ML24113A252
| ML24113A252 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 04/22/2024 |
| From: | Michael Mahoney NRC/NRR/DORL/LPL2-2 |
| To: | Earp D Duke Energy Progress |
| References | |
| L-2024-LLE-0004 | |
| Download: ML24113A252 (6) | |
Text
From: Michael Mahoney Sent: Monday, April 22, 2024 2:27 PM To: Dennis Earp (dennis.Earp@duke-energy.com)
Subject:
Audit Plan -Shearon Harris Nuclear Power Plant, Unit 1 - RIPE Exemption 10 CFR 50.55a(h)(2) (L-2024-LLE-0004)
Attachments: Audit-Plan-Harris RIPE Exemption_Final.docx
Hi Dennis,
By letter dated February 6, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24037A284), as supplemented letter dated April 3, 2024 (ML24094A105), Duke Energy Progress, LLC (Duke Energy) submitted a request for an exemption from certain requirements of Title 10 of the Code of Federal Regulations (10 CFR)
Section 50.55a(h)(2), Protection systems, for the Shearon Harris Nuclear Power Plant, Unit 1 (Harris).
Specifically, the exemption request would remove the requirement for the Reactor Protection System cables that terminate within the Turbine Control System Cabinet G (1TCS-CAB-G) to meet the requirement in IEEE 279-1971, Criteria for Protection Systems for Nuclear Power Generating Stations, Section 4.6, Channel Independence, that the cables be independent and physically separated. The exemption request was submitted under the Risk -Informed Process for Evaluations (RIPE).
To improve the efficiency of the NRC staffs review, FPLs representatives and the NRC staff have discussed the performance of an NRC staff audit using an online reference portal that would allow the NRC staff limited, read-only access to the information identified in Section 5.0 of the attached audit plan. The NRC staff plans to conduct a desk audit to review the documentation provided on the portal. The online reference portal would allow the NRC staff to audit internal licensee information to confirm information in the exemption request. Any audit information that the NRC staff determines to be necessary to support the development of the NRC staffs safety evaluation will be requested to be formally submitted on the docket. The audit may also include interactions (e.g., teleconferences or webinars) on a mutually agreeable schedule sufficient to understand or resolve issues associated with the information made available on the online reference portal.
Use of the online reference portal is acceptable, as long as the following conditions are met:
- The online reference portal will be password-protected, and passwords will be assigned to those directly involved in the review on a need-to-know basis.
- The online reference portal will be sufficiently secure to prevent NRC staff from printing, saving, or downloading any documents; and
- Conditions of the use of the online reference portal will be displayed on the login screen and with concurrence by each user.
These conditions associated with the online reference portal must be maintained throughout the duration of the audit process.
The NRC staff would like to request that the portal be populated with the information identified in section 5.0 of attached audit plan. The NRC staff may request additional documents during the review, which will be transmitted to you via email.
This email will be added to ADAMS (public), and I will provide you with the accession number.
If you have any questions, please contact me.
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: 2483
Mail Envelope Properties (SA1PR09MB94862571BE1C48CC1C251BEEE5122)
Subject:
Audit Plan -Shearon Harris Nuclear Power Plant, Unit 1 - RIPE Exemption 10 CFR 50.55a(h)(2) (L-2024-LLE-0004)
Sent Date: 4/22/2024 2:26:56 PM Received Date: 4/22/2024 2:26:59 PM From: Michael Mahoney
Created By: Michael.Mahoney@nrc.gov
Recipients:
"Dennis Earp (dennis.Earp@duke-energy.com)" <dennis.Earp@duke-energy.com>
Tracking Status: None
Post Office: SA1PR09MB9486.namprd09.prod.outlook.com
Files Size Date & Time MESSAGE 3180 4/22/2024 2:26:59 PM Audit-Plan-Harris RIPE Exemption_Final.docx 59322
Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
AUDIT PLAN
REGARDING EXEMPTION REQUEST FROM
CERTAIN REQUIREMENTS IN 10 CFR 50.55a(h)(2) SUBMITTED UNDER
THE RISK-INFORMED PROCESS FOR EVALUATIONS (RIPE)
DUKE ENERGY PROGRESS, LLC.
SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1
DOCKET NO. 50-400
1.0 BACKGROUND
By letter dated February 6, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24037A284), as supplemented letter dated April 3, 2024 (ML24094A105), Duke Energy Progress, LLC (Duke Energy) submitted a request for an exemption from certain requirements of Title 10 of the Code of Federal Regulations (10 CFR)
Section 50.55a(h)(2), Protection systems, for the Shearon Harris Nuclear Power Plant, Unit 1 (Harris).
Specifically, the exemption request would remove the requirement for the Reactor Protection System cables that terminate within the Turbine Control System Cabinet G (1TCS-CAB-G) to meet the requirement in IEEE 279-1971, Criteria for Protection Systems for Nuclear Power Generating Stations, Section 4.6, Channel Independence, that the cables be independent and physically separated. The exemption request was submitted under the Risk-Informed Process for Evaluations (RIPE).
The NRC staffs review of the exemption request has commenced in accordance with the Office of Nuclear Reactor Regulation (NRR) Temporary Staff Guidance TSG-DORL-2021-01, Revision 3, Risk-Informed Process for Evaluations. The NRC staff has determined that a regulatory audit should be conducted in accordance with the NRR Office Instruction LIC-111, Revision 1, Regulatory Audits, dated October 31, 2019 (ML19226A274), for the NRC staff to gain a more detailed understanding of the licensees proposed exemption request.
A regulatory audit is a planned, license-related or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. A 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 the licensing or regulatory decision. Performing a regulatory audit of the licensees information is expected to assist the NRC staff in efficiently conducting its review or gain insights on the licensees processes or procedures.
Enclosure
2.0 REGULATORY AUDIT BASIS
An audit was determined to be the most efficient approach toward a timely resolution of questions associated with this exemption request review. The NRC staff is requesting an initial set of internal licensee information to be reviewed by the staff using an online reference portal.
Upon completion of this audit, the NRC staff is expected to achieve the following.
- 1. Confirm licensee information which supports statements made in the exemption request.
The audit information that the NRC staff determines to be necessary to support the development of the NRC staffs safety evaluation will be requested to be submitted on the docket.
3.0 REGULATORY AUDIT SCOPE OR METHOD
The purpose of the remote audit is to gain a more detailed understanding of licensees proposed exemption request. The areas of focus for the regulatory audit are the information contained in the licensees February 6, 2024, submittal as supplemented, and the proposed audit questions in section 5.0 of this audit plan.
4.0 AUDIT TEAM
The audit will be conducted by NRC staff from the NRR Division of Engineering and External Hazards (DEX), Electrical Engineering Branch (EEEB) and Instrumentation and Controls Branch (EICB). The audit will be led by staff from the NRR Division of Operating Reactor Licensing (DORL). NRC staff from other organizations may be assigned to the team as appropriate and others may participate as observers (such as staff from the Division of Risk Assessment or Regional staff).
The following are members of the NRC audit team:
Team Member Title Organization Mike Mahoney Project Manager NRR/DORL/LPLII-2 Michael.Mahoney@nrc.gov Ming Li Electronics Engineer NRR/DEX/EICB Ming.Li@nrc.gov
5.0 PROPOSED AUDIT QUESTIONS AND INFORMATION REQUEST
Audit Questions
- Confirm and demonstrate the electrical dependency between Turbine Trip System (TTS) trains in the 1TCS-CAB-G cabinet: Confirm and demonstrate the electrical and physical independence of Reactor Protection System (RPS) circuits and cables for redundant trains in RPS cabinet and cable raceway.
- Confirm Terminal Box B and Turbine Control System (TCS) cabinet 1TCS-CAB-G do not contain Class 1E associated circuits.
- Identify TTS associated circuits and confirm whether the TTS circuits were bundled and bound together with various redundant RPS circuits in cable trays and RPS cabinets beyond any credited isolation devices.
- Confirm that the 15-amp power line is in 1TCS-CAB-G. If this is the case, demonstrate this 15-amp design that violates the maximum 1-amp maximum short circuit current allowed by WCAP-8892-A does not degrade the RPS Class 1E circuits below an acceptable level.
- Provide a technical basis to demonstrate that the hot short would be limited to a single RPS train, and all three types of shorts have to occur to impact both RPS trains.
Information Requests
Please make the following information available for the NRC staff to audit:
- 1. A concise description of the 2017 turbine controls modification as referenced in your February 6, 2024, exemption request, with emphasize on circuits and cable running that relate to, and within the proximity to any Class 1E circuits.
- 2. Spatial layout of Terminal Box B and TTS cabinet 1TCS-CAB-G.
- 3. Part of the TTS and RPS schematics that show the interaction between these two systems, including the electrical isolations between safety and non-safety related circuits, power cables and signal cables raceways and their separation.
6.0 LOGISTICS
The audit will be started once an electronic reference portal is set up and the documentation is made available to the NRC staff. The initial desk audit will be conducted over several days. The licensee will be kept informed on a regular basis during periodic discussions with the project manager regarding the progress. The audit may include interactions (e.g., teleconferences or webinars) on a mutually agreeable schedule sufficient to understand or resolve issues associated with the information made available.
7.0 DELIVERABLES
An audit summary will be prepared within 90 days of the completion of the audit. If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the staff will issue RAIs (or requests for confirmatory information (RCIs)) to the licensee.