RA-23-0276, Response to Request for Additional Information Regarding License Amendment Request to Align Certain Technical Specification Requirements with Industry Standards Provided in Improved Standard Technical Specific

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Response to Request for Additional Information Regarding License Amendment Request to Align Certain Technical Specification Requirements with Industry Standards Provided in Improved Standard Technical Specific
ML23311A076
Person / Time
Site: Harris Duke energy icon.png
Issue date: 11/06/2023
From: Haaf T
Duke Energy Progress
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
RA-23-0276
Download: ML23311A076 (1)
v • d • e


Text

Thomas P. Haaf Site Vice President Harris Nuclear Plant 5413 Shearon Harris Rd New Hill, NC 27562-9300 984-229-2512 10 CFR 50.90 November 6, 2023 Serial: RA-23-0276 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:

Response to Request for Additional Information Regarding License Amendment Request to Align Certain Technical Specification Requirements with Industry Standards Provided in Improved Standard Technical Specifications Ladies and Gentlemen:

By application dated May 31, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23151A724), Duke Energy Progress, LLC (Duke Energy),

submitted a license amendment request (LAR) to revise the Technical Specifications (TS) for the Shearon Harris Nuclear Power Plant, Unit 1 (Harris). The proposed amendment to the Harris TS will modify Surveillance Requirement (SR) 4.6.1.1 to eliminate the requirement to perform periodic position verification for containment penetrations that are maintained locked, sealed, or otherwise secured closed, as well as adopt TS Task Force (TSTF) Improved Standard TS Change Traveler No. 45 (TSTF-45-A), Exempt Verification of Containment Isolation Valves that are Not Locked, Sealed, or Otherwise Secured (ADAMS Accession No. ML040400137). The proposed amendment will also revise Harris TS 3.3.3.5, Remote Shutdown System, to increase the Completion Time for inoperable Remote Shutdown System components to a time that is more consistent with their safety significance and remove the requirement to submit a Special Report. It will also relocate the content in Table 3.3-9, Remote Shutdown System, and Table 4.3-6, Remote Shutdown Monitoring Instrumentation Surveillance Requirements, in accordance with TSTF-266-A, Revision 3, Eliminate the Remote Shutdown System Table of Instrumentation and Controls (ADAMS Accession No. ML040620072). Additionally, the proposed amendment will update Harris SR 4.3.1.1, Table 4.3-1, Reactor Trip System Instrumentation Surveillance Requirements, to address the application of the Surveillance Frequency Control Program (SFCP) to establish the Frequency for performance of the Analog Channel Operational Test (ACOT) of select Reactor Trip System (RTS) instrumentation. Changes are also proposed to the Administrative Controls Section of the Harris TS to reflect current organizational titles as well as remove reporting requirements that are redundant to existing regulations. The proposed changes above reflect requirements consistent with those in Revision 5 of NUREG-1431, Standard Technical Specifications -

Westinghouse Plants (ADAMS Accession No. ML21259A155).

The NRC staff reviewed the LAR and determined that additional information is needed to complete their review. Duke Energy received the request for additional information (RAI) from

U.S. Nuclear Regulatory Commission Page 2 of 2 Serial: RA-23-0276 the NRG through electronic mail on October 6, 2023 (ADAMS Accession No. ML23283A014).

The enclosure to this letter provides Duke Energy's response to the RAI. An attachment to the enclosure provides a revised mark-up of proposed Harris TS 3.3.3.5 based upon the response to the RAI.

This additional information does not change the No Significant Hazards Determination provided in the original submittal. No regulatory commitments are contained within this letter.

Please refer any questions regarding this submittal to Ryan Treadway, Director- Nuclear Fleet Licensing, at 980-373-5873.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on November 6, 2023.

Sincerely, Thomas P. Haaf Site Vice President Harris Nuclear Plant

Enclosure:

Response to Request for Additional Information

Attachment:

Revised Mark-up for Technical Specification 3.3.3.5 Proposed Change cc: P. Boguszewski, Senior NRG Resident Inspector, HNP L. Brayboy, Radioactive Materials Branch Manager, N.C. DHSR M. Mahoney, NRG Project Manager, HNP L. Dudes, NRG Regional Administrator, Region II

U.S. Nuclear Regulatory Commission Serial: RA-23-0276 Enclosure ENCLOSURE RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400 RENEWED LICENSE NUMBER NPF-63

U.S. Nuclear Regulatory Commission Page 1 of 3 Serial: RA-23-0276 Enclosure Response to Request for Additional Information By application dated May 31, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23151A724), Duke Energy Progress, LLC (Duke Energy),

submitted a license amendment request (LAR) to revise the Technical Specifications (TS) for the Shearon Harris Nuclear Power Plant, Unit 1 (Harris). The proposed amendment to the Harris TS will modify Surveillance Requirement (SR) 4.6.1.1 to eliminate the requirement to perform periodic position verification for containment penetrations that are maintained locked, sealed, or otherwise secured closed, as well as adopt TS Task Force (TSTF) Improved Standard TS Change Traveler No. 45 (TSTF-45-A), Exempt Verification of Containment Isolation Valves that are Not Locked, Sealed, or Otherwise Secured (ADAMS Accession No. ML040400137). The proposed amendment will also revise Harris TS 3.3.3.5, Remote Shutdown System, to increase the Completion Time for inoperable Remote Shutdown System components to a time that is more consistent with their safety significance and remove the requirement to submit a Special Report. It will also relocate the content in Table 3.3-9, Remote Shutdown System, and Table 4.3-6, Remote Shutdown Monitoring Instrumentation Surveillance Requirements, in accordance with TSTF-266-A, Revision 3, Eliminate the Remote Shutdown System Table of Instrumentation and Controls (ADAMS Accession No. ML040620072). Additionally, the proposed amendment will update Harris SR 4.3.1.1, Table 4.3-1, Reactor Trip System Instrumentation Surveillance Requirements, to address the application of the Surveillance Frequency Control Program (SFCP) to establish the Frequency for performance of the Analog Channel Operational Test (ACOT) of select Reactor Trip System (RTS) instrumentation. Changes are also proposed to the Administrative Controls Section of the Harris TS to reflect current organizational titles as well as remove reporting requirements that are redundant to existing regulations. The proposed changes above reflect requirements consistent with those in Revision 5 of NUREG-1431, Standard Technical Specifications -

Westinghouse Plants (ADAMS Accession No. ML21259A155).

The NRC staff reviewed the LAR and determined that additional information is needed to complete their review. Duke Energy received the request for additional information (RAI) from the NRC through electronic mail on October 6, 2023 (ADAMS Accession No. ML23283A014).

RAI-1

Regulations at 10 CFR 50.36(c)(2) states that technical specifications (TS) shall contain limiting conditions for operation [LCO]. It further states that limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

NUREG-1431, Volume 2, Revision 5 (referred to herein as the STS [Standard Technical Specifications]) states the following about the SSCs [Systems, Structures, and Components]

covered by the Remote Shutdown System LCO (LCO 3.3.4):

The Remote Shutdown System LCO provides the OPERABILITY requirements of the instrumentation and controls necessary to place and maintain the unit

U.S. Nuclear Regulatory Commission Page 2 of 3 Serial: RA-23-0276 Enclosure in MODE 3 from a location other than the control room. The instrumentation and controls required are listed in Table B 3.3.4-1.

The controls, instrumentation, and transfer switches are required for:

  • Core reactivity control (initial and long term),
  • RCS pressure control,
  • RCS inventory control via charging flow, and
  • Safety support systems for the above Functions, including service water, component cooling water, and onsite power, including the diesel generators.

[Emphasis added]

Based on this description, the LCO applies to all instrumentation and controls needed to perform the safety functions required by the LCO. STS Required Action A.1 provides a 30-day Completion Time to restore the Remote Shutdown System to operable status when one or more required functions are inoperable. Required Actions B.1 and B.2 require the plant to be placed in a Mode where the LCO does not apply (i.e., Hot Standby within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Hot Shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) if Required Action A.1 is not met. Therefore, the same shutdown requirement in the STS applies to both the instrument channels and the required support equipment, such as transfer switches and control panels.

The Harris TS have separate action statements for the Remote Shutdown System monitoring instrumentation channels (LCO 3.3.3.5.a, and Action a) and for all transfer switches, Auxiliary Control Panel Controls and Auxiliary Transfer Panel Controls (LCO 3.3.3.5.b, and Action c).

Both Actions currently require restoration to operable status within 7 days; however, if the Completion Time for Action a is not met, the licensee is required to place the plant in HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, whereas if the Completion Time for Action c is not met, the licensee is required to place the plant in HOT STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The LAR proposes to revise the Completion Time from 7 days to 30 days for both Actions. In addition, the LAR proposes to modify the shutdown requirement Completion Times for Action a to align with the STS Required Actions B.1 and B.2. However, the LAR does not propose to modify the Action c requirements to match the STS. The NRC staff notes that Action c does not require the unit to be placed in a Mode where the LCO no longer applies even though the Action applies when the LCO and the specified action (restore to operable status) have not been met.

10 CFR 50.36 states, When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met. [Emphasis added] It is unclear how the proposed revisions to Action c meet the requirements of 10 CFR 50.36.

Please provide the technical basis for different shutdown requirements for TS LCO 3.3.3.5 Actions a and c, including the differences in time to shutdown and the differences in endstates (i.e., HOT SHUTDOWN versus HOT STANDBY).

U.S. Nuclear Regulatory Commission Page 3 of 3 Serial: RA-23-0276 Enclosure Duke Energy Response The use of HOT STANDBY in TS LCO 3.3.3.5 Action c has existed since the original issuance of the Harris TS (ADAMS Accession No. ML18004B700). Recognizing that this Action does not currently place the unit in a Mode in which the LCO is not applicable, Duke Energy requests that the Action be revised to reflect the same shutdown requirement and Completion Time as that requested for Action a, which is consistent with a controlled plant shutdown. This will further align the Harris TS with the requirements provided in the STS as well as meet the 10 CFR 50.36 requirement that a licensee shall shut down the reactor when a LCO is not met. The updated proposed change to Action c is as follows:

c. With one or more inoperable Remote Shutdown System transfer switches, power, or control circuits required by 3.3.3.5.b, restore the inoperable switch(s)/circuit(s) to OPERABLE status within 7 days 30 days, or be in HOT STANDBY within the next 12 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

An updated proposed mark-up of TS Page 3/4 3-63 is provided in the Attachment to this Enclosure.

U.S. Nuclear Regulatory Commission Serial: RA-23-0276 Enclosure - Attachment ATTACHMENT REVISED MARK-UP FOR TECHNICAL SPECIFICATION 3.3.

3.5 PROPOSED CHANGE

INSTRUMENTATION specified in the Technical Requirements Manual REMOTE SHUTDOWN SYSTEM LIMITING CONDITION FOR OPERATION 3.3.3.5.a The Remote Shutdown System monitoring instrumentation channels shown in Table 3.3-9 shall be OPERABLE.

3.3.3.5.b All transfer switches, Auxiliary Control Panel Controls and Auxiliary Transfer Panel Controls for the OPERABILITY of those components required by the SHNPP Safe Shutdown Analysis to (1) remove decay heat via auxiliary feedwater flow and steam generator power-operated relief valve flow from steam generators A and B, (2) control RCS inventory through the normal charging flow path, (3) control RCS pressure, (4) control reactivity, and (5) remove decay heat via the RHR system shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTION: 30 days

a. With the number of OPERABLE remote shutdown monitoring channels less than STANDBY within the Minimum Channels OPERABLE as required by Table 3.3-9, restore the the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> inoperable channel(s) to OPERABLE status within 7 days, or be in HOT and in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

SHUTDOWN b. With the number of OPERABLE remote shutdown monitoring channels less than within the following the Total Number of Channels required by Table 3.3-9, restore the inoperable 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. channels to OPERABLE status within 60 days or submit a Special Report in accordance with Specification 6.9.2 within 14 additional days. DELETED.

c. With one or more inoperable Remote Shutdown System transfer switches, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in power, or control circuits required by 3.3.3.5.b, restore the inoperable HOT SHUTDOWN switch(s)/circuit(s) to OPERABLE status within 7 days, or be in HOT STANDBY within the following within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. 30 days

~..._______.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. specified in the Surveillance Frequency SURVEILLANCE REQUIREMENTS Control Program.

4.3.3.5.1 Each remote shutdown monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION operations at the frequencies shown in Table 4.3-6.

4.3.3.5.2 Each Remote Shutdown System transfer switch, power and control circuit and control switch required by 3.3.3.5.b, shall be demonstrated OPERABLE at the frequency specified in the Surveillance Frequency Control Program.

Add:

Pages 3/4 3-64 through 3/4 3-65 deleted by Amendment No. XXX SHEARON HARRIS - UNIT 1 3/4 3-63 Amendment No. 179

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