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MONTHYEARML15289A5902015-10-26026 October 2015 Request for Additional Information Regarding License Amendment Request to Revise Emergency Action Level Scheme to One Based on Rev. 6 of Nuclear Energy Institute 99-01, Development of Emergency Action Levels Project stage: RAI HNP-15-091, Response to Request for Additional Information Regarding License Amendment Request to Revise Emergency Action Level Scheme to One Based on Revision 6 of NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors2015-11-19019 November 2015 Response to Request for Additional Information Regarding License Amendment Request to Revise Emergency Action Level Scheme to One Based on Revision 6 of NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors Project stage: Response to RAI HNP-16-004, Supplement to Response to Request for Additional Information Regarding License Amendment Request to Revise Emergency Action Level Scheme to One Based on Revision 6 of Nuclear Energy Institute 99-01, Development of Emergency....2016-01-28028 January 2016 Supplement to Response to Request for Additional Information Regarding License Amendment Request to Revise Emergency Action Level Scheme to One Based on Revision 6 of Nuclear Energy Institute 99-01, Development of Emergency.... Project stage: Supplement ML16057A8382016-04-13013 April 2016 (Hnp), Unit 1 - Issuance of Amendment to Adopt Emergency Action Level Scheme Pursuant to NEI 00-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors Project stage: Approval 2015-11-19
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Category:Letter
MONTHYEARIR 05000400/20230042024-01-30030 January 2024 Integrated Inspection Report 05000400/2023004 ML23317A3462023-11-14014 November 2023 Duke Fleet - Correction Letter to License Amendment Nos. 312 & 340 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-554, Revision 1 IR 05000400/20230032023-11-0909 November 2023 Integrated Inspection Report 05000400/2023003 ML23346A1322023-10-0606 October 2023 Communication from C-10 Research & Education Foundation Regarding NextEra Common Emergency Fleet Plan License Amendment Request and Related Documents Subsequently Published ML23234A1702023-10-0303 October 2023 Issuance of Amendment No. 199 Regarding Administrative Changes to the Renewed Facility Operating License and Technical Specifications ML23256A0882023-09-25025 September 2023 Issuance of Alternative to Steam Generator Welds ML23195A0782023-08-29029 August 2023 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-554, Revision 1 IR 05000400/20230052023-08-23023 August 2023 Updated Inspection Plan for Shearon Harris Nuclear Power Plant, Unit 1 (Report 05000400/2023005) ML23234A2542023-08-22022 August 2023 RQ Inspection Notification Letter IR 05000400/20234022023-07-26026 July 2023 Security Baseline Inspection Report 05000400/2023402 IR 05000400/20230022023-07-24024 July 2023 Integrated Inspection Report 05000400/2023002 IR 05000400/20234402023-07-17017 July 2023 Special Inspection Report 05000400/2023440 and Preliminary Greater than Green Finding and Apparent Violation Cover Letter IR 05000400/20243012023-05-15015 May 2023 Notification of Licensed Operator Initial Examination 05000400/2024301 IR 05000400/20230012023-05-10010 May 2023 Integrated Inspection Report 05000400 2023001 IR 05000400/20234042023-05-0404 May 2023 Cyber Security Inspection Report 05000400/2023404 ML23118A0762023-05-0101 May 2023 Approval for Use of Specific Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI ML23118A1392023-04-28028 April 2023 Submittal of Updated Final Safety Analysis Report (Amendment 65), Technical Specification Bases Revision, Report of Changes Pursuant to 10 CFR 50.59 and Summary of Commitment Changes IR 05000400/20234032023-04-0505 April 2023 Security Baseline Inspection Report 05000400/2023403 IR 05000400/20230102023-03-15015 March 2023 Comprehensive Engineering Team Inspection (CETI) Inspection Report 05000400/2023010 ML22332A4932023-03-10010 March 2023 William States Lee III 1 and 2 - Issuance of Amendments Regarding the Relocation of the Emergency Operations Facility IR 05000400/20220062023-03-0101 March 2023 Annual Assessment Letter for Shearon Harris Nuclear Power Plant - NRC Inspection Report 05000400/2022006 ML23033A5272023-02-0808 February 2023 Correction of Typographical Errors Incurred During Issuance of License Amendment No. 196 IR 05000400/20220042023-02-0707 February 2023 Integrated Inspection Report 05000400/2022004 ML23020A1252023-01-23023 January 2023 Notification of Target Set Inspection and Request for Information (NRC Inspection Report 05000400/2023403) ML22096A0032022-11-18018 November 2022 McGuire Nuclear Station and Shearon Harris Nuclear Power Plant Authorization of RA-19-0352 Regarding Use of Alternative for RPV Head Closure Stud Examinations ML22256A2532022-11-14014 November 2022 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-541, Rev. 2 IR 05000400/20220032022-11-10010 November 2022 Integrated Inspection Report 05000400/2022003 IR 05000400/20223012022-11-0202 November 2022 NRC Operator License Examination Report 05000400/2022301 ML22271A6202022-09-29029 September 2022 Notification of Shearon Harris Nuclear Power Plant Comprehensive Engineering Team Inspection - U.S. Nuclear Regulatory Commission Inspection Report 05000400/2023010 ML22258A1262022-09-14014 September 2022 NRC Operator Licensing Examination Approval 05000400/2022301 ML22242A0022022-09-12012 September 2022 Issuance of Amendments to Adopt TSTF 569, Revision 2, Revise Response Time Testing Definition ML22227A0682022-09-0202 September 2022 Alternative to Certain Inservice Testing Requirements in the American Society of Mechanical Engineers Code for Operation and Maintenance for Certain Target Rock Solenoid Valves IR 05000400/20220052022-08-24024 August 2022 Updated Inspection Plan for Shearon Harris Nuclear Power Plant (Report 05000400/2022005) IR 05000400/20224032022-08-23023 August 2022 Security Baseline Inspection Report 05000400/2022403 ML22126A0082022-08-0909 August 2022 Issuance of Amendment No. 194 Revise Technical Specifications Related to Reactor Protection System Instrumentation P7 IR 05000400/20220022022-08-0505 August 2022 Integrated Inspection Report 05000400/2022002 ML22161B0332022-07-28028 July 2022 Issuance of Amendment No. 193 Regarding Revision of Surveillance Requirements to Remove Shutdown Limitation IR 05000400/20220112022-07-20020 July 2022 Biennial Problem Identification and Resolution Inspection Report 05000400 2022011 IR 05000400/20224022022-06-30030 June 2022 Material Control and Accounting Program Inspection Report 05000400/2022402 (OUO Removed) IR 05000400/20220102022-06-13013 June 2022 Design Basis Assurance Inspection (Programs) Inspection Report 05000400/2022010 ML22138A4012022-05-26026 May 2022 Project Manager Reassignment ML22101A2822022-05-0606 May 2022 Regulatory Audit Summary Related to the Review of License Amendment Regarding Revising the Flood Hazard Protection Scheme IR 05000400/20220012022-05-0404 May 2022 Integrated Inspection Report 05000400/2022001 IR 05000400/20224012022-03-24024 March 2022 Security Baseline Inspection Report 05000400/2022401 ML22020A0072022-03-10010 March 2022 Issuance of Amendment No. 192 Regarding Removal of Extraneous Content and Requirements from the Renewed Facility Operating License and Technical Specifications ML22010A2812022-03-0404 March 2022 Issuance of Amendments to Adopt TSTF-577, Rev. 1 Revised Frequencies for Steam Generator Tube Inspections (EPID L-2021-LLA-0161 IR 05000400/20210062022-03-0202 March 2022 Annual Assessment Letter for Shearon Harris Nuclear Power Plant (Report No. 05000400/2021006) ML21351A4722022-02-10010 February 2022 Issuance of Amendment No. 190 Regarding Revision to Containment Spray Nozzle Test Frequency IR 05000400/20210042022-02-0404 February 2022 Integrated Inspection Report 05000400/2021004 ML22034A5352022-02-0202 February 2022 Notification of Licensed Operator Initial Examination 05000400/2022301 2024-01-30
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML24025A1592024-01-25025 January 2024 NRR E-mail Capture - Shearon Harris Nuclear Power Plant, Unit 1 - Request for Additional Information - Rvi AMP and Inspection Plan (L-2023-LLL-0016) ML23151A3482023-05-30030 May 2023 Duke Fleet - Request for Additional Information Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) ML23142A2732023-05-22022 May 2023 Duke Fleet - Request for Additional Information Proposed Alternative for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1) ML23082A0432023-03-23023 March 2023 002 Radiation Safety Baseline Inspection Information Request Final ML23020A1252023-01-23023 January 2023 Notification of Target Set Inspection and Request for Information (NRC Inspection Report 05000400/2023403) ML22115A1412022-04-25025 April 2022 NRR E-mail Capture - Duke Common EOF Relocation - Request for Addition Information ML21354A8612021-12-15015 December 2021 NRR E-mail Capture - Request for Additional Information - Duke Fleet Request RA-19-0352 - Alternative for RPV Closure Stud Exams (L-2020-LLR-0156) ML21258A3652021-09-15015 September 2021 Notification of an NRC Fire Protection Team Inspection (FPTI) (NRC Inspection Report 05000400/2021011) and Request for Information (RFI) ML21172A2432021-06-21021 June 2021 NRR E-mail Capture - Request for Additional Information - Harris RA-20-0252 - LAR to Remove Extraneous Requirements from OL and TS (L-2021-LLA-0027) ML21036A1142021-02-0505 February 2021 NRR E-mail Capture - Request for Additional Information - Harris - Relief Request RA-20-0312 - SW Pinhole Leak (L-2020-LLR-0143) ML21049A2632021-02-0404 February 2021 NRR E-mail Capture - Request for Additional Information - Duke Energy Fleet License Amendment Request to Revise Emergency Plan ML21032A0492021-02-0101 February 2021 NRR E-mail Capture - Request for Additional Information - Duke Fleet RA-20-0263 - Use of Later ASME B&Pv, XI for Repair - Replacement (L-2020-LLR-0124) ML20323A4072020-11-18018 November 2020 NRR E-mail Capture - Request for Additional Information - Brunswick License Exemption Request from 10CFR73 Annual Force on Force Exercise Requirements (EPIC L-2020-LLE-0180) ML20297A3072020-10-13013 October 2020 NRR E-mail Capture - Request for Additional Information - Shearon Harris Nuclear Power Plant, Unit 1 - RCS Flowrate Reduction/Lbloca LAR ML20274A0462020-09-29029 September 2020 Request for Additional Information Regarding License Amendment Request to Adopt TSTF-505, Revision 2 ML20247J3822020-09-0303 September 2020 Request for Additional Information - Shearon Harris Nuclear Power Plant, Unit 1 - Revise TS Related to Accident Monitoring and RFO Instrumentation ML19331A4002019-11-27027 November 2019 Request for Additional Information Regarding Licensing Action to Modify the Departure from Nucleate Boiling Ratio Safety Limit to Address Transition to New Fuel Type ML19204A2682019-07-23023 July 2019 NRR E-mail Capture - Shearon Harris Nuclear Power Plant, Unit 1 Request for Additional Information for the Escw System TS AOT Extension and Removal of an Expired Note in TS Risk Informed LAR (L-2019-LLA-0025) ML19136A2712019-05-28028 May 2019 Supplemental Information Needed for Acceptance of Requested Licensing Action Regarding License Amendment Request to Modify the Departure from Nucleate Boiling Ratio Safety Limit to Address Transition to New Fuel Type ML19060A0912019-03-18018 March 2019 Request for Additional Information Regarding License Amendment Request to Adopt 10 CFR 50.69, Risk Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors ML19011A1372019-01-10010 January 2019 NRR E-mail Capture - Duke Energy Fleet RAIs - Relief Request 18-GO-001 - Proposed Alternative for Depth Sizing Qualification Examination of Welds (L-2018-LLR-0117) ML19007A3422018-12-21021 December 2018 NRR E-mail Capture - Duke Energy Fleet Draft RAIs - Relief Request 18-GO-001 - Proposed Alternative for Depth Sizing Qualification Examination of Welds (L-2018-LLR-0117) ML18332A4392018-11-28028 November 2018 NRR E-mail Capture - Shearon Harris Nuclear Power Plant, Unit 1 Request for Additional Information for EAL Scheme Changes ML18337A1272018-11-28028 November 2018 NRR E-mail Capture - Shearon Harris Nuclear Power Plant, Unit 1 Request for Additional Information Regarding the Rts/Esfas Trip Setpoints Modification LAR ML18264A0282018-10-0909 October 2018 RAI Regarding License Amendment Request to Adopt 10 CFR 50.69, Risk Informed Categorization Aad Treatment of Structures, Systems and Components for Nuclear Power Reactors ML18145A1812018-06-18018 June 2018 Request for Additional Information, License Amendment Request to Revise Updated Final Safety Analysis Report to Incorporate Tornado Missile Risk Evaluator Methodology Into Licensing Basis RA-18-0011, Response to Request for Supplemental Information Regarding Duke Energy'S Response to GL 2016-01 Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools2018-05-30030 May 2018 Response to Request for Supplemental Information Regarding Duke Energy'S Response to GL 2016-01 Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools ML18116A1052018-04-25025 April 2018 NRR E-mail Capture - Harris/Robinson RAIs - Change Technical Specifications to Support Performance of Core Reload Design and Safety Analyses (L-2017-LLA-0356) ML18108A7602018-04-18018 April 2018 NRR E-mail Capture - Harris/Robinson Draft RAIs - Change Technical Specifications to Support Performance of Core Reload Design and Safety Analyses (L-2017-LLA-0356) ML18058B2242018-02-26026 February 2018 Emailed Radiation Safety RFI ML18005A5482018-01-0808 January 2018 Request for Additional Information Regarding License Amendment Request for Spent Fuel Storage Pool Criticality Analyses (CAC No. MF9996; EPID L-2017-LLA-0303) ML17345A8772017-12-11011 December 2017 NRR E-mail Capture - Harris and Robinson Supplemental RAI - LAR to Adopt DPC-NE-3009-P, Revision 0, Thermal-Hydraulic Models for Transient Analysis, (L-2016-LLA-0012) ML17339A0722017-12-0404 December 2017 NRR E-mail Capture - Subject: Harris and Robinson Draft Supplemental RAIs - LAR to Adopt DPC-NE-3009-P, Revision 0, Thermal-Hydraulic Models for Transient Analysis, (L-2016-LLA-0012) ML17289A3062017-10-23023 October 2017 Shearon Harris Nuclear Plant, Unit 1 - Request for Additional Information Regarding License Amendment Request Proposing Changes to Emergency Diesel Generator Technical Specifications Surveillance Requirements (CAC No. MF9828; EPID L-2017-LLA-0244) ML17250B0172017-09-18018 September 2017 Shearon Harris, Unit 1 - Request for Additional Information Re: License Amendment Request Proposing New Set of Fission Gas Gap Release Fractions for High Burnup Fuel Rods that Exceed the LHGR Limit Detailed in RG 1.183, Table 3 (CAC No. MF9740) ML17241A0182017-08-30030 August 2017 Supplemental Information Needed for Acceptance of Requested Licensing Action Regarding Spent Fuel Storage Pool Criticality Analyses ML17192A4842017-07-11011 July 2017 NRR E-mail Capture - Duke Energy Fleet RAIs Alternative for Reactor Pressure Vessel Flange Threads Examination (MF9513 to MF9521) ML17123A1332017-05-0909 May 2017 Shearon Harris Nuclear Plant, Unit 1 - Request for Additional Information Re: License Amendment Request to Relocate Specific TS Parameters to the COLR, Remove Reference to a Plant Procedure as it Pertains to the COLR in TSs, etc. (CAC No. MF8894) ML17109A2912017-04-19019 April 2017 NRR E-mail Capture - Shearon Harris Nuclear Power Plant, Unit 1 Final Request for Additional Information Concerning LAR to Adopt TSTF-339, TSTF-5 and Other Administrative Changes ML16363A0112016-12-27027 December 2016 Notification of Shearon Harris Nuclear Power Plant Design Basis Assurance Inspection - U.S. Nuclear Regulatory Commission Inspection Report 05000400/2017007 ML16335A0462016-12-0606 December 2016 Shearon Harris Nuclear Power Plant, Unit 1 - Request for Additional Information Regarding License Amendment Request to Modify Diesel Fuel Oil Testing Surveillance Requirements (CAC No. MF7775) ML16288A0782016-10-26026 October 2016 Shearon Harris Nuclear Power Plant, Unit 1, and H.B. Robinson Steam Electric Plant, Unit No. 2 - Redacted, Request for Additional Information Re: Request to Adopt DPC-NF-2010 and DPC-NF-2011 Nuclear Design Methodology (CAC Nos. MF7693 and MF7694) ML16288A0042016-10-26026 October 2016 Shearon Harris Nuclear Plant, Unit 1 - Request For Additional Information Regarding License Amendment Request To Relocate The Explosive Gas Mixture And Liquid Holdup Tanks Technical Specifications Requirements (CAC No. MF8067) ML16223A4172016-08-0808 August 2016 Notification of Inspection and Request for Information ML16209A2642016-08-0202 August 2016 Shearon Harris Nuclear Plant, Unit 1 - Second Request For Additional Information Regarding License Amendment Request For A Temporary Change To Technical Specifications For The 'A' Emergency Service Water Pump Replacement (CAC No. MF7017) ML16028A1972016-02-0808 February 2016 Request for Additional Information Regarding License Amendment Request for a Temporary Change to Technical Specifications for the 'A' Emergency Service Water Pump Replacement ML15344A0302015-12-17017 December 2015 Request for Additional Information Application to Revise Technical Specifications for Methodology Report DPC-NE-2005-P, Revision 5, Thermal Hydraulic Statistical Core Design Methodology (MF5872/MF5873) ML15320A3862015-11-19019 November 2015 RAI LAR to Adopt TSTF-523 ML15314A3592015-11-10010 November 2015 Duke Energy Draft RAIs Request to Adopt TSTF-523 (CAC Nos. MF6413-MF6422) ML15314A3562015-11-10010 November 2015 E-mail from J. Whited to A. Zaremba Duke Energy Draft RAIs License Amendment Request to Adopt TSTF-523 (CAC Nos. MF6413-MF6422) 2024-01-25
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 26, 2015 Mr. Benjamin C. Waldrep, Site Vice President Shearon Harris Nuclear Power Plant 5413 Shearon Harris Rd.
New Hill, NC 27562-0165
SUBJECT:
SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO REVISE EMERGENCY ACTION LEVEL SCHEME TO ONE BASED ON REVISION 6 OF NUCLEAR ENERGY INSTITUTE 99-01, "DEVELOPMENT OF EMERGENCY ACTION LEVELS FOR NON-PASSIVE REACTORS" (CAC NO. MF6196)
Dear Mr. Waldrep:
By letter dated April 30, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15126A083), 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. 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 No. ML12326A805).
The staff has reviewed the licensee's submittal and determined that additional information is needed in order to complete its review. The enclosed Request for Additional Information (RAI) was e-mailed to the licensee in draft form on October 6, 2015. A teleconference call was held on October 15, 2015, in which the draft RAI was discussed. A response to the enclosed RAI is to be provided by November 20, 2015. Please note that if you do not respond to this letter by the agreed-upon date or provide an acceptable alternate date in writing, we may deny your application for amendment under the provisions of Title 1O of the Code of Federal Regulations, Section 2.108.
B. Waldrep If you have any questions, please call me at 301-415-2760 or Martha.Barillas@nrc.gov.
Sincerely,
~::mas, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-400
Enclosure:
Request for Additional Information cc w/enclosure: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO REVISE EMERGENCY ACTION LEVEL SCHEME TO ONE BASED ON REVISION 6 TO NUCLEAR ENERGY INSTITUTE 99-01, DEVELOPMENT OF EMERGENCY ACTION LEVELS FOR NON-PASSIVE REACTORS DUKE ENERGY PROGRESS, INC.
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 No. 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 No. ML12326A805).
The requests for additional information (RAls) listed below, in regards to Enclosure 3, "Emergency Action Level Basis Document, are needed to support the Nuclear Regulatory Commission staff's continued technical review of the proposed EAL scheme change.
RAl-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 developer's 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, 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:
Enclosure
o For the proposed RA 1.3, the NEI 99-01 basis discussion includes reference to gaseous radioactivity while the proposed RA 1.3 only applies to liquid effluent samples.
o For the proposed RA 1.4, 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.
RAl-HNP-2 Section 4.3, "Instrumentation Used for EALs," to NEI 99-01, Revision 6, states in part: "Scheme developers should ensure that specified values used as EAL setpoints are within the calibrated range of the referenced instrumentation." 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 setpoinVindication.
RAl-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:
- Emergency Classification Level,
- Fission Product Barrier Threshold, and
- 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.
RAl-HNP-4 For EALs RA 1.1, 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. Provide justification that supports the changes in the Table R-1 values from the previous values to the current values.
RAl-HNP-5 For EAL RU2.1, site-specific refueling pathway level indication is not provided per NEI 99-01, Revision 6. 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.
RAl-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.
RAl-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. Provide further justification for this deviation or revise accordingly based on NEI 99-01, Revision 6 (EAL AA2).
RAl-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. 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.
RAl-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. Provide further justification, or revise EAL CS1 .3 and CG1 .2 accordingly consistent with NEI 99-01, Revision 6.
- b. HNP added, "Visual observation of UNISOLABLE RCS [reactor coolant system]
leakage," to the EAL wording. 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. Provide further justification, or revise accordingly consistent with NEI 99-01, Revision 6.
RAl-HNP-10 For EALs CU2.1, SU 1.1 and SA 1.1, no list/table was provided with the proposed EALs that shows off-site and on-site alternating current (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. Provide justification as to why list/table of AC power supplies was not provided, or revise accordingly.
RAl-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. Provide justification for this deviation, or revise accordingly consistent with NEI 99-01, Revision 6.
RAl-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. Provide justification for this deviation, or revise accordingly consistent with NEI 99-01, Revision 6.
RAl-HNP-13 Concerning EALs CUS.1 and SU7.1, address the following:
- a. The DEMNET System is provided as a communication method to the offsite response organizations (OROs). 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.
RAl-HNP-14 For EAL CA6.1 and SA9.1, the HNP Basis discussion for seismic events refers to a discussion under EAL HU2.1. 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.
RAl-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. 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.
RAl-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. Provide further justification for exclusion of this Appendix R basis information, or revise accordingly.
RAl-HNP-17 No clear start time is provided for EALs HA6.1 and HS6.1. 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.
RAl-HNP-18 For IC RC1, Fission Product Barrier 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.
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. Provide justification for this change or revise accordingly.
ML15289A590 *via email NRR-048 NRR/DORL/LPL2- NRR/DORL/LPL2-OFFICE NRR/DORL/LPL2-2/LA NSIR/DPR/DDEP*
2/PM 2/BC NAME MBarillas BClayton JAnderson SHelton DATE 10/21/15 10/21/15 9/23/15 10/23/15 NRR/DORL/LPL2-OFFICE 2/PM NAME MBarillas DATE 10/26/15