ML20329A381

Regulatory Audit Summary Regarding License Amendment Request to Adopt Risk Informed Completion Times Technical Specification Task Force-505, Rev. 2, Provide Risk-Informed Completion Times (EPID L-2019-LLA-0218

ML20329A381
Person / Time
Site:	Harris
Issue date:	12/07/2020
From:	Tanya Hood Plant Licensing Branch II
To:	Maza K Progress Energy Carolinas
Hood T-NRR/DORL 301-415-1387
References
EPID L-2019-LLA-0218
Download: ML20329A381 (11)

Text

December 7, 2020 Ms. Kim Maza Site Vice President Shearon Harris Nuclear Power Plant Mail Code NHP01 5413 Shearon Harris Road New Hill, NC 27562-9300

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - REGULATORY AUDIT

SUMMARY

REGARDING LICENSE AMENDMENT REQUEST TO ADOPT RISK-INFORMED COMPLETION TIMES TECHNICAL SPECIFICATION TASK FORCE-505, REVISION 2, PROVIDE RISK-INFORMED COMPLETION TIMES - RITSTF INITIATIVE 4B (EPID L-2019-LLA-0218)

Dear Ms. Maza:

By letter dated October 7, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19280C844), Duke Energy Progress, LLC (the licensee) submitted a license amendment request (LAR) for the Shearon Harris Nuclear Power Plant, Unit 1. The proposed amendment would modify Technical Specifications (TSs) requirements to permit the use of risk-informed completion times in accordance with the Technical Specifications Task Force (TSTF) traveler TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF [risk-informed TSTF] Initiative 4b.

To support its review of the LAR, the U.S. Nuclear Regulatory Commission staff conducted a remote regulatory audit through an internet portal established by the licensee. The audit was conducted from June 22, 2020, to June 25, 2020.

K. Maza A summary of the regulatory audit, schedule of activities, list of participants, and list of documents are enclosed.

Sincerely,

/RA/

Tanya E. Hood, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-400

Enclosures:

1. Regulatory Audit Summary

2. Schedule of Activities

3. List of Participants

4. List of Documents Reviewed During Audit cc: Listserv

OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY AUDIT

SUMMARY

REGARDING LICENSE AMENDMENT REQUEST TO ADOPT RISK-INFORMED EXTENDED COMPLETION TIMES DUKE ENERGY PROGRESS, LLC SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400

1.0 BACKGROUND

By letter dated October 7, 2019,1 Duke Energy Progress, LLC (the licensee) submitted a license amendment request (LAR) for Shearon Harris Nuclear Power Plant, Unit 1 (Harris). The proposed LAR would revise technical specification requirements to permit the use of risk-informed completion times for actions to be taken when limiting conditions for operation are not met. The proposed changes are based on Technical Specifications Task Force (TSTF)

Traveler 505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, dated July 2, 2018.2 An audit plan was issued by the U.S. Nuclear Regulatory Commission (NRC) staff by email on May 20, 2020,3 as supplemented by a letter dated June 24, 2020.4 The scope of the audit was to gain a better understanding of the information needed to support the NRC staffs licensing decision regarding the LAR and to develop requests for additional information (RAIs). The information submitted in the LAR is under final review, and any additional information, including information identified during this audit, needed to support the LAR review will be formally requested by the NRC staff.

2.0 AUDIT DATES AND LOCATION The regulatory audit was conducted through an online portal established by the licensee that allowed the NRC staff and contractors to access documents remotely via the internet from June 22, 2020, to June 25, 2020.

1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML19280C844 2

ADAMS Accession No. ML18183A493 3

ADAMS Accession No. ML20141L623 4

ADAMS Accession No. ML20175A575 Enclosure 1

3.0 AUDIT ACTIVITIES The NRC audit team held an entrance meeting on June 22, 2020, with the licensees staff and contractors. During the remainder of the audit, team members participated in technical discussions based on their discipline according to the audit plan. Enclosure 2 provides the schedule of activities during the audit.

Technical discussions were focused on the following major areas: probabilistic risk analysis, external hazards, and electrical power distribution systems. The audit team participated in a summary exit meeting with the licensee on June 25, 2020. The NRC staff provided a brief conclusion of the team goals, objectives, and technical discussions. Enclosure 3 lists audit participants from the NRC, Pacific Northwest National Laboratory and Energy Research, Inc. lists the documents reviewed during the audit. There were no deviations from the finalized audit plan. No regulatory decisions were made during the audit.

4.0 RESULTS OF THE AUDIT Based on insights from the remote audit, the licensee indicated that they could provide a supplement to the LAR that would address the majority of audit questions asked by the NRC staff. By letter dated July 27, 2020,5 the licensee provided a supplement to the LAR. Based on its review of the licensees supplemental document, the NRC staff issued RAIs to the licensee in an email dated September 29, 2020,6 with a request to submit its response by November 13, 2020.7 The NRC staff is currently reviewing this information.

5 ADAMS Accession No. ML20209A304 6

ADAMS Accession No. ML20274A046 7

ADAMS Accession No. ML20316A007 Enclosure 1

SCHEDULE OF ACTIVITIES Monday, June 22, 2020 8:30 am - 11:00 am Eastern Daylight Time (EDT)

Entrance briefing - U.S. Nuclear Regulatory Commission (NRC) and Licensee.

Introductions and Logistics.

Discussion of Audit Questions 21 through 26 Electrical discussion.

Discussion of Audit Question 07 concerning the modeling of digital Instrumentation and Control (I&C) in the Probabilistic Risk Assessment (PRA).

Discussion of Audit Question 15 concerning credit for FLEX equipment and operator actions.

12:00 pm - 4:00 pm EDT Discussion of Audit Question 01 concerning the status of implementation items from the 10 CFR 50.69 license amendment.

Discussion of Audit Question 12 concerning a key assumption and source of PRA model uncertainty.

Continuation of discussion of Electrical Audit Questions 24 and 25.

Summary of the day NRC Staff meeting Tuesday, June 23, 2020 8:30 am - 11:15 am EDT Summary of the previous day. Discussion of Audit Question 29 continued regarding the Technical Specification (TS) 3.8.1.1 Action d.1 plant configuration.

Presentation and demonstration by licensee of the Harris real-time risk (RTR) model using their RTR software Phoenix. The demonstration included showing how a risk-informed completion times (RICT) calculation would be performed for TS.

12:00 pm - 5:00 pm EDT Discussion of Audit Question 08 concerning PRA modeling of specific TS functions.

Discussion of Audit Question 11 concerning the development and application of the RTR model.

Discussion of Audit Question 06 concerning TS actions, for which example RICT estimates were not provided in Table E1-2 of the License Amendment Request (LAR) and the applicability of the RICT program to these TS actions.

Continuation of discussion of Audit Question 27 and 29, specifically with regards to having the licensee provide example RICT estimates for those TS actions for which RICT estimates were not provided in the LAR.

Summary of the day NRC Staff meeting Enclosure 2

Wednesday, June 24, 2020 8:30 am - 11:15 am EDT Summary of the previous day by NRC and Licensee.

Discussion of Audit Questions 05, 20, and 30 concerning the definition of TS loss of function and LCO [Limiting Condition for Operation] conditions that appear to result in TS loss of function.

Follow-up to Audit Questions 08 and 11 from Tuesday.

Discussion of Audit Question 14 concerning the identification of 2 Risk Management Actions.

Discussion of Audit Question 09 and 10 concerning the treatment of common cause failures.

Discussion of Audit Question 19 concerning PRA modeling of manual actuations.

12:00 pm - 5:00 pm EDT Discussion of Audit Question 28 concerning PRA modeling of electrical sources and loads.

Discussion of Audit Question 16 concerning parameters used to develop the seismic core damage frequency (CDF).

Discussion of Audit Question 17 and 18 concerning the bounding seismic large early release frequency (LERF) analysis and high winds screening evaluation.

Discussion of Audit Questions 13 concerning the process for identifying key assumptions and uncertainties.

Summary of the day (3:30 pm to 4:00 pm)

NRC Staff meeting Thursday, June 25, 2020 8:30 am - 11:45 am EDT Summary of previous day and audit question discussion status by NRC and Licensee.

Follow-up discussion of Audit Question 15 from Monday concerning FLEX modeling.

Discussion of Audit Question 02 concerning open peer review facts and observations.

(F&Os).

Discussion of new Audit Question 31 concerning the TS 3.8.1.1 Action d.1 design success criteria.

Follow-up discussion of Audit Question 05 from Wednesday concerning the loss of function.

Follow-up discussion of Audit Question 28 from Wednesday concerning electrical sources and load models.

Follow-up discussion of Audit Question 07 from Monday concerning PRA modeling of digital I&C systems.

Follow-up discussion of Audit Question 18 regarding high winds PRA.

12:30 pm - 4:25 pm EDT Discussion of Audit Question 03 concerning PRA maintenance and upgrades.

Discussion of Audit Question 04 concerning the PRA update process.

Follow-up discussion of Audit Question 08 from Tuesday concerning PRA modeling of TS functions related to containment sprays and containment fan coolers.

NRC staff meeting (1:45 pm to 2:45 pm)

Summary of the week with the licensee (2:45 pm to 3:10 pm)

Audit Exit Meeting with NRC and licensee management (3:30 pm to 3:50 pm)

LIST OF PARTICIPANTS U.S. Nuclear Regulatory Commission Team Staff Role Azarm, Mohamad Electrical Systems Contractor, ERI Biro, Mihaela PRA Licensing Reviewer, DRA/APLA Hilsmeier, Todd PRA Licensing Reviewer, DRA/APLA Hood, Tanya Project Manager, DORL Li, Ming I&C Reviewer, DEX/EICB Nakanishi, Tony Observer, DRA/APLA Nguyen, Khoi Electrical Systems Reviewer, DEX/EEOB Park, Sunwoo PRA Licensing Reviewer, DRA/APLC Pascarelli, Robert PRA Licensing Branch Chief, DRA/APLA Russell, Andrea Technical Specifications Reviewer, DSS/STSB Scully, Derek Reactor Systems Engineer, DSS/SCPB Short, Steven Principal Engineer, PNNL Wu, De PRA Licensing Reviewer, DRA/APLC Acronyms APLA - PRA Licensing Branch A APLC - PRA Licensing Branch C DEX - Division of Engineering DORL - Division of Operating Reactor Licensing DRA - Division of Risk Assessment DSS - Division of Safety Systems EEOB - Electrical Engineering Operating Branch EICB - Instrumentation and Control Branch B ERI - Energy Research, Inc.

SCPB - Containment and Plant Systems Branch STSB - Technical Specifications Branch PNNL - Pacific Northwest National Laboratory Enclosure 3

LIST OF DOCUMENTS REVIEWED PRA Notebooks and Information HNP-F-PSA-0065, Appendix A.24, Revision 9, Harris Nuclear Plant Probabilistic Safety Assessment - Alternate Seal Injection, Dedicated Shutdown Diesel Generator (T) and FLEX Notebook HNP-F-PSA-0065, Appendix A.6, Revision 8, Harris Nuclear Plant Probabilistic Safety Assessment - Containment Fan Cooler System (B) Notebook HNP-F-PSA-0065, Appendix A.17, Revision 8, Harris Nuclear Plant Probabilistic Safety Assessment - Containment Spray System (S) Notebook File titled RPS.pdf, containing the PRA model RPS fault tree File titled E1ED65.pdf, containing PRA model fault trees File titled FLEX Actions.pdf, containing HRA for FLEX operator actions File titled Changelog excluding FO Changes.pdf, containing changes made to the PRA models since 2017 exclusive of those made to resolve F&Os File titled LERF Operator Actions.pdf, containing a list of top 20 LERF operator actions ranked based on F-V File titled CDF Operator Actions.pdf, containing a list of top 20 CDF operator actions ranked based on F-V PRA Quality HNP-F/PSA-0069, Revision 5, Appendix D, HNP - PSA Model Peer Review Resolution, Focused Scope Peer Review of Human Reliability Analysis, Data Analysis and Uncertainty Treatment & MOR 2007 Presentation (December 2007 - January 2008)

HNP-F/PSA-0069, Revision 5, Appendix G, HNP - PSA Model Peer Review Resolution, NRC Staff Review of Harris Fire PRA Model Peer Review (March 2008)

HNP-F/PSA-0069, Revision 5, Appendix J, HNP - PSA Model Peer Review Resolution, Partial Scope Fire PRA Follow-on Peer Review (May 2008)

HNP-F/PSA-0069, Revision 5, Appendix L, HNP - PSA Model Peer Review Resolution, Focused-Scope PRA Peer Review of the HNP Internal Flooding PRA (2014)

HNP-F/PSA-0069, Revision 5, Appendix R, HNP - PSA Model Peer Review Resolution, 2017 Internal Events and Internal Flood F&O Closure Report HNP-F/PSA-0069, Revision 5, Appendix S, HNP - PSA Model Peer Review Resolution, IE/IF F&O Closure Gap Assessment, 2017 HNP-F/PSA-0069, Revision 5, Appendix T, HNP - PSA Model Peer Review Resolution, IE/IF F&O Closure Addendum with Upgrade vs. Update Justifications, December 2017 HNP-F/PSA-0069, Revision 5, Appendix U, HNP - PSA Model Peer Review Resolution, Fire F&O Closure Report, October 2017 HNP-F/PSA-0069, Revision 5, Appendix V, HNP - PSA Model Peer Review Resolution, Internal Events Focused Scope Peer Review of LE-D6, 8/14/17 HNP-F/PSA-0069, Revision 5, Appendix W, HNP - PSA Model Peer Review Resolution, HNP Fire Focused Scope Peer Review Report (June 2019)

HNP-F/PSA-0069, Revision 5, Appendix X, HNP - PSA Model Peer Review Resolution, HNP Fire F&O Closure (June 2019)

HNP-F/PSA-0069, Revision 5, Appendix Y, HNP - PSA Model Peer Review Resolution, HNP Internal Events Focus Scope Peer Review (September 2019)

Enclosure 4

25137-RPT-01, Revision 0, Harris Nuclear Power Plant PRA Finding-Level Fact and Observation Independent Assessment, dated 6/10/2020 File titled Description of documents generated since the LAR.pdf LAR Support Documents and Information HNP-F/PSA-0119, Revision 001, Online Phoenix PRA Model, dated 5/23/2019 File titled Phoenix Summer Winter modes for1 NRC Spreadsheet files titled HNP TSTF-505 Support uncertainty, which was subsequently updated by file titled HNP TSTF-505 Support Updated File titled Uncertainty Screening Legend.pdf, identifying the screening criteria used for the uncertainty evaluation File titled Documentation supporting RICT Calcs.pdf, describing surrogate events used to make RICT calculations RICT Program and PRA Related Plant Procedures File titled RICT Program - Procedure Impacts.pdf, providing a schematic of plant procedure changes being made to incorporate the RICT program Harris Unit 1 Administrative Procedure OM-001, Revision 119 DRAFT, Operations Administrative Requirements Nuclear Operating Fleet Administrative Procedure AD-OP-ALL-0NEW, Revision 000 DRAFT, Risk-Informed Completion Time Program Calculations Nuclear Operating Fleet Administrative Procedure AD-WC-ALL-0240, Revision 002 DRAFT, On-line Risk Management Process Nuclear NGO Administrative Procedure AD-NF-NGO-0502, Revision 4 Draft, Probabilistic Risk Assessment (PRA) Model Technical Adequacy CSD-WC-HNP-0240-00, Revision 000 Draft, HNP Risk Management Actions CSD-WC-HNP-0240-00, Revision 000, HNP ERAT Guidance

ML20329A381 OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LA NRR/DORL/LPL2-2/BC NRR/DORL/LPL2-2/PM NAME THood BAbeywickrama UShoop THood DATE 11/23/2020 11/24/2020 12/07/2020 12/07/2020