this discussion results in the conclusion that a successful reactor trip is indicated when reactor power is less than 5%.
Please justify why the qualifier, as indicated by reactor power > 5%, was added to the EALs, or revise accordingly. This justification should include the a discussion of the procedures and related training that clearly indicate that licensed operators are trained to solely rely on reactor power being less than 5% to determine post-trip reactor status.
RAI-HNP-20 For IC RC1, Fission Product Barrier (FPB) Threshold Potential Loss, address the following:
- a. The Potential Loss 1 proposes the following wording: > the capacity of one charging pump in the normal mode (greater than 120 gpm). This is not consistent with NEI 99-01, Revision 6, which states, Operation of a standby charging (makeup) pump is required. As proposed, the wording could imply that operators must determine an actual leak rate of 120 gpm or greater rather than determine that a second charging pump is required due to either an unisolable RCS leak or steam generator tube leakage.
Please provide justification for this deviation, or revise accordingly.
- b. The proposed Generic basis provides that the threshold is met when RCS leakage is determined to be in excess of normal makeup capacity with letdown isolated. This is not consistent with NEI 99-01, Revision 6, which states, Operation of a standby charging (makeup) pump is required. As proposed, this could imply that this threshold condition is not applicable until letdown is isolated. Furthermore, this basis discussion implies that the threshold is RCS leakage of approximately 120 gpm vice the need to start a second charging pump. Please provide justification for this change, or revise accordingly.
DRAFT