ML17289A306

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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)
ML17289A306
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 10/23/2017
From: Martha Barillas
Plant Licensing Branch II
To: Hamilton T
Duke Energy Progress
Barillas M DORL/LPL2-2 301-415-2760
References
CAC MF9828, EPID L-2017-LLA-0244
Download: ML17289A306 (6)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Ms. Tanya M. Hamilton Site Vice President Shearon Harris Nuclear Power Plant 5413 Shearon Harris Road M/C HNP01 New Hill, NC 27562-0165 October 23, 2017

SUBJECT:

SHEARON HARRIS NUCLEAR POWER 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)

Dear Ms. Hamilton:

By application dated June 5, 2017 (Agencywide Documents Access and Management System Accession No. ML17156A216), Duke Energy Progress, LLC (the licensee) submitted a license amendment request for the Shearon Harris Nuclear Power Plant, Unit 1 (HNP), requesting changes to the HNP Technical Specifications. The changes would restrict the steady-state voltage and frequency limits for emergency diesel generator (EOG) operation to ensure that accident mitigation equipment can perform as designed. The proposed changes would also increase the voltage limit for the EOG full load rejection test.

The U.S. Nuclear Regulatory Commission staff has determined that additional information is needed in order to complete its review. The enclosed request for additional information was e-mailed to the licensee in draft form on October 2, 2017, and a clarification call was held on October 4, 2017. Please note that if a response to this letter is not received by November 2, 2017, or an acceptable alternate date is not provided in writing, we may deny the application for amendment under the provisions of Title 10 of the Code of Federal Regulations Section 2.108, "Denial of application for failure to supply information."

If you have any questions, please contact me at 301-415-2760 or by e-mail to Martha. Baril!as@nrc.gov.

Docket No. 50-400

Enclosure:

Request for Additional Information cc w/enclosure: Distribution via Listserv Sincerely, Martha Barillas, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

DUKE ENERGY PROGRESS LLC SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 DOCKET NUMBER 50-400 REQUEST FOR ADDITIONAL INFORMATION REGARDING A LICENSE AMENDMENT REQUEST PROPOSING CHANGES TO EMERGENCY DIESEL GENERATOR TECHNICAL SPECIFICATIONS SURVEILLANCE REQUIREMENTS CAC NUMBER MF9828 EPID L-2017-LLA-0244 By application dated June 5, 2017 (Agencywide Documents Access and Management System Accession Number ML17156A216), Duke Energy Progress LLC, the licensee, requested changes to the Shearon Harris Nuclear Power Plant, Unit 1 (HNP) Technical Specifications.

The changes would restrict the steady-state voltage and frequency limits for emergency diesel generator (EOG) operation to ensure that accident mitigation equipment can perform as designed. The proposed changes would also increase the voltage limit for the EDG full load rejection test The U.S. Nuclear Regulatory Commission staff has determined the following request for additional information (RAI) is needed in order to complete its review.

Applicable Regulations:

Title 10 of the Code of Federal Regulations (10 CFR) 50.36, "Technical specifications,"

provides the requirements of the contents of Technical Specifications. Paragraph 50.36(c)(3) of 1 O CFR 50.36 requires, in part, establishing Surveillance Requirements to assure that the limiting conditions for operation will be met.

The 10 CFR 50.46, "Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors," requirements related to the acceptance criteria for the performance of the emergency core cooling system (ECCS).

General Design Criterion (GDC) 10, "Reactor design," and GDC 15, "Reactor coolant system design," requirements related to the reactor coolant system pressure boundary and the integrity of the fuel during anticipated operational occurrences.

GDC 17, "Electric power systems," related to nuclear power plants having onsite and offsite electric power systems to permit the functioning of structures, systems, and components that are important to safety.

GDC 34, "Residual heat removal," states that a system to remove residual heat shall be provided. The system safety function shall be to transfer fission product decay heat and other residual heat from the reactor core at a rate such that specified acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary are not exceeded. The GDC requires, in part, that capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) the system safety function can be accomplished, assuming a single failure.

Enclosure GDC 35, "Emergency core cooling," states that a system to provide abundant emergency core cooling shall be provided. The system safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that (1) fuel and clad damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts. The GDC also requires that suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.

RAI 1

The licensee is proposing to revise the HNP Technical Specification EOG voltage limit from 6900 plus or minus(+/-) 690 volts to 6900 +/- 276 volts, and frequency limit from 60 +/- 1.2 Hertz (Hz) to 60 +/- 0.48 Hz. In section 3.5 of Attachment 1 to the license amendment request {LAR),

the licensee stated that the final safety analysis report (FSAR) analyses of record (AOR) remain bounding with the revised EOG voltage and frequency limits. However, the FSAR AOR may be affected by the revised EOG voltage and frequency limits through their impact to the performance characteristics of the safety grade equipment and systems credited in the AOR.

Provide the following additional information to support the validity of the FSAR AOR with the new EOG voltage and frequency limits:

RAI 2

a) Identify the loss-of-coolant accident (LOCA) and non-LOCA events from the FSAR Chapter 15 analyses crediting the equipment and systems powered by the EOG.

b) For each of the events listed in a), identify the equipment and systems powered by the EOG and credited in the FSAR AOR. The requested information should include the input values that represent the performance characteristics of the identified equipment and systems that were credited in the AOR. For example, the input values should include the flow rates of ECCS pumps and emergency feedwater pumps, isolation valve closure time, automatic actuation delay time, power-operated relief valve (PORV) delay and lifting time, etc.

c) Provide the new input values representing the performance characteristics of the identified equipment and systems powered by the EOG based on the revised voltage and frequency limits to demonstrate the Chapter 15 analyses identified in a) remain bounding with the new EOG voltage and frequency proposed values. The new input values should include the flow rates of ECCS pumps and emergency feedwater pumps, isolation valve closure time, automatic actuation delay time, PORV delay and lifting time, etc. Provide a discussion of the methodology used to determine the new input values based on the new EOG voltage and frequency limits and address the adequacy of the methodology used.

It is stated in Section 3.3 of the LAR, "The engineering evaluation and calculations demonstrate that the proposed frequency tolerance of+/- 0.8°/o ensures safety-related pumps meet their design functions, and the accident analyses inputs and assumptions are maintained. The available net positive suction head and the required available net positive suction head of the safety-related pumps was considered for this evaluation." Provide a list of the safety-related pumps that were evaluated. For each pump, provide the following, in order to demonstrate they will continue to perform their design function with the EOG proposed frequency tolerance:

(1) flow rate at 59.52 Hz, 60 Hz, and 60.48 Hz; (2) the discharge pressure at 59.52 Hz, 60 Hz, and 60.48 Hz; and (3) required net positive suction head and available net positive suction head at 59.52 Hz, 60 Hz, and 60.48 Hz.

It is stated in Section 3.4.5 of the LAR, "In addition, the impact to the Auxiliary Feedwater (AFW), Emergency Service Water (ESW), Component Cooling Water (CCW), Spent Fuel Pool Cooling (SFPC), Boric Acid Transfer (BAT), and ESCW systems have been evaluated, and the conclusion reached for each of these systems is that equipment functions and limits are maintained with the+/- 0.8°/o frequency tolerance value." Provide the following data that was evaluated for each pump in these systems: (1) flow rate at 59.52 Hz, 60 Hz, and 60.48 Hz;

{2) the discharge pressure at 59.52 Hz, 60 Hz, and 60.48 Hz; and (3) required net positive suction head and available net positive suction head at 59.52 Hz, 60 Hz, and 60.48 Hz. Also provide the minimum required flow rate, the minimum required discharge pressure, and any low-pressure alarm settings for each pump.

In its LAR, the licensee did not provide the following information that addresses EOG performance for the EOG new proposed frequency. For the EOG lube oil pump and jacket water pump on the EOG skid, provide the (1) flow rate at 59.52 Hz, 60 Hz, and 60.48 Hz, (2) the discharge pressure at 59.52 Hz, 60 Hz, and 60.48 Hz, and (3) required net positive suction head and available net positive suction head at 59.52 Hz, 60 Hz, and 60.48 Hz. Also provide the minimum required flow rate, the minimum required discharge pressure, and any low-pressure alarm settings for each pump.

In order to demonstrate that the EOG fuel oil consumption is not affected by the proposed frequency tolerances, for the fuel oil transfer pump, provide the (1) flow rate at 59.52 Hz, 60 Hz, and 60.48 Hz, (2) the discharge pressure at 59.52 Hz, 60 Hz, and 60.48 Hz, and (3) required net positive suction head and available net positive suction head at 59.52 Hz, 60 Hz, and 6048 Hz Discuss whether or not any relief valves on the affected pumps' discharge piping will lift due to the higher discharge pressure when the EOG is operating at 60.48 Hz. If a relief valve will lift, explain how the affected pumps will continue to perform their design function at the higher frequency.

ML17289A306 OFFICE NRR/DORLILPL2-2/PM NAME MBarillas DATE 1012312017 OFFICE NRRIDSS/SRXBIBC*

NAME EOesterle DATE 7105117 RidsNrrLABClayton Resource RidsNrrDeEPNB Resource RidsNrrDssSrxb Resource RWolfgang, NRR SSun, NRR

  • bv e-mail NRR/DORL/LPL2-21LA NRRIDE/EPNB/BC*

BClavton DAllev 1012312017' 9/14117 NRR/DORLILPL2-2/BC NRR/DORLILPL2-2/PM UShooo MBarillas 1012312017 10123/2017