ML18282A224

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Regulatory Audit Summary Regarding License Amendment Requests to Adopt 10 CFR 50.69
ML18282A224
Person / Time
Site: Harris, Brunswick  Duke Energy icon.png
Issue date: 11/14/2018
From: Martha Barillas
Plant Licensing Branch II
To: Capps S
Duke Energy Corp
Barillas M, 415-2760
References
EPID L-2018-LLA-0008, EPID L-2018-LLA-0034
Download: ML18282A224 (8)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 14, 2018 Mr. Steven Capps Senior Vice President Nuclear Corporate Duke Energy Corporation 526 South Church Street, EC-07H Charlotte, NC 28202

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2, AND SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - REGULATORY AUDIT

SUMMARY

REGARDING LICENSE AMENDMENT REQUESTS TO ADOPT 10 CFR 50.69, "RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS FOR NUCLEAR POWER PLANTS" (EPID L-2018-LLA-0008 AND EPID L-2018-LLA-0034)

Dear Mr. Capps:

By letters dated January 10, 2018, and February 1, 2018 (Agencywide Documents Access and Management System Accession Nos. ML18010A344 and ML180338768, respectively), Duke Energy Progress, LLC (Duke Energy) submitted license amendment requests for Brunswick Steam Electric Plant, Units 1 and 2, and Shearon Harris Nuclear Power Plant, Unit 1. The proposed amendments would modify the licensing basis to allow for the implementation of the provisions of Section 50.69, "Risk-informed categorization and treatment of structures, systems and components for nuclear power plants," of Title 10 of the Code of Federal Regulations.

To support its review, the U.S. Nuclear Regulatory Commission staff conducted a regulatory audit that started July 17, 2018, and ended July 19, 2018, at the Duke Energy Corporate office in Charlotte, North Carolina. The staff reviewed documents and held discussions with members of Duke Energy. The regulatory audit summary, list of participants, and list of documents reviewed during the audit are enclosed.

S. Capps

"'. 2 -

If you have any questions, please contact me at 301-415-2760 or Martha.Barillas@nrc.gov.

Docket Nos. 50-325, 50-324, and 50-400

Enclosure:

1. Regulatory Audit Summary
2. List of Participants
3. List of Documents Reviewed During Audit cc: Listserv Mr. William R. Gideon Vice President Brunswick Steam Electric Plant Duke Energy Progress, LLC 8470 River Road, SE (M/C BNP001)

Southport, NC 28461 Ms. Tanya M. Hamilton Site Vice President Shearon Harris Nuclear Power Plant Duke Energy 5413 Shearon Harris Road M/C HNP01 New Hill, NC 27562-0165 Sincerely, Martha Barillas, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY AUDIT

SUMMARY

FOR JULY 17, 2018 - JULY 19, 2018 RE: LICENSE AMENDMENT REQUESTS TO ADOPT 10 CFR 50.69 "RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS FOR NUCLEAR POWER PLANTS" DUKE ENERGY PROGRESS, LLC BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NOS. 50-325, 50-324, AND 50-400

1.0 BACKGROUND

By letters dated January 10, 2018 (Reference 1 ), and February 1, 2018 (Reference 2), Duke Energy Progress, LLC (Duke Energy or the licensee) submitted license amendment requests (LARs) for Brunswick Steam Electric Plant, Units 1 and 2 (Brunswick), and Shearon Harris Nuclear Power Plant, Unit 1 (Shearon Harris). The proposed amendments would modify the licensing bases to allow for the implementation of the provisions of Section 50.69, "Risk-informed categorization and treatment of structures, systems and components for nuclear power plants," of Title 10 of the Code of Federal Regulations (10 CFR).

This voluntary risk-informed alternative rule allows power reactor licensees and license applicants to apply a risk-informed categorization process to categorize structures, systems, and components (SSCs) based on their safety significance. The final rule was published in the Federal Register on November 22, 2004 (69 FR 68008) (Reference 3). The U.S. Nuclear Regulatory Commission (NRC or the Commission) staff issued Regulatory Guide 1.201, Revision 1, "Guidelines for Categorizing Structures, Systems, and Components in Nuclear Power Plants According to Their Safety Significance," in May 2006 (Reference 4).

The NRC staff determined that a regulatory audit of Duke Energy's Brunswick and Shearon Harris 10 CFR 50.69 applications should be conducted in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits," for the staff to gain a better understanding of the licensee's proposed risk-informed categorization process. The regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. The regulatory audit is conducted with the intent to gain understanding, to verify information, and/or to identify information that will require docketing to support the basis of a licensing or regulatory decision. Performing a regulatory audit of the licensee's information is expected to assist the NRC staff in efficiently conducting its review or gain insights on the licensee's processes or procedures. Information that the NRC staff relies upon to make the safety determinations must be submitted on the docket. However, the NRC staff may review supporting information retained as records under 10 CFR 50.71 and/or 10 CFR 54.37, which, although not required to be submitted as part of the licensing action, would help the staff better understand the licensee's submitted information.

The purpose of the regulatory audit was to gain an understanding of the information needed to support the staff's licensing decision regarding the Brunswick and Shearon Harris LARs and to develop appropriate requests for additional information (RAls), as needed. The information submitted in support of the Brunswick and Shearon Harris LARs is under review, and additional information needed to support the LAR review will be formally communicated by the NRC staff using the RAI process in accordance with NRR Office Instruction LIC-101, "License Amendment Review Procedures."

The regulatory audit took place from July 17, 2018, to July 19, 2018, at the Duke Energy office in Charlotte, North Carolina. The regulatory audit was conducted to review the current program for compliance with the Commission's requirements in 10 CFR 50.69.

2.0 AUDIT ACTIVITIES The NRC audit team consisted of four NRC staff members and two NRC Pacific Northwest National Laboratory contractors. Enclosure 2 provides a list of attendees from NRC, Pacific Northwest National Laboratory, and Duke Energy. Enclosure 3 contains a list of documents reviewed by the team during the audit.

The regulatory audit commenced on July 17, 2018, with the NRC audit team and the licensee's staff and contractors. The audit focused on the Brunswick's and Shearon Harris's Internal Events Probabilistic Risk Assessment (PRA), Internal Flooding PRA, and Fire PRA models, in addition to the overall 1 O CFR 50.69 categorization process, with a specific concentration on the Facts and Observations (F&O) report and PRA acceptability. The main purpose of this audit was to gain an understanding of the information needed to support the NRC staff's licensing decision and to identify RAls, as needed, using the RAI process in accordance with NRR Office Instruction LIC-101.

The first half of the audit focused on review of Brunswick's technical presentations, interactions, and audit questions. The second half of the audit concentrated on similar activities for Shearon Harris. The staff reviewed the licensee's information to facilitate review of the submittals, including the technical acceptability of the PRAs.

During the audit, team members participated in technical discussions to meet the audit objectives listed in the audit plan (Reference 5) and discussed questions as they pertained to the Brunswick and Shearon Harris applications (Reference 6).

Technical discussions focused on the following major review areas: (1) technical acceptability of PRA model insights, 2) overview of categorization process, and 3) review of F&O reports. In addition, the NRC staff asked about FLEX equipment included in the PRA model. The NRC staff identified information that is needed as part of the LAR review and will be formally sent as RAls.

At the conclusion of the audit, the team participated in a summary exit meeting with the Duke Energy audit team on July 19, 2018. The NRC staff provided a brief conclusion of the audit objectives that were met and details on the path forward. There were no open items needing further clarification and no deviation from the audit plan. Enclosure 3 contains a list of documents reviewed by the team during the audit.

3.0 RESULTS OF THE AUDIT The RAls were issued to the licensee on September 19, 2018, with a request to submit its response by October 19, 2018, for Shearon Harris, and on October 9, 2018, with a request to submit its response by November 2, 2018 for Brunswick (Reference 7 and Reference 8).

4.0 REFERENCES

1.

Letter from W. Gideon, Duke Energy Progress, LLC, to NRC, "Brunswick Steam Electric Plant, Units 1 and 2 - Application to Adopt 10 CFR 50.69, 'Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) for Nuclear Power Reactors,"' dated January 10, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18010A344).

2.

Letter from T. Hamilton, Duke Energy Progress, LLC, to NRC, "Shearon Harris Nuclear Power Plant, Unit 1 - Application to Adopt 10 CFR 50.69, 'Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) for Nuclear Power Reactors,"' dated February 1, 2018 (ADAMS Accession No. ML18033B768).

3.

Federal Register Notice (69 FR 68008), "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Plants," dated November 22, 2004 (ADAMS Accession No. ML042960073).

4.

NRC Regulatory Guide 1.201, Revision 1, "Guidelines for Categorizing Structures, Systems, and Components in Nuclear Power Plants according to Their Safety Significance," issued May 2006 (ADAMS Accession No. ML061090627).

5.

Letter from M. Barillas, NRC, to S. Capps, Duke Energy Corporation, "Brunswick Steam Electric Plant, Units 1 and 2, and Shearon Harris Nuclear Power Plant, Unit 1 - Audit Plan RE: Application to Adopt 10 CFR 50.69, 'Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) for Nuclear Power Reactors,"' dated July 2, 2018 (ADAMS Accession No. ML18180A418).

6.

Letter from M. Barillas, NRC, to S. Capps, Duke Energy Corporation, "Brunswick Steam Electric Plant, Units 1 and 2, and Shearon Harris Nuclear Power Plant, Unit 1 - Audit Plan Questions RE: Application to Adopt 10 CFR 50.69, 'Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) for Nuclear Power Reactors,"' dated July 11, 2018 (ADAMS Accession No. ML18191A997).

7.

Letter from M. Barillas, NRC, to T. Hamilton, Shearon Harris Nuclear Power Plant, "Shearon Harris Nuclear Power Plant, Unit 1 - Request for Additional Information Regarding License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) for Nuclear Power Reactors," dated October 9, 2018 (ADAMS Accession No. ML18264A028).

8.

E-mail from D. Galvin, NRC, to Brunswick Steam Electric Plant, Units 1 and 2 - Request for Additional Information Regarding License Amendment Request to Adopt 1 O CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) for Nuclear Power Reactors," dated October 5, 2018 (ADAMS Accession No. ML18282A149).

List of Participants U.S. Nuclear Regulatory Commission Audit Team Jonathan Evans Leslie Fields Michael Levine Brandon Hartle Acting Branch Chief Team Leader Brunswick Technical Lead Shearon Harris Technical Lead Pacific Northwest National Laboratory Team Steve Short Mark Wilk PRA/Shearon Harris PRA/Brunswick Duke Energy Company (Duke)

Robert Rishel Jennifer Varnedoe Ricardo Davis-Zapata Robert Rishel Nicole Edwards Ryan Treadway Duke/PRA Duke/PRA Duke/PRA Duke/PRA Duke/Fleet Licensing Duke Energy

List of Documents Reviewed During the Audit

  • Peer Review, Focused-scope peer review, and Facts and Observations (F&O) closure reports for both Brunswick and Shearon Harris
  • Shearon Harris HNP-F/PSA-0065, Appendix-Alternate Seal Injection, Dedicated Shutdown Diesel Generator (T) and FLEX Notebook
  • Duke Energy AD-EG-ALL-1220, Implementation of 50.69 Risk-Informed Engineering Programs
  • Brunswick Fire PRA Quantification Calculation P3059-1000-01
  • Brunswick and Shearon Harris Fussell-Vesely and RAW Internal Event Importances
  • Shearon Harris Risk Achievement Worth Fire importances
  • Brunswick draft FLEX modeling impact on sequences and importances
  • Shearon Harris draft FLEX modeling impact on sequences and importances
  • Equipment in Shearon Harris Turbine building
  • HNP-F/PSA-0094, Revision 1, Analysis of Sumps and Alarms
  • HRA Combination examples for Brunswick and Shearon Harris
  • BNP-PSA-034, Revision 17, Human Reliability Analysis
  • BNP-PSA-062, Supplemental Diesel and FLEX Equipment, Appendix

ML18282A224 OFFICE DORL/LPL2-2/PM DORL/LPL2-2/LA NAME MBarillas LRonewicz DATE 10/17/2018 10/16/2018 DORL/LPL2-2/BC UShoop 11/13/2018

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