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{{#Wiki_filter:}} | {{#Wiki_filter:July 14, 2008 Robert J. Duncan II, Vice President Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165 | ||
==SUBJECT:== | |||
SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - ACCEPTANCE REVIEW REGARDING THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST NUMBER 13R-02 (TAC NO. MD8742) | |||
By letter dated April 29, 2008 (Agencywide Documents Access and Management System Accession No. ML081330461), Carolina Power and Light Company, now doing business as Progress Energy Carolinas, Inc. (PEC), submitted Relief Request 13R-02 for the Shearon Harris Nuclear Power Plant, Unit 1 (HNP). The proposed relief request would allow the selection of piping welds based on a risk-informed (RI) selection and examination program as an alternative to a portion of HNP's current inservice inspection (ISI) program. | |||
Pursuant to Sections 50.55a(a)(3)(i) and 50.55a(a)(3)(ii) of Title 10 of the Code of Federal Regulations (10 CFR), the applicant shall demonstrate that the proposed alternative would provide an acceptable level of quality and safety, or that compliance with the specified requirements of Section 50.55a would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety. For HNP Relief Request 13R-02, t states that the alternative would continue to provide an acceptable level of quality and safety. | |||
The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff's acceptance review of this request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review and make an independent assessment regarding the acceptability of the proposed change. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant. | |||
In Relief Request 13R-02, HNP requests to implement an RI-ISI program based on the "Revised Risk-Informed Inservice Inspection Evaluation Procedure" (EPRI TR-112657, Revision B-A, December 1999). Review of proposed RI-ISI programs is performed in accordance with Regulatory Guide (RG) 1.178, "An Approach for Plant-Specific Risk-Informed Decisionmaking for Inservice Inspection of Piping." | |||
R. Duncan | |||
RG 1.178 states that, when completed, Draft Guide (DG) 1122, "An Approach for Determining the Technical Adequacy of Probab ilistic Risk Assessment [(PRA)] Results for Risk-Informed Activities," will provide guidance on determining the quality of the PRA that is sufficient to provide confidence in the results such that they can be used in regulatory decisionmaking for light-water reactors. DG-1122 was issued as RG 1.200, Revision 1, in January 2005. As clarified in Regulatory Issue Summary 2007-06, "Regulatory Guide 1.200 Implementation," issued on March 22, 2007, the NRC staff will use Revision 1 of RG 1.200 to assess the technical adequacy of the PRA for requested changes in all RI applications received after December 2007. | |||
RG 1.200 describes an acceptable approach for defining the technical adequacy of a base PRA. | |||
This assessment can be performed by directly comparing the base PRA to the supporting requirements in the endorsed American Society of Mechanical Engineers Standard RA-Sb-2005, and addressing the staff position on each requirement discussed in Appendix A of RG 1.200. | |||
Alternatively, the licensee can perform a self assessment using the results of a previous peer review performed in accordance with the process documented in the Nuclear Energy Institute (NEI) report, NEI 00-02, and addressing the staff position on each requirement discussed in Appendix B of RG 1.200. | |||
HNP Relief Request 13R-02 very briefly summarizes the technical adequacy of the HNP PRA and refers to RG 1.200. However, the summary does not provide sufficient information regarding when the reviews were performed, who performed the reviews, which versions of the PRA were reviewed, and what guideline documents were used during the reviews to demonstrate that the reviews are consistent with RG 1.200. The submittal also does not provide any alternative measure of technical adequacy. Without the required information regarding the technical adequacy of the PRA, the staff does not have sufficient information to begin its review. | |||
HNP Relief Request 13R-02 should be supplemented to provide a discussion confirming that either RG 1.200 guidelines on PRA technical adequacy have been evaluated and satisfied, or to provide and justify an acceptable alternative approach. Supporting requirements in the endorsed standard that have not been met, and all observations developed during the review(s), | |||
should be resolved or demonstrated to be unimportant to the resulting RI-ISI program. | |||
The NRC staff has reviewed your application and concluded that the information delineated above is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed relief request in terms of regulatory requirem ents and the protection of public health and safety and the environment. | |||
In order to make the application complete, the NRC staff requests that HNP supplement the relief request to address the info rmation requested above by June 20, 2008. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff | |||
=s request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC staff will cease its review activities associated with the application. If the relief request is subsequently accepted for review, you will be advised of any further information needed to support the NRC staff | |||
=s detailed technical review by separate correspondence. | |||
R. Duncan | |||
The information requested and the associated time frame outlined in this letter were discussed with Dave Corlett, Kara Stacy, and other members of your staff on June 4, 2008. If you have any questions, please contact me at (301) 415-3178. | |||
Sincerely, | |||
/RA/ Marlayna Vaaler, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation | |||
Docket No. 50-400 | |||
cc: See next page | |||
ML081890498 NRR-106 OFFICE LPL2-2/PM LPL2-2/LA DRA/APLA/BC LPL2-2/BC NAME MVaaler CSola MRubin TBoyce (FSaba for) | |||
DATE 07/14/08 07/11/08 07/14/08 07/14/08 Mr. Robert J. Duncan II Shearon Harris Nuclear Power Plant, Carolina Power & Light Company Unit No. 1 | |||
cc: | |||
Mr. Kelvin Henderson Plant General Manager Shearon Harris Nuclear Power Plant Progress Energy Carolinas, Inc. | |||
Post Office Box 165, Mail Zone 3 New Hill, North Carolina 27562-0165 | |||
Mr. Chris L. Burton Director of Site Operations Shearon Harris Nuclear Power Plant Progress Energy Carolinas, Inc. | |||
Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165 | |||
Mr. David H. Corlett, Supervisor Licensing/Regulatory Programs Shearon Harris Nuclear Power Plant Progress Energy Carolinas, Inc. | |||
Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165 | |||
Ms. Phyllis N. Mentel, Manager Support Services Shearon Harris Nuclear Power Plant Progress Energy Carolinas, Inc. | |||
Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165 | |||
Resident Inspector / Harris NPS c/o U. S. Nuclear Regulatory Commission 5421 Shearon Harris Road New Hill, North Carolina 27562-9998 | |||
Mr. J. Paul Fulford Manager, Performance Evaluation and Regulatory Affairs PEB 5 Progress Energy Carolinas, Inc. | |||
Post Office Box 1551 Raleigh, North Carolina 27602-1551 | |||
Mr. David T. Conley Associate General Counsel II - | |||
Legal Department Progress Energy Service Company, LLC Post Office Box 1551 Raleigh, North Carolina 27602-1551 | |||
Chairman of the North Carolina Utilities Commission Post Office Box 29510 Raleigh, North Carolina 27626-0510 Public Service Commission State of South Carolina Post Office Drawer 11649 Columbia, South Carolina 29211 Ms. Beverly Hall, Section Chief Division of Radiation Protection N.C. Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, North Carolina 27609-7721 | |||
Mr. Robert P. Gruber Executive Director Public Staff NCUC 4326 Mail Service Center Raleigh, North Carolina 27699-4326 | |||
Ms. Margaret A. Force Assistant Attorney General State of North Carolina Post Office Box 629 Raleigh, North Carolina 27602 | |||
Mr. Tony Gurley, Chair Board of County Commissioners of Wake County Post Office Box 550 Raleigh, North Carolina 27602 | |||
Mr. Carl Thompson, Chair Board of County Commissioners of Chatham County Post Office Box 87 Pittsboro, North Carolina 27312 | |||
Mr. John H. O'Neill, Jr. | |||
Pillsbury Winthrop Shaw Pittman, LLP 2300 N Street NW. | |||
Washington, DC 20037-1128 | |||
Mr. John D. Runkle Attorney at Law Post Office Box 3793 | |||
Chapel Hill, Nort h Carolina 27515-3793 | |||
Mr. Jim Warren NC Waste Awareness & Reduction Network Post Office Box 61051 Durham, North Carolina 27715-1051}} | |||
Revision as of 11:20, 20 September 2018
| ML081890498 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/14/2008 |
| From: | Vaaler M G NRC/NRR/ADRO/DORL/LPLII-2 |
| To: | Duncan R J Carolina Power & Light Co |
| Vaaler, Marlayna, NRR/DORL 415-3178 | |
| References | |
| TAC MD8742 | |
| Download: ML081890498 (5) | |
Text
July 14, 2008 Robert J. Duncan II, Vice President Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165
SUBJECT:
SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - ACCEPTANCE REVIEW REGARDING THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST NUMBER 13R-02 (TAC NO. MD8742)
By letter dated April 29, 2008 (Agencywide Documents Access and Management System Accession No. ML081330461), Carolina Power and Light Company, now doing business as Progress Energy Carolinas, Inc. (PEC), submitted Relief Request 13R-02 for the Shearon Harris Nuclear Power Plant, Unit 1 (HNP). The proposed relief request would allow the selection of piping welds based on a risk-informed (RI) selection and examination program as an alternative to a portion of HNP's current inservice inspection (ISI) program.
Pursuant to Sections 50.55a(a)(3)(i) and 50.55a(a)(3)(ii) of Title 10 of the Code of Federal Regulations (10 CFR), the applicant shall demonstrate that the proposed alternative would provide an acceptable level of quality and safety, or that compliance with the specified requirements of Section 50.55a would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety. For HNP Relief Request 13R-02, t states that the alternative would continue to provide an acceptable level of quality and safety.
The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff's acceptance review of this request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review and make an independent assessment regarding the acceptability of the proposed change. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
In Relief Request 13R-02, HNP requests to implement an RI-ISI program based on the "Revised Risk-Informed Inservice Inspection Evaluation Procedure" (EPRI TR-112657, Revision B-A, December 1999). Review of proposed RI-ISI programs is performed in accordance with Regulatory Guide (RG) 1.178, "An Approach for Plant-Specific Risk-Informed Decisionmaking for Inservice Inspection of Piping."
R. Duncan
RG 1.178 states that, when completed, Draft Guide (DG) 1122, "An Approach for Determining the Technical Adequacy of Probab ilistic Risk Assessment [(PRA)] Results for Risk-Informed Activities," will provide guidance on determining the quality of the PRA that is sufficient to provide confidence in the results such that they can be used in regulatory decisionmaking for light-water reactors. DG-1122 was issued as RG 1.200, Revision 1, in January 2005. As clarified in Regulatory Issue Summary 2007-06, "Regulatory Guide 1.200 Implementation," issued on March 22, 2007, the NRC staff will use Revision 1 of RG 1.200 to assess the technical adequacy of the PRA for requested changes in all RI applications received after December 2007.
RG 1.200 describes an acceptable approach for defining the technical adequacy of a base PRA.
This assessment can be performed by directly comparing the base PRA to the supporting requirements in the endorsed American Society of Mechanical Engineers Standard RA-Sb-2005, and addressing the staff position on each requirement discussed in Appendix A of RG 1.200.
Alternatively, the licensee can perform a self assessment using the results of a previous peer review performed in accordance with the process documented in the Nuclear Energy Institute (NEI) report, NEI 00-02, and addressing the staff position on each requirement discussed in Appendix B of RG 1.200.
HNP Relief Request 13R-02 very briefly summarizes the technical adequacy of the HNP PRA and refers to RG 1.200. However, the summary does not provide sufficient information regarding when the reviews were performed, who performed the reviews, which versions of the PRA were reviewed, and what guideline documents were used during the reviews to demonstrate that the reviews are consistent with RG 1.200. The submittal also does not provide any alternative measure of technical adequacy. Without the required information regarding the technical adequacy of the PRA, the staff does not have sufficient information to begin its review.
HNP Relief Request 13R-02 should be supplemented to provide a discussion confirming that either RG 1.200 guidelines on PRA technical adequacy have been evaluated and satisfied, or to provide and justify an acceptable alternative approach. Supporting requirements in the endorsed standard that have not been met, and all observations developed during the review(s),
should be resolved or demonstrated to be unimportant to the resulting RI-ISI program.
The NRC staff has reviewed your application and concluded that the information delineated above is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed relief request in terms of regulatory requirem ents and the protection of public health and safety and the environment.
In order to make the application complete, the NRC staff requests that HNP supplement the relief request to address the info rmation requested above by June 20, 2008. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff
=s request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC staff will cease its review activities associated with the application. If the relief request is subsequently accepted for review, you will be advised of any further information needed to support the NRC staff
=s detailed technical review by separate correspondence.
R. Duncan
The information requested and the associated time frame outlined in this letter were discussed with Dave Corlett, Kara Stacy, and other members of your staff on June 4, 2008. If you have any questions, please contact me at (301) 415-3178.
Sincerely,
/RA/ Marlayna Vaaler, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket No. 50-400
cc: See next page
ML081890498 NRR-106 OFFICE LPL2-2/PM LPL2-2/LA DRA/APLA/BC LPL2-2/BC NAME MVaaler CSola MRubin TBoyce (FSaba for)
DATE 07/14/08 07/11/08 07/14/08 07/14/08 Mr. Robert J. Duncan II Shearon Harris Nuclear Power Plant, Carolina Power & Light Company Unit No. 1
cc:
Mr. Kelvin Henderson Plant General Manager Shearon Harris Nuclear Power Plant Progress Energy Carolinas, Inc.
Post Office Box 165, Mail Zone 3 New Hill, North Carolina 27562-0165
Mr. Chris L. Burton Director of Site Operations Shearon Harris Nuclear Power Plant Progress Energy Carolinas, Inc.
Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165
Mr. David H. Corlett, Supervisor Licensing/Regulatory Programs Shearon Harris Nuclear Power Plant Progress Energy Carolinas, Inc.
Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165
Ms. Phyllis N. Mentel, Manager Support Services Shearon Harris Nuclear Power Plant Progress Energy Carolinas, Inc.
Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165
Resident Inspector / Harris NPS c/o U. S. Nuclear Regulatory Commission 5421 Shearon Harris Road New Hill, North Carolina 27562-9998
Mr. J. Paul Fulford Manager, Performance Evaluation and Regulatory Affairs PEB 5 Progress Energy Carolinas, Inc.
Post Office Box 1551 Raleigh, North Carolina 27602-1551
Mr. David T. Conley Associate General Counsel II -
Legal Department Progress Energy Service Company, LLC Post Office Box 1551 Raleigh, North Carolina 27602-1551
Chairman of the North Carolina Utilities Commission Post Office Box 29510 Raleigh, North Carolina 27626-0510 Public Service Commission State of South Carolina Post Office Drawer 11649 Columbia, South Carolina 29211 Ms. Beverly Hall, Section Chief Division of Radiation Protection N.C. Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, North Carolina 27609-7721
Mr. Robert P. Gruber Executive Director Public Staff NCUC 4326 Mail Service Center Raleigh, North Carolina 27699-4326
Ms. Margaret A. Force Assistant Attorney General State of North Carolina Post Office Box 629 Raleigh, North Carolina 27602
Mr. Tony Gurley, Chair Board of County Commissioners of Wake County Post Office Box 550 Raleigh, North Carolina 27602
Mr. Carl Thompson, Chair Board of County Commissioners of Chatham County Post Office Box 87 Pittsboro, North Carolina 27312
Mr. John H. O'Neill, Jr.
Pillsbury Winthrop Shaw Pittman, LLP 2300 N Street NW.
Washington, DC 20037-1128
Mr. John D. Runkle Attorney at Law Post Office Box 3793
Chapel Hill, Nort h Carolina 27515-3793
Mr. Jim Warren NC Waste Awareness & Reduction Network Post Office Box 61051 Durham, North Carolina 27715-1051