RA-20-0387, EAL Technical Bases Document Revision 002

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EAL Technical Bases Document Revision 002
ML20351A186
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 12/16/2020
From: Burchfield J
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-20-0387
Download: ML20351A186 (6)


Text

d_~ DUKE

~ ENERGY RA-20-0387 December 16, 2020 Attn: Document Control Desk U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, Maryland 20852-2746

Subject:

Duke Energy Carolinas, LLC 10 CFR 50.54(q) 10 CFR 72.44(f)

Oconee Nuclear Station, Units 1, 2, and 3 Docket Nos. 50-269, -270, and -287 EAL Technical Bases Document Revision 002 J. Ed Burchfield, Jr.

Vice President Oconee Nuclear Station Duke Energy ON01 VP I 7800 Rochester Hwy Seneca, SC 29672 o 864.873.3478 t 864.873.4208 Ed.Burchfield@duke-energy.com 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 2, 2020.

This revision has been evaluated in accordance with 10 CFR 50.54(q) and it was determined that the change 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, J. Ed Burchfield, Jr.

Vice President Oconee Nuclear Station Attachment

1. AR 02356235 Changes In ONS EAL Tech Bases Document CSD-EP-ONS-0101-01 Rev.002

RA-20-0387 December 16, 2020 Page2 xc:

Ms. Laura Dudes Administrator, USNRC Region II Marquis One Tower 245 Peachtree Center., NE Suite 1200 Atlanta GA 30303-1257 Mr. Shawn Williams Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Jared Nadel NRC Senior Resident Inspector Oconee Nuclear Station

AR 02356235 Changes In ONS EAL Tech Bases Document CSD-EP-ONS-0101-01 Rev.002 CSD-EP-ONS-0101-01 (EAL Technical Basis) revision 2 changes:

Screening or Evaluation Number: 02356235 Part I. Identification of ICs and EALs Affected by Proposed Change and the applicable NEI Generic ICs and EALs:

1)

Made editorial changes to improve procedure use (bolded some information, added additional spaces to allow all references to be on same page and similar changes.

2)

Added additional clarification to Emergency Action Level (EAL} Technical Basis for CA6.1 and SA9.1. These are the ONS equivalent for IC NEI 99-01 CA6 and SA9. These changes provide clarifying information and do not change the specific EALs or ICs.

Page /Section Change From Change to

1.

Throughout Old Revision number, table of contents New revision number, updated table of contents as a result procedure updates due to change in the procedure, of procedure changes, updated revision summary identifying revision summary, page numbers.

the changes made from the procedure revision request, and page numbers as a result of the changes to the procedure.

2.

RGl.1 None Added to document:

P.46 One additional space (no words) before last line "Instrumentation that may be used to assess this EAL:

(ref 2):"

3.

CA6.l None Added to document:

P.100 Continued on next page AND SA9.l P. 182

14.

CA6.l None Added to document:

P. 102 One additional space (no words) between "Escalation of the emergency classification level would be via IC RS1".

AND "ONS Basis References"

5.

HU3.2 None Added to document:

P. 119 One additional space (no words) after "Escalation of the emergency classification level would be based on ICs in Recognition Categories R, F, Sor C".

Page 1 of 4

AR 02356235 Changes In ONS EAL Tech Bases Document CSD-EP-ONS-0101-01 Rev.002

~-

HU4.2 Blank page Deleted from document:

P.125 (revision 1)

One entire blank page, no words.

17.

HU7.1 None Added to document:

P. 136 One additional space (no words) before "ONS Basis Reference(s):".

8.

SA9.l One additional space (no words)

None P. 184 between "Escalation of the emergency classification level would be via IC FS1 or RS1".

AND "ONS Basis References"

9.

CA6.l,

None Added to document:

P. 99 AND This EAL is applicable when:

SA9.l, P.181 A single event is significant enough to cause after the 5 damage to 2 trains of the same safety system, bullets OR discussing The event causes damage to a common Basis component that supports 2 trains of the same safety system.

10. CA6.l This IC addresses a hazardous event begins last that causes damage to SAFETY No verbiage added to document, only formatting (made paragraph on SYSTEMS needed for the current existing words "bold'J:

P. 99, operating mode. In order to provide the continues appropriate context for consideration of This IC addresses a hazardous event that causes through end of an ALERT classification, the hazardous damage to SAFETY SYSTEMS needed for the current paragraph on event must have caused indications of operating mode. In order to provide the appropriate P. 100 degraded SAFETY SYSTEM context for consideration of an ALERT classification, the performance in one train, and there hazardous event must have caused indications of must be either indications of degraded SAFETY SYSTEM performance in one performance issues with the second train, and there must be either indications of SAFETY SYSTEM train or VISIBLE performance issues with the second SAFETY DAMAGE to the second train such that SYSTEM train or VISIBLE DAMAGE to the second the potential exists for this second train such that the potential exists for this second SAFETY SYSTEM train to have SAFETY SYSTEM train to have performance issues.

performance issues. In other words, in In other words, in order for this EAL to be classified, the order for this EAL to be classified, the hazardous event must occur, at least one SAFETY hazardous event must occur, at least SYSTEM train must have indications of degraded Page 2 of 4

AR 02356235 Changes In ONS EAL Tech Bases Document CSD-EP-ONS-0101-01 Rev.002 one SAFETY SYSTEM train must have performance, and the second SAFETY SYSTEM train indications of degraded performance, must have indications of degraded performance or AND and the second SAFETY SYSTEM train VISIBLE DAMAGE such that the potential exists for must have indications of degraded performance issues. Note that this second SAFETY performance or VISIBLE DAMAGE SYSTEM train is from the same SAFETY SYSTEM that SA9.1 such that the potential exists for has indications of degraded performance for criteria in begins last performance issues. Note that this the first condition of this EAL; commercial nuclear power second SAFETY SYSTEM train is from plants are designed to be able to support single system paragraph on the same SAFETY SYSTEM that has issues without compromising public health and safety P. 181, indications of degraded performance for from radiological events.

continues criteria in the first condition of this EAL; through end of commercial nuclear power plants are Indications of degraded performance address paragraph on designed to be able to support single damage to a SAFETY SYSTEM train that is in P. 182 system issues without compromising service/operation since indications for it will be public health and safety from readily available. The indications of degraded radiological events.

performance should be significant enough to cause Indications of degraded performance concern regarding the operability or reliability of the address damage to a SAFETY SYSTEM SAFETY SYSTEM train.

train that is in service/operation since indications for it will be readily available.

The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

Page 3 of 4

AR 02356235 Changes In ONS EAL Tech Bases Document CSD-EP-ONS-0101-01 Rev.002 11. CA6.l, P. 101 entire page AND SA9.l P. 183 entire page To accommodate the table, change 11 "Change From" information is moved to this column Change From:

None Added to document:

The examples below can assist in determining the threshold meeting the two train criteria.

(NO Degraded to Train A only prior to the event Performance) and the event impacted only 1 train In Service Event caused damage No Train A was OOS (Degraded to Train B only prior to the event Performance) and the event impacted only 1 train In Service Event causes damage Yes The event was (Degraded to both trains significant enough to (Visible Damage)

Performance) impact two trains.

In STBY Event caused damage No Cannot classify on (Visible Damage)

(Visible Damage) to both trains Visible Damage only In STBY Event caused damage Yes The event was (Visible Damage) to both trains significant enough to Performance) impact two trains In Service Event causes damage Yes The event was (Degraded to both trains significant enough to Performance)

Performance) impact two trains In Service OR Event caused cdamage Yes The event impacted in STBY to a common equipment common component to both to two or more trains trains (i.e. BWST)

Page 4 of 4