ML24101A052
| ML24101A052 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 04/10/2024 |
| From: | Michael Mahoney NRC/NRR/DORL/LPL2-2 |
| To: | Earp D Duke Energy Progress |
| References | |
| L-2023-LLA-0078 | |
| Download: ML24101A052 (5) | |
Text
From:
Michael Mahoney Sent:
Wednesday, April 10, 2024 7:54 AM To:
Dennis Earp (dennis.Earp@duke-energy.com)
Subject:
Shearon Harris Nuclear Power Plant, Unit 1 - Request for Additional Information - ITS Alignments LAR (L-2023-LLA-0078)
Attachments:
RAIs for Harris ITS Alignments LAR (L-2023-LLA-0078).docx Hi Dennis, By letter RA-23-005 dated May 31, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23151A724) as supplemented by letter RA-23-0276, dated November 6, 2023 (ML23311A076), Duke Energy Progress, LLC (the licensee)) submitted a license amendment request (LAR) for the Shearon Harris Nuclear Power Plant, Unit 1 (Harris).
The proposed amendment makes various Technical Specification changes consistent with those in Revision 5 of NUREG-1431, Standard Technical Specifications - Westinghouse Plants.
The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing your submittal and has identified areas where additional information is needed to complete its review.
As discussed, response to the attached RAIs is requested no later than 30 business days from todays date.
The NRC staff considers that timely responses to RAIs help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me.
Once this email is added to ADAMS, I will provide the accession number.
Thanks Mike Mahoney Project Manager, LPL2-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Desk: (301)-415-3867 Mobile: (301)-250-0450 Email: Michael.Mahoney@nrc.gov
Hearing Identifier:
NRR_DRMA Email Number:
2463 Mail Envelope Properties (SA1PR09MB9486F756B655B6ADEF9D8E08E5062)
Subject:
Shearon Harris Nuclear Power Plant, Unit 1 - Request for Additional Information -
ITS Alignments LAR (L-2023-LLA-0078)
Sent Date:
4/10/2024 7:54:25 AM Received Date:
4/10/2024 7:54:29 AM From:
Michael Mahoney Created By:
Michael.Mahoney@nrc.gov Recipients:
"Dennis Earp (dennis.Earp@duke-energy.com)" <dennis.Earp@duke-energy.com>
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REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO ALIGN CERTAIN TECHNICAL SPECIFICATIONS REQUIREMENTS WITH IMPROVED STANDARD TECHNICAL SPECIFICATIONS RENEWED FACILITY OPERATING LICENSE NO. NPF-63 DUKE ENERGY PROGRESS, LLC SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400 EPID: L-2023-LLA-0078
Background
By letter to the U.S. Nuclear Regulatory Commission (NRC or the Commission) dated May 31, 2023 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML23151A724), as supplemented by letter dated November 6, 2023 (ML23311A076), Duke Energy Progress, LLC (Duke Energy or the licensee) requested changes to the technical specifications (TSs) for the Shearon Harris Nuclear Power Plant, Unit 1 (Harris). The proposed changes align certain TS requirements with industry standards provided in the NRCs improved standard TS (ISTS).
Part of the amendment request provides TS changes to align certain Harris TSs with TSTF-425, Revision 3, Relocate Surveillance Frequencies to Licensee Control - RITSTF [Risk-Informed Technical Specification Task Force] Initiative 5b (ML090850642). The NRC staff evaluated the licensees proposed revision and has determined that additional information, as described in the following request for additional information (RAI(s)), is needed to complete its review of the proposed change.
Regulatory Basis 10 Code of Federal Regulations (CFR) 50.36, Technical Specifications, requires, in part, that the TS shall be included by applicants for a license authorizing operation of a production or utilization facility. 10 CFR 50.36(c) requires that TS include items in five specific categories related to station operation. These categories are (1) Safety limits, limiting safety system settings, and limiting control settings, (2) Limiting conditions for operation (LCOs) (3)
Surveillance requirements (SRs), (4) Design features, and (5) Administrative controls.
10 CFR 50.36(c)(1)(ii)(A) states that limiting safety system settings for nuclear reactors are settings for automatic protective devices related to those variables having significant safety functions. Where a limiting safety system setting is specified for a variable on which a safety limit has been placed, the setting must be so chosen that automatic protective action will correct the abnormal situation before a safety limit is exceeded. If, during operation, it is determined that the automatic safety system does not function as required, the licensee shall take appropriate action, which may include shutting down the reactor.
10 CFR 50.36(c)(3), SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
RAI 1
In the LAR, the licensee proposed to change the TS Table 4.3-1, Reactor Trip System Instrumentation Surveillance Requirements, as shown below:
Functional Unit Analog Channel Operational Test (ACOT)
Current Proposed Change
- 2. Power Range, Neutron Flux
- b. Low Setpoint S/U(1)
S/U(17), SFCP
- 5. Intermediate Range, Neutron Flux S/U(1)
S/U(17), SFCP
- 6. Source Range, Neutron Flux S/U(1), SFCP(8)
S/U(17), SFCP(8)
The current Table 4.3-1, Table Notations include the following:
- When the Reactor Trip System breakers are closed, and the Control Rod Drive System is capable of rod withdrawal.
(1) If not performed in previous 31 days.
(8) Surveillance in MODES 3*, 4*, and 5* shall also include verification that permissives P-6 and P-10 are in their required state for existing plant conditions by observation of the permissive annunciator window.
The licensee proposed adding a new note (17) that states:
(17) If not performed within the Frequency specified in the Surveillance Frequency Control Program.
The current surveillance requirements for the three functions in the table above require an ACOT prior to each reactor startup. The notation in the table for a required surveillance at startup is modified by a Note that states the surveillance is only required if it has not been performed within the previous 31 days.
The licensee is proposing the implementation of a required surveillance frequency for the three functions. The proposed frequency is both event-based (i.e., at Startup) and periodic, as controlled within the Surveillance Frequency Control Program (SFCP). Since a SFCP Frequency does not currently exist for these functions, the licensee is proposing a starting ACOT frequency of once per 184 days. The LAR indicates that the licensee is also proposing to eliminate the requirement to ensure these channels are ACOT tested within 31 days prior to reactor startup.
On Page 13 of the LAR, the licensee referenced WCAP-15376-P Revision 0, Risk-Informed Assessment of the Reactor Trip System and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times, that provided the justification for extending ACOT periodic surveillance test intervals from 92 to 184 days. On Page 14 of the LAR, the licensee states, Changes to the Frequencies will be made in accordance with NEI 04-10, Revision 1.
NEI-04-10, Revision 1, Step 6, states in general the next logical Surveillance Test Interval (STI) in technical specifications is chosen for improvement.
a) Please describe the technical basis which establishes the proposed periodic surveillance frequency of 184 days for the three SRs listed above. Westinghouse report WCAP-15736-P provides a basis for an increment from 92 to 184 days (i.e., quarterly to semi-annually) and NEI 04-10, Revision 1, Step 6, states that for surveillance step incrementation, the next logical STI in technical specification is chosen. For example, for a change from monthly surveillance, the next increment would be quarterly, rather than semiannually. Additionally, please describe your technical basis for initially conducting an ACOT for these three channels on a semi-annual basis rather than a more frequent basis.
b) The current TS requirement to perform the ACOT for the affected channels ensures that shortly before a plant start-up the affected channels are tested and found to be functioning as required. That is, the ACOT requirement in the current technical specifications ensures that this test is performed within a 31-day window prior to startup, thus ensuring that the channels are recently demonstrated to be functioning as required prior to startup. Neither the LAR, the referenced WCAP, or the NEI 04-10 provide a justification for extending this window from within 31 days prior to startup to within 184 days prior to startup.
Please describe the justification/technical basis which provides the assurance that these channels are ready to support the accomplishment of required safety actions during plant startups and will remain functioning as required once the proposed surveillance frequency is implemented.