ML20297A307

NRR E-mail Capture - Request for Additional Information - Shearon Harris Nuclear Power Plant, Unit 1 - RCS Flowrate Reduction/Lbloca LAR

ML20297A307
Person / Time
Site:	Harris
Issue date:	10/13/2020
From:	Michael Mahoney NRC/NRR/DORL/LPL2-2
To:	Earp D Duke Energy Progress
References
L-2020-LLA-0040
Download: ML20297A307 (3)

Text

From: Mahoney, Michael Sent: Tuesday, October 13, 2020 8:28 AM To: Dennis Earp (dennis.Earp@duke-energy.com)

Cc: Art Zaremba

Subject:

Request for Additional Information - Shearon Harris Nuclear Power Plant, Unit 1 - RCS Flowrate Reduction/LBLOCA LAR (EPID L-2020-LLA-0040)

Hi Dennis, By letter dated March 6, 2020, as supplemented by letter dated April 23 and June 22, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession Nos.

ML20066L112, ML20114E131, and ML20174A640, respectively), Duke Energy Progress, LLC (the licensee) submitted a license amendment request (LAR) for Shearon Harris Nuclear Power Plant (Harris), Unit 1.

The amendment would revise technical specifications proposing changes to TS 3/4.2.5, DNB

[departure from nucleate boiling] Parameters, and TS 6.9.1.6, Core Operating Limits Report, in support of analysis development for Harris, Unit 1 Cycle 24 and the introduction of reload batches of Framatome, Inc. (Framatome) GAIA fuel assemblies. TS 3/4.2.5 would be revised to reflect a lower minimum Reactor Coolant System (RCS) flow rate, whereas TS 6.9.1.6.2 would reflect the incorporation of the Framatome topical report EMF-2103(P)(A), Revision 3, Realistic Large Break LOCA [Loss-of-Coolant Accident] Methodology for Pressurized Water Reactors.

TS 6.9.1.6.2 would also be revised to reflect the removal of analytical methods no longer applicable for the determination of core operating limits.

In order to complete its review, the U.S. Nuclear Regulatory Commission staff requests additional information. A clarification call to ensure mutual understanding was conducted on October 7, 2020. Please provide your response to the following requests for additional information (RAIs) within 45 days of the date of this correspondence.

RAI - 1 Framatome Licensing Report ANP-3766P/NP, Harris Nuclear Plant Unit 1 Small Break LOCA Analysis with GAIA Fuel Design, enclosed the March 6, 2020, letter, states, in Section 4.3:

For Harris Nuclear Plant Unit 1, the condition for which all three RCPs [Reactor Coolant Pumps] are tripped is based on the RCS pressure with consideration of required operator action times specified in the plant Emergency Operating Procedure. A delayed RCP trip time of 5 minutes following the specified trip criteria being met was analyzed to demonstrate compliance to 10 CFR 50.46(b)(1-4) criteria The spectrum of cold and hot leg breaks in this study includes break sizes from 1.00 to 8.70 inches. The results of the delayed RCP trip cases indicate that there is at least 5 minutes for operators to trip all three RCPs after the specified trip criteria being met with considerable margin to the 10 CFR 50.46(b)(1-4) criteria.

According to Title 10 of the Code of Federal Regulations (CFR), Section 50.46(a)(1)(i),

emergency core cooling performance must be analyzed for a number of postulated loss-of-

coolant accidents of break sizes, locations, and other properties sufficient to provide assurance that the most severe postulated loss-of-coolant accident has been calculated.

Considering the limiting range of breaks for Harris and associated phenomenology, a 5-minute RCP trip delay is essentially the same as allowing the RCPs to run throughout the event.

Meanwhile, it is not clear, based on the sequence of events for the limiting break size range, whether an operator would trip the RCPs sooner than the 5-minute trip delay time that was analyzed.

Please provide additional justification that a shorter RCP trip delay time would not lead to a higher Peak Cladding Temperature (PCT). Consider specifically, RCP trip delay times that may result in RCP trip prior to the time of PCT.

RAI-2

In response to NRC Request No. 3, in the April 23, 2020, supplement letter, the licensee provided information addressing the limitations and conditions associated with the implementation of the Framatome GAIA fuel assembly topical report, ANP-10342NP-A, GAIA Fuel Assembly Mechanical Design, (ADAMS Accession No. ML19309D916). Among other things, the licensee noted that the rod cluster control assembly (RCCA) ejection accident would be subject to analysis or evaluation to support loading of the GAIA fuel assembly design, in accordance with the reload safety analysis methods in use at Harris. This information was provided to address Limitation and Condition 5 of the ANP-10342NP-A safety evaluation.

However, Limitation and Condition 5 requires demonstration that the acceptance criteria are satisfied. The information referenced in the previous RAI response was based on a different fuel system design, meaning it is unclear how the analysis would apply to GAIA fuel.

Please provide information to demonstrate that implementing the GAIA fuel design at Harris will satisfy the applicable acceptance criteria, thus ensuring applicability of the submitted loss-of-coolant accident analyses.

Once this email is added to ADAMS, I will provide the accession number for your reference.

If you have any questions, please contact me.

Thanks Mike Michael Mahoney McGuire and Catawba Project Manager, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Desk: (301)-415-3867 Email: Michael.Mahoney@NRC.GOV

Hearing Identifier: NRR_DRMA Email Number: 857 Mail Envelope Properties (MN2PR09MB553126B4496DB50EB30B4A2BE5040)

Subject:

Request for Additional Information - Shearon Harris Nuclear Power Plant, Unit 1

- RCS Flowrate Reduction/LBLOCA LAR (EPID L-2020-LLA-0040)

Sent Date: 10/13/2020 8:28:00 AM Received Date: 10/13/2020 8:28:02 AM From: Mahoney, Michael Created By: Michael.Mahoney@nrc.gov Recipients:

"Art Zaremba" <Arthur.Zaremba@duke-energy.com>

Tracking Status: None "Dennis Earp (dennis.Earp@duke-energy.com)" <dennis.Earp@duke-energy.com>

Tracking Status: None Post Office: MN2PR09MB5531.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 5107 10/13/2020 8:28:02 AM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: