RA-19-0469, Emergency Plan Revisions 2019-005, 2019-006, and 2019-007
| ML19352G690 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 12/18/2019 |
| From: | Burchfield J Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RA-19-0469 | |
| Download: ML19352G690 (9) | |
Text
( ~ DUKE ENERGY J. Ed Burchfield, Jr.
Vice President Oconee Nuclear Station Duke Energy ON01VP I 7800 Rochester Hwy Seneca, SC 29672 RA-19-0469 o 864.873.3478 f 864.873.4208 December 18, 2019 10 CFR 50.54(q) Ed.Burchfiefd@duke-energy.com 10 CFR 72.44(f)
Attn: Document Control Desk U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, Maryland 20852-27 46
Subject:
Duke Energy Carolinas, LLC Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287 Emergency Plan Revisions 2019-005, 2019-006, and 2019-007 Pursuant to 10 CFR 50.54(q), and 10 CFR 72.44(f), Duke Energy is submitting the attached summary of changes to the Oconee Nuclear Station (ONS) Emergency Plan which became effective December 16, 2019.
These revisions have been evaluated in accordance with 10 CFR 50.54(q) and it was determined that the changes did not reduce the effectiveness of the ONS Emergency Plan. The revised ONS Emergency Plan continues to meet the requirements of Appendix E to 10 CFR 50 and the planning standards of 10 CFR 50.47(b).
If there are any questions or concerns pertaining to this revision please call Sheila Dalton, Manager Nuclear Support Services, at 864-873-3657.
Sincerely,
) Ll~ )
J. Ed Burchfield, Jr.
Vice President Oconee Nuclear Station Attachments Change Summary for ONS E-Plan Revision 2019-005 Change Summary for ONS E-Plan Revision 2019-006 Change Summary for ONS E-Plan Revision 2019-007
RA-19-0469 U. S. Nuclear Regulatory Commission December 18, 2019 Page 2 xc: Ms. Laura Dudes Administrator, USNRC Region II Marquis One Tower 245 Peachtree Center., NE Suite 1200 Atlanta GA 30303-1257 Ms. Audrey Klett Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop O-8G9A Rockville, MD 20852-2738 Mr. Jared Nadel NRC Senior Resident Inspector Oconee Nuclear Station
CHANGE
SUMMARY
FOR ONS E-PLAN REVISION 2019-005 Under ML19058A632 Oconee Nuclear Stations Section D revision 2019-005 includes changes to EALs and the technical basis for the following EALs:
- CA6.1 Alert
- Removed HG1.1
- SA9.1 Alert ML19058A632 Letter dated July 1, 2019.
Subject:
Catawba Nuclear Station, Units 1 And 2; McGuire Nuclear Station, Units 1 And 2; Oconee Nuclear Station, Units 1, 2, And 3; Brunswick Steam Electric Plant, Units 1 And 2; Shearon Harris Nuclear Power Plant, Unit 1; And H. B. Robinson Steam Electric Plant, Unit No. 2 - Issuance of Amendments To Revise Emergency Action Level Schemes To Incorporate Clarifications Provided By Emergency Preparedness Frequently Asked Questions 2015-013, 2015-014, And 2016-002 (EPID L-2018-LLA-0174)
Amendment Nos. 303 and 299 to Renewed Facility Operating License Nos. NPF-35 and NPF-52 for the Catawba Nuclear Station, Units 1 and 2 (Catawba), respectively; Amendment Nos. 315 and 294 to Renewed Facility Operating License Nos. NPF-9 and NPF-17 for the McGuire Nuclear Station, Units 1 and 2 (McGuire), respectively; Amendment Nos. 412, 414, and 413 to Renewed Facility Operating License Nos. DPR-38, DPR-47, and DPR-55 for the Oconee Nuclear Station, Units 1, 2, and 3 (Oconee),
respectively; Amendment Nos. 291 and 319 to Renewed Facility Operating License Nos. DPR-71 and DPR-62 for Brunswick Steam Electric Plant, Units 1 and 2 (Brunswick), respectively; Amendment No. 172 to Renewed Facility Operating License No. NPF-63 for the Shearon Harris Nuclear Power Plant, Unit 1 (Harris); and Amendment No. 264 to Renewed Facility Operating License No. DPR-23 for the H. B.
Robinson Steam Electric Plant, Unit No. 2 (Robinson).
CHANGE
SUMMARY
FOR ONS E-PLAN REVISION 2019-006 Attachment to 50.54q CHANGE MATRIX
- Page Current Proposed Change Reason
/Section
- 1. D-100 N/A An event affecting equipment Additional CA6.1 common to two or more safety Clarification systems or safety system trains added from new (i.e., there are indications of EPFAQ 2018-04 paragraphs degraded performance and/or inserted VISIBLE DAMAGE affecting the prior to common equipment) should be last classified as an Alert under CA6, as paragraph appropriate to the plant mode. By affecting the operability or reliability of multiple system trains, the loss of the common equipment effectively meets the two-train impact criteria that underlie the EALs and Bases.
An event affecting a single-train safety system (i.e., there are indications of degraded performance and/or VISIBLE DAMAGE affecting the one train) would not be classified under CA6 because the two-train impact criteria that underlie the EALs and Bases would not be met. If an event affects a single-train safety system, then the emergency classification should be made based on plant parameters/symptoms meeting the EALs for another IC. Depending upon the circumstances, classification may also occur based on Shift Manager/Emergency Director judgement.
An event that affects two trains of a safety system (e.g., one train has indications of degraded performance and the other VISIBLE DAMAGE) that also has
CHANGE
SUMMARY
FOR ONS E-PLAN REV 2019-006 (Contd)
Attachment to 50.54q CHANGE MATRIX
- Page Current Proposed Change Reason
/Section one or more additional trains should be classified as an Alert under CA6, as appropriate to the plant mode. This approach maintains consistency with the two-train impact criteria that underlie the EALs and Bases, and is warranted because the event was severe enough to affect the operability or reliability of two trains of a safety system despite plant design criteria associated with system and system train separation and protection. Such an event may have caused other plant impacts that are not immediately apparent.
- 2. D-181 N/A An event affecting equipment Additional SA9.1 common to two or more safety Clarification systems or safety system trains added from (i.e., there are indications of EPFAQ 2018-04 new degraded performance and/or paragraphs VISIBLE DAMAGE affecting the inserted common equipment) should be prior to classified as an Alert under SA9, last as appropriate to the plant paragraph mode. By affecting the operability or reliability of multiple system trains, the loss of the common equipment effectively meets the two-train impact criteria that underlie the EALs and Bases.
An event affecting a single-train safety system (i.e., there are indications of degraded performance and/or VISIBLE
CHANGE
SUMMARY
FOR ONS E-PLAN REV 2019-006 (Contd)
Attachment to 50.54q CHANGE MATRIX
- Page Current Proposed Change Reason
/Section DAMAGE affecting the one train) would not be classified under SA9 because the two-train impact criteria that underlie the EALs and Bases would not be met. If an event affects a single-train safety system, then the emergency classification should be made based on plant parameters/symptoms meeting the EALs for another IC.
Depending upon the circumstances, classification may also occur based on Shift Manager/Emergency Director judgement.
An event that affects two trains of a safety system (e.g., one train has indications of degraded performance and the other VISIBLE DAMAGE) that also has one or more additional trains should be classified as an Alert under SA9, as appropriate to the plant mode. This approach maintains consistency with the two-train impact criteria that underlie the EALs and Bases, and is warranted because the event was severe enough to affect the operability or reliability of two trains of a safety system despite plant design criteria associated with system and system train separation and protection. Such an event may have caused other plant impacts that are not
CHANGE
SUMMARY
FOR ONS E-PLAN REV 2019-006 (Contd)
Attachment to 50.54q CHANGE MATRIX
- Page Current Proposed Change Reason
/Section immediately apparent.
- 3. D-191 OR OR RVLS not valid with forced flow, Note 9 LPI pump(s) are running AND LPI pump(s) are running suction source is taking suction from the LPI not significant.
drop line
- 4. D-191 RVLS indicated level 0 RVLS indicated level 0 with all RVLS not valid with all RCPs not running RCPs not running and both LPI with forced flow, 1st par and both LPI pumps taking pumps not running represents suction source is suction from the drop line reactor vessel level below the not significant.
not running represents bottom of the RCS hotleg reactor vessel level below (without instrument uncertainty the bottom of the RCS hotleg considered).
(without instrument uncertainty considered).
- 5. D-203 N/A If EOPs direct operators to open Additional the Pressurizer pressure relief Clarification RCS - Loss valves to implement a core added from inserted cooling strategy (i.e., a feed EPFAQ 2018-01 between and bleed cooldown), then 3rd and there will exist a reactor coolant 4th par. flow path from the RCS, past the pressurizer safety and relief valves and into the containment that operators cannot isolate without compromising the effectiveness of the strategy (i.e., for the strategy to be effective, the valves must be kept in the open position); therefore, the flow through the pressure relief line is UNISOLABLE. In this case, the ability of the RCS pressure boundary to serve as an effective barrier to a release of fission products has been
CHANGE
SUMMARY
FOR ONS E-PLAN REV 2019-006 (Contd)
Attachment to 50.54q CHANGE MATRIX
- Page Current Proposed Change Reason
/Section eliminated and thus this condition constitutes a loss of the RCS barrier
- 6. D-3 ....Decision-makers ....Decision-makers responsible Remove site responsible for for Emergency Classification document first par.
implementation of may use this document as a reference, RP/0/A/1000/001, technical reference in support of superseded by Emergency Classification, EAL interpretation. fleet guidance.
may use this document as a technical reference in support of EAL interpretation.
- 7. D-13 4.2.1 RP/0/A/1000/001 4.2.1 AD-EP-ALL-0101 Remove site Emergency Classification Emergency Classification document 4.2.1 reference superseded by fleet guidance.
CHANGE
SUMMARY
FOR ONS E-PLAN REVISION 2019-007 Changed the name and document number for the EAL Technical Basis document for fleet consistency
- Section or Current wording Proposed Wording Reason Step 1 Title and Emergency Plan Oconee CSD-EP-ONS- Changed title and Document Section D 0101-01, EAL document number for number for Emergency Technical Basis fleet consistency Oconee Classification Document System Emergency Action Level Technical Bases Removing the EAL Technical Basis document out of the Emergency Plan Section D and placing the Technical Basis in a standalone document CSD-EP-ONS-0101-01. The EAL Technical Basis will be incorporated into the emergency plan by reference. Section D will refer directly to the CSD.