RA-21-0162, Supplement to License Amendment Request to Revise the 10 CFR 50.69, Risk Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, Categorization Process to Reflect an Alternative
| ML21159A046 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/08/2021 |
| From: | Maza K Duke Energy Progress |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RA-21-0162 | |
| Download: ML21159A046 (9) | |
Text
Kim E. Maza Site Vice President Harris Nuclear Plant 5413 Shearon Harris Road New Hill, NC 27562 10 CFR 50.90 June, 2021 RA-21-0162 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400/Renewed License No. NPF-63
Subject:
Supplement to License Amendment Request to Revise the 10 CFR 50.69, "Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors," Categorization Process to Reflect an Alternative Seismic Approach
References:
1.
Letter from K. E. Maza (Duke Energy Progress, LLC) to U.S. Nuclear Regulatory Commission, License Amendment Request to Revise the 10 CFR 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors, Categorization Process to Reflect an Alternative Seismic Approach, dated January 14, 2021 (ADAMS Accession No. ML21014A092).
2.
Letter from U.S. Nuclear Regulatory Commission to T. M. Hamilton (Duke Energy Progress, LLC), Shearon Harris Nuclear Power Plant, Unit 1 - Issuance of Amendment No. 174 RE: Adopt Title 10 of the Code of Federal Regulations 50.69, Risk-informed categorization and treatment of structures, systems, and components (SSCs) for Nuclear Power Reactors, dated September 17, 2019 (ADAMS Accession No. ML19192A012).
3.
Letter from U.S. Nuclear Regulatory Commission to K. E. Maza (Duke Energy Progress, LLC), Shearon Harris Nuclear Power Plant, Unit 1 - Regulatory Audit for the Review of License Amendment Request to Revise the 10 CFR 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors, Categorization Process to Reflect an Alternative Seismic Approach, dated April 26, 2021 (ADAMS Accession No. ML21099A274).
Ladies and Gentlemen:
By letter dated January 14, 2021 (Reference 1), Duke Energy Progress, LLC (Duke Energy) requested an amendment to the Shearon Harris Nuclear Power Plant, Unit 1 (HNP) Renewed Facility Operating License (FOL). The proposed change would revise the license condition associated with the adoption of Title 10 of the Code of Federal Regulations (10 CFR), Section 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors, that was added to the HNP FOL upon the issuance of Amendment No.
174 (Reference 2). Specifically, the proposed change would revise the license condition to
( ~ DUKE ENERGY 8
U.S. Nuclear Regulatory Commission RA-21-0162 Page2 reflect an alternative approach to the one provided in NEI 00-04, "10 CFR 50.69 SSC Categorization Guideline," Revision O (ADAMS Accession No. ML052910035), for evaluating the impact of the seismic hazard in the 10 CFR 50.69 categorization process.
As a result of a regulatory audit that was conducted by the U.S. Nuclear Regulatory Commission (NRC) on May 11, 2021 (Reference 3), Duke Energy is supplementing the license amendment request (LAR) to support the NRC staff's review of the proposed change.
The enclosure to this letter provides a table that was requested by the NRC staff during the regulatory audit, as well as a minor change to the proposed 1 O CFR 50.69 license condition that was provided in Reference 1. Attachment 1 provides the existing HNP FOL page marked to show the proposed change. This marked-up FOL page supersedes the one provided in Reference 1 entirely.
Duke Energy has reviewed the information supporting the No Significant Hazards Consideration and the Environmental Consideration that was previously provided to the NRC in Reference 1.
The additional information provided in this LAR supplement does not impact the conclusion that the proposed license amendment does not involve a significant hazards consideration. The additional information also does not impact the conclusion that there is no need for an environmental assessment to be prepared in support of the proposed amendment.
There are no regulatory commitments contained in this submittal.
If there are any questions or if additional information is needed, please contact Mr. Art Zaremba, Manager - Nuclear Fleet Licensing, at 980-373-2062 or Arthur.Zaremba@duke-energy.com.
I declare under penalty of perjury that the foregoing is true and correct. Executed on June 8, 2021.
Sincerely, 1/~ f. ~,-
Kim E. Maza Site Vice President Harris Nuclear Plant
Enclosure:
Supplemental Information
Attachment:
- 1. Facility Operating License Markup cc (with enclosure/attachment):
L. Dudes, NRC Regional Administrator, Region II J. Zeiler, NRC Senior Resident Inspector, HNP M. Mahoney, NRC Project Manager, HNP W. L. Cox, Ill, Section Chief N.C. DHSR
U.S. Nuclear Regulatory Commission RA-21-0162 Page 1 Enclosure Supplemental Information
U.S. Nuclear Regulatory Commission RA-21-0162 Page 2 The following supplemental information, which includes a table and a revision to the proposed 10 CFR 50.69 license condition for Shearon Harris Nuclear Power Plant, Unit 1 (HNP), is in response to the regulatory audit held between the U.S. Nuclear Regulatory Commission (NRC) and Duke Energy Progress, LLC (Duke Energy) on May 11, 2021.
Table 3-1 below summarizes the Integrated Decision-making Panel (IDP) limitations from NEI 00-04, 10 CFR 50.69 SSC Categorization Guideline, Revision 0 (ADAMS Accession No. ML052910035), and those limitations imposed for the Electric Power Research Institute (EPRI) alternative seismic Tier 1 approach proposed for HNP in the Duke Energy license amendment request dated January 14, 2021 (ADAMS Accession No. ML21014A092). The steps of the 10 CFR 50.69 categorization process are performed at either the function level, component level, or both. For each 10 CFR 50.69 categorization step, the evaluation level is also summarized in Table 3-1. A component is assigned its final Risk Informed Safety Class (RISC) category upon approval by the IDP.
Table 3-1 is modified from the version provided in Duke Energys HNP 10 CFR 50.69 license amendment request to the NRC dated February 1, 2018 (ADAMS Accession No. ML18033B768), with changes marked by bold, italic font and revision bars.
The seismic margin analysis (SMA) approach was previously approved by the NRC for use in the HNP 10 CFR 50.69 categorization process (ADAMS Accession No. ML19192A012). The previously approved SMA approach remains valid. By letter dated January 14, 2021, Duke Energy requested approval to use the EPRI alternative seismic Tier 1 approach in the HNP 10 CFR 50.69 categorization process. Therefore, with the proposed change, either seismic approach would be considered valid within the HNP 10 CFR 50.69 categorization process. Only one of the two seismic risk assessment approaches will be used (either the SMA approach or the EPRI alternative seismic Tier 1 approach) for each individual 10 CFR 50.69 categorization.
Both seismic approaches are noted in Table 3-1 below, as each approach has different constraints.
U.S. Nuclear Regulatory Commission RA-21-0162 Page 3 Table 3-1: IDP Changes from Preliminary High Safety Significance (HSS) to Low Safety Significance (LSS)
Element Categorization Step
- NEI 00-04 Section Evaluation Level IDP Change HSS to LSS Drives Associated Functions Risk (PRA Modeled)
Internal Events Base Case -
Section 5.1 Component Not Allowed Yes Fire, Seismic and Other External Events Base Case Allowable No PRA Sensitivity Studies Allowable No Integral PRA Assessment -
Section 5.6 Not Allowed Yes Risk (Non-modeled)
Fire, and Other External Hazards -
Component Not Allowed No Seismic -
SMA Process Component Not Allowed No Seismic -
Alternative Tier 1 Approach Function/Component Allowed1 No Shutdown - Section 5.5 Function/Component Not Allowed No Defense-in-Depth Core Damage -
Section 6.1 Function/Component Not Allowed Yes Containment -
Section 6.2 Component Not Allowed Yes Qualitative Criteria Considerations -
Section 9.2 Function Allowable N/A Passive Passive - Section 4 Segment/Component Not Allowed No 1 IDP consideration of seismic insights can also result in an LSS to HSS determination.
U.S. Nuclear Regulatory Commission RA-21-0162 Page 4 Revision to Proposed 10 CFR 50.69 License Condition To further clarify that either the SMA process or the EPRI alternative seismic approach are proposed as valid approaches for categorization at HNP in accordance with 10 CFR 50.69, Duke Energy proposes to revise the 10 CFR 50.69 license condition that was added to the HNP Facility Operating License (FOL) by Amendment No. 174 to the content provided below. of this submittal provides a markup of the HNP FOL to reflect this proposed change to the 10 CFR 50.69 license condition and supersedes the markup provided in the January 14, 2021 license amendment request entirely.
Duke Energy is approved to implement 10 CFR 50.69 using the processes for categorization of Risk Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) using: Probabilistic Risk Assessment (PRA) models to evaluate risk associated with internal events, including internal flooding, and internal fire; the shutdown safety assessment process to assess shutdown risk; the Arkansas Nuclear One, Unit 2 (ANO-2) passive categorization method to assess passive component risk for Class 2 and Class 3 SSCs and their associated supports; and the results of non-PRA evaluations that are based on the IPEEE Screening Assessment for External Hazards, i.e., seismic margin analysis (SMA) to evaluate seismic risk, and a screening of other external hazards updated using the external hazard screening significance process identified in ASME/ANS PRA Standard RA-Sa-2009; as specified in Unit 1 License Amendment No. 174 dated September 17, 2019.
In addition, Duke Energy is approved to implement 10 CFR 50.69 using the alternative seismic approach for categorization of RISC-1, RISC-2, RISC-3, and RISC-4 SSCs as described in Duke Energy letter RA-20-0311, dated January 14, 2021, and as specified in License Amendment No. [XXX] dated [DATE].
Prior NRC approval, under 10 CFR 50.90, is required for a change to the categorization process specified above (e.g., change from a seismic margins approach to a seismic probabilistic risk assessment approach).
U.S. Nuclear Regulatory Commission RA-21-0162 Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400 / Renewed License No. NPF-63 Supplement to License Amendment Request to Revise the 10 CFR 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors, Categorization Process to Reflect an Alternative Seismic Approach Facility Operating License Markup
Replace with "FOL INSERT" APPENDIX D ADDITIONAL CONDITIONS RENEWED LICENSE NO. NPF-63 Duke Energy Progress, L.: C shall comply with the following conditions on the schedule noted below:
Amendment Number Additional Conditions O1:Jl"e EneFgy is appF01reel to implement 10 GFR e0.e9 l:JSing tt:le pFOGesses f:OF oateg0Fi2:ation of: Risk lnroFmeel Saroty Glass (RISC) 1, RISC 2, RISC a, anel RISC 4 stF1:Jot1:JFes, systems, anel oomponents (SSGs) 1:Jsing: PFObabilistio Risi" Assessment (PR.'\\) moelels to eyal1:Jate Fisk assooiateel v,*itt:l intemal e1,ents, inol1:Jeling intemal flooeling, anel intemal fiFe; tt:le st:11:Jtelovm saroty assessment pFooess to assess st:11:Jtelown Fisk; tt:le AFkansas N1:JoleaF One, Unit 2 (ANO 2) passiYe oateg0Fi2:ation mett:loel to assess passiYe oomponent Fisl" t:oF Glass 2 anel Glass a SSGs anel tt:leiF assooiateel s1:Jpports; anel tt:le Fes1:Jlts of: non PR.'\\ eYal1:Jations tt:lat aFe baseel on tt:le IPEEE Sornening Assessment t:oF Ex-temal l=la2:aFels, i.e., seismio maFgin analysis (SM/\\) to eYal1:Jate seismio Fisk, anel a soFeening of: ott:leF ex-temal t:la2:aFels 1:Jpelateel 1:Jsing tt:le e~demal t:la2:aFel soFeening signifioanoe pFOoess ielentit:ieel in ASMEIANS PR.'\\ StanelaFel RA Sa 2009; as speoifieel in Unit 1 Lioense Amenelment No. 174 elateel SeptembeF 17, 2019.
D1:Jl"e EneFgy will oomplete tt:le implementation items list in Attaot:lment 1 of:
D1:Jke EneFgy letteF to tt:le NRG elateel ApFil 2a, 2019 pFioF to implementation of:
1 0 GFR e0.e9. All iss1:Jes ielentit:ieel in tt:le attaot:lment will be aelelFesseel anel any assooiateel ot:langes will be maele, roo1:Jseel soope peOF Fe1,iews will be peFf:oFmeel on ot:langes tt:lat aFe PR.'\\ 1:JpgFaeles as elet:ineel in tt:le PR.'\\
stanelaFel (ASMEIANS RA Sa 2009, as enelOFseel by RG 1.200, ReYision 2),
anel any t:inelings will be FesolYeel anel FOfleoteel in tt:le PR.'\\ of: FeGOFel pFiOF to implementation of: tt:le 10 GFR e0.e9 oateg0Fi2:ation pFooess. Implementation Date Upon implementation of Amendment No.
[XXX]
PFioF to implementation ot: 1 o GFR e0.e9.
Amendment No. -+/--74
FOL INSERT Duke Energy is approved to implement 10 CFR 50.69 using the processes for categorization of Risk Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) using: Probabilistic Risk Assessment (PRA) models to evaluate risk associated with internal events, including internal flooding, and internal fire; the shutdown safety assessment process to assess shutdown risk; the Arkansas Nuclear One, Unit 2 (ANO-2) passive categorization method to assess passive component risk for Class 2 and Class 3 SSCs and their associated supports; and the results of non-PRA evaluations that are based on the IPEEE Screening Assessment for External Hazards, i.e., seismic margin analysis (SMA) to evaluate seismic risk, and a screening of other external hazards updated using the external hazard screening significance process identified in ASME/ANS PRA Standard RA-Sa-2009; as specified in Unit 1 License Amendment No. 174 dated September 17, 2019.
In addition, Duke Energy is approved to implement 10 CFR 50.69 using the alternative seismic approach for categorization of RISC-1, RISC-2, RISC-3, and RISC-4 SSCs as described in Duke Energy letter RA-20-0311, dated January 14, 2021, and as specified in License Amendment No. [XXX] dated [DATE].
Prior NRC approval, under 10 CFR 50.90, is required for a change to the categorization process specified above (e.g., change from the alternate seismic approach (referenced above) to a seismic probabilistic risk assessment approach).